We use the same locum tenens interpreting physician (or "temporary" radiologic technologist) on a recurring basis throughout the year. Do we need to handle the personnel records for this person differently from our "permanent" interpreting physicians (radiologic technologists)? Which records will be reviewed at the time of our next inspection?
If the locum tenens interpreting physician (or “temporary” radiologic technologist) reads for (or performs mammograms for) the facility on a recurring basis throughout the year, the facility can treat this person as “permanent” for purposes of the annual inspection. In that event, the facility has to show that this person met all the requirements (including the continuing requirements, when appropriate) on the date of the inspection.
If the facility considered this person “temporary” and not working at the facility at the time of the inspection, the facility has to show that this person met all the requirements (including the continuing requirements, when appropriate) on each of the multiple occasions this person started reading (or performing mammograms) at the facility.
For example, if the person worked for a week at a time starting the 15th day of each month, the facility is responsible for documenting that the person was qualified on each of those 12 occasions. This is not as daunting a task as it first appears. The facility needs to document that the person was fully qualified the first time he/she started working at the facility. In addition, in each of the calendar quarters the person worked, the facility needs to document (before letting the person provide mammography services) that the person met the continuing requirements (when appropriate) and maintained a valid medical license (or valid State license or certification).