If interpreting physicians do not start working directly in mammography after meeting the initial requirements, but decide to start working at a mammography facility later, what must they do to make sure they are in compliance with MQSA?
What should facilities do before allowing new personnel, including locum tenens or those personnel who have left the facility but returned later, to provide mammography services?
Physicians who have not worked in mammography for some period of time after meeting the initial requirements need to work under direct supervision when they return to mammography, if they do not meet the continuing experience and continuing education requirements. While under direct supervision, these personnel must obtain the necessary continuing experience and CME to requalify before resuming independent work in mammography. 21 C.F.R. 900.12(a)(1)(iv). A facility may be cited during an inspection if such physicians work without supervision prior to obtaining sufficient hours of CME and continuing experience to meet the continuing requirements. Similarly, facilities should check to see that all new personnel meet all the appropriated requirements prior to letting them provide mammographic services independently. If these personnel are working independently and do not have the required continuing experience and CME/CEU, the facility may be cited for these problems.