Active Technologist
What is a Radiologic Technician/Technologist?
According to the FDA’s MQSA, a radiologic technician is “an individual specifically trained in the use of radiographic equipment and the positioning of patients for radiographic examinations and who meets the requirements set forth in Sec. 900.12(a)(2).” (FDA, 2017)
What is an active technologist?
An active technologist is an individual currently working at a facility who meets all requirements to be considered a radiologic technician by the FDA’s MQSA.
What are the requirements to be considered a Radiologic Technician?
The FDA’s MQSA lists the requirements to be considered a Radiologic Technician as:
“(i) General requirements.
(A) Be licensed to perform general radiographic procedures in a State; or
(B) Have general certification from one of the bodies determined by the FDA to have procedures and requirements adequate to ensure that radiologic technologists certified by the body are competent to perform radiologic examinations; and
(ii) Mammography requirements.
Have, prior to April 28, 1999, qualified as a radiologic technologist under paragraph (a)(2) of this section of FDA's interim regulations of December 21, 1993, or completed at least 40 contact hours of documented training specific to mammography under the supervision of a qualified instructor. The hours of documented training shall include, but not necessarily be limited to:
(A) Training in breast anatomy and physiology, positioning and compression, quality assurance/quality control techniques, imaging of patients with breast implants;
(B) The performance of a minimum of 25 examinations under the direct supervision of an individual qualified under paragraph (a)(2) of this section; and
(C) At least 8 hours of training in each mammography modality to be used by the technologist in performing mammography exams” (Mammography Quality Standards Act Regulations, 2022)
What are the Continuing Education and Experience requirements for a Radiologic Technician?
The FDA’s MQSA lists the Continuing Education and Experience requirements for a Radiologic Technician as:
“(iii) Continuing education requirements.
(A) Following the third-anniversary date of the end of the calendar quarter in which the requirements of paragraphs (a)(2)(i) and (a)(2)(ii) of this section were completed, the radiologic technologist shall have taught or completed at least 15 continuing education units in mammography during the 36 months immediately preceding the date of the facility's annual MQSA inspection or the last day of the calendar quarter preceding the inspection or any date in between the two. The facility will choose one of these dates to determine the 36-month period.
(B) Units earned through teaching a specific course can be counted only once towards the 15 required in paragraph (a)(2)(iii)(A) of this section, even if the course is taught multiple times during the previous 36 months.
(C) At least six of the continuing education units required in paragraphs (a)(2)(iii)(A) of this section shall be related to each mammographic modality used by the technologist.
(D) Requalification. Radiologic technologists who fail to meet the continuing education requirements of paragraph (a)(2)(iii)(A) of this section shall obtain a sufficient number of continuing education units in mammography to bring their total up to at least 15 in the previous 3 years, at least 6 of which shall be related to each modality used by the technologist in mammography. The technologist may not resume performing unsupervised mammography examinations until the continuing education requirements are completed.
(E) Before a radiologic technologist may begin independently performing mammographic examinations using a mammographic modality other than one of those for which the technologist received training under paragraph (a)(2)(ii)(C) of this section, the technologist shall have at least 8 hours of continuing education units in the new modality.
(iv) Continuing experience requirements.
(A) Following the second-anniversary date of the end of the calendar quarter in which the requirements of paragraphs (a)(2)(i) and (a)(2)(ii) of this section were completed or of April 28, 1999, whichever is later, the radiologic technologist shall have performed a minimum of 200 mammography examinations during the 24 months immediately preceding the date of the facility's annual MQSA inspection or the last day of the calendar quarter preceding the inspection or any date in between the two. The facility will choose one of these dates to determine the 24-month period.
(B) Requalification. Radiologic technologists who fail to meet the continuing experience requirements of paragraph (a)(2)(iv)(A) of this section shall perform a minimum of 25 mammography examinations under the direct supervision of a qualified radiologic technologist, before resuming the performance of unsupervised mammography examinations.” (Mammography Quality Standards Act Regulations, 2022)
What are the different types of Radiologic Technicians mentioned within the mammography audit?
The mammography audit lists two types of Radiologic Technicians: 1) Primary Technologist and 2) Secondary Technologist.
Sources: "Mammography Quality Standards Act Regulations". U.S. Food And Drug Administration, 2017,https://www.fda.gov/radiation-emitting-products/regulations-mqsa/mammography-quality-standards-act-regulations#s9002.