LARA - CT Operator Requirements

CT Operator Requirements

Rule 705. Six months after the effective date of these rules, all CT examinations shall be performed by a radiologic technologist who meets all of the following requirements or by a physician or osteopathic physician licensed under article 15 of the act.

(a) Initial qualifications. Before beginning to perform CT examinations independently, a technologist shall meet both of the following:

(i) Be currently registered by the American registry of radiologic technologists (ARRT) or by the Canadian association of medical radiation technologists (CAMRT).
(ii) Document at least 20 hours of training and experience in operating CT equipment, radiation physics, and radiation protection or have the advanced certification in computed tomography from the ARRT.
(b) Continuing education. A technologist shall be in compliance with the ARRT requirements for continuing education for the imaging modality in which he or she performs services. The continuing education shall include credits pertinent to CT.

Discussion:
This rule goes into effect on December 8, 2011 which is 6 months after the CT rules became effective. This rule was based on the radiological technologist requirements of the American College of Radiology's CT Accreditation Program. It was modified to allow licensed physicians to operate the CT machine and it defined the amount of documented training and experience needed to meet the initial qualifications.

Question 1: Is on-the-job training acceptable for the required 20 hours training and experience in operating CT equipment, radiation physics and radiation protection?

Question 2: What is acceptable documentation for the initial qualifications?

Question 3: I have been operating CT equipment for many years prior to these rules. Will I be grandfathered to meet the initial qualifications requirement?

Question 4: Does the 10 hours not associated with the on-the-job training have to be hours approved by the ARRT or ASRT?

Question 5: I am not registered with ARRT or CAMRT but I am registered with a radiographic organization in a different country. Will I meet the initial qualifications requirement?

Question 6: I am registered with ARRT but it is in Nuclear Medicine and not in Radiography. Will I meet the initial qualification requirement?

Question 7: I am registered as a certified nuclear medicine technologist (CNMT) with the Nuclear Medicine Technology Certification Board (NMTCB). Will I meet the initial qualification requirement?

Question 8: To become certified with the ARRT in Radiography, the radiography education program I completed included training in radiation physics and radiation protection. Will this training cover the radiation physics and radiation protection portion of the required 20 hours of training?

Question 9: We use a team of two technologists to perform CT scans. Do both technologists need to be qualified under the CT rules?

Question 10: When will I need to demonstrate compliance with the CT continuing education requirements?

Question 11: We are a PET/CT facility. The radiologists bill for a diagnostic interpretation of the CT data from the PET/CT study. Some of our machine operators are NMTCB certified technologists. If the CT data is also used diagnostically, do the machine operators have to be ARRT or CAMRT registered technologists for those PET/CT studies?

Question 1: Is on-the-job training acceptable for the required 20 hours training and experience in operating CT equipment, radiation physics and radiation protection?

Training programs or facilities can count on-the-job training performing supervised CT examinations toward the 20 hour total. As guidance, however, no more than 10 hours of the required 20 should come from on-the-job training. If on-the-job training was obtained from more than one entity, each entity must provide its own letter documenting those areas that it covered.

Question 2: What is acceptable documentation for the initial qualifications?

Documentation of initial qualifications could be:

Letter or other document from training program
CEU certificates
Letter or other document confirming in-house or formal training
ARRT(CT) certificate

A letter from a training program or facility providing the training should be on official letterhead indicating the number of hours training acquired specific to CT. The letter(s) or document(s) should include the following:

a statement that the training included experience in operating CT equipment and training in radiation physics, and radiation protection
the inclusive dates when the training was given;
the name of the individual(s) supervising the training; and
the signature of a responsible official of the facility or training program.

An example of acceptable on the job training documentation could read as follows:

OFFICIAL LETTERHEAD

During the dates [INCLUSIVE DATES], [NAME] received [NUMBER OF HOURS] contact hours of training specific to CT, which included experience in operating CT equipment and training in radiation physics, and radiation protection. The training included the performance of examinations for [NUMBER OF HOURS] hours under the direct supervision of [NAME(S) OF QUALIFIED SUPERVISOR(S)].

SIGNED BY RESPONSIBLE OFFICIAL

Question 3: I have been operating CT equipment for many years prior to these rules. Will I be grandfathered to meet the initial qualifications requirement?

No. Everyone will have until December 8, 2011 to complete the 20 hours of training or to obtain the advanced certificate in CT from the ARRT.

Question 4: Does the 10 hours not associated with the on-the-job training have to be hours approved by the ARRT or ASRT?

No, it does not have to be approved by ARRT or ASRT. It can be in-house training, applications training, training by the medical physicist, or any other similar training.

Question 5: I am not registered with ARRT or CAMRT but I am registered with a radiographic organization in a different country. Will I meet the initial qualifications requirement?

The rule is specific that a CT operator must be registered with the ARRT or CAMRT. We strongly encourage you to contact ARRT or CAMRT and become registered with one of these organizations. However, the Radiation Safety Section is willing to review your credentials and make a determination if your registration meets the intent of the rule. We will grant an exception to the rule if so determined. So far we have granted an exception for registration with the Health Professions Council (U.K.) as a Diagnostic Radiographer.

Question 6: I am registered with ARRT but it is in Nuclear Medicine and not in Radiography. Will I meet the initial qualification requirement?

Yes. Any technologist that is registered with the ARRT meets the first part of initial qualification requirement. In addition to being registered, they will also have to complete 20 hours of training or obtain the advanced certificate in CT from the ARRT.

Question 7: I am registered as a certified nuclear medicine technologist (CNMT) with the Nuclear Medicine Technology Certification Board (NMTCB). Will I meet the initial qualification requirement?

No. The rule specifies that a radiologic technologist must be registered with either the ARRT or the CAMRT.

Question 8: To become certified with the ARRT in Radiography, the radiography education program I completed included training in radiation physics and radiation protection. Will this training cover the radiation physics and radiation protection portion of the required 20 hours of training?

After review of the information you provided on ARRT certification in Radiography, we have concluded that the education programs include training in radiation physics and radiation protection. If you are ARRT registered in Radiography, ARRT(R), and do not have the advanced certificate in CT, we will assume that you have had training in radiation physics and radiation protection but you will still need to document 20 hours of training and experience in operating CT equipment.

Question 9: We use a team of two technologists to perform CT scans. Do both technologists need to be qualified under the CT rules?

No. Only one technologist needs to be qualified. If a team approach is used where only one operator meets the qualifications under the rules, the qualified operator must be in the CT room during the examination. This is to provide reasonable assurance that any mistakes made by any technologist who does not meet the qualification requirements are corrected before patients are irradiated or harm is done to the patient.

Question 10: When will I need to demonstrate compliance with the CT continuing education requirements?

Continuing education requirements will be enforced beginning with the technologist's first ARRT biennium reporting period that begins after December 8, 2011, when the rule became effective. The rule requires that all non-physician CT operators be in compliance with the ARRT continuing education requirements and that each operator obtain credits pertinent to CT. The number of CT credits is not specified in the rule but must be more than 1 credit.

As an example, if the biennium reporting period begins June 1, 2012, the technologist would have until June 1, 2014, to obtain the necessary credits to renew their registration along with the required CT credits. Radiation Safety inspectors would then expect to see documentation of current ARRT registration along with documentation of the CT credits obtained during the prior biennium period.

Technologists registered with CAMRT will also need to obtain a total of 24 credits, including credits pertinent to CT over a 24 month reporting period. CAMRT technologists do not have a biennium reporting period and will have until December 8, 2013, to obtain the required credits. Newly registered CAMRT technologists will have 24 months after they begin operating CT equipment to obtain their credits. After that date, Radiation Safety inspectors will look for documentation of 24 credits including credits in CT over the 24 months prior to the inspection.

Question 11: We are a PET/CT facility. The radiologists bill for a diagnostic interpretation of the CT data from the PET/CT study. Some of our machine operators are NMTCB certified technologists. If the CT data is also used diagnostically, do the machine operators have to be ARRT or CAMRT registered technologists for those PET/CT studies?

Subrule 705(a)(i) requires CT operators to be registered with the ARRT or CAMRT. However, if diagnostic CT scans are done in conjunction with a PET scan the procedure is exempt from the requirements of Part 15.

When standalone CT scans are done using a PET/CT scanner, operators will need to meet all requirements of Rule 705. Certification with NMTCB will not be acceptable in this case.

"Diagnostic CT scans done in conjunction with a PET scan" means CT data is obtained at the same time as the PET data and the CT data is used for both the co-registered PET/CT image and for diagnostic interpretation and billing.

"Standalone CT scans" means an additional diagnostic CT scan is done while the patient is there for a PET/CT procedure or the CT portion of the PET/CT scanner is used to perform diagnostic CT scans. In this case, the facility needs to obtain a Certificate of Need for diagnostic CT scans that are not in conjunction with the PET/CT procedure.

Answer to Question #11 updated March 14, 2013

March 14, 2013