State certification for nuclear medicine technologists has been a difficult goal to accomplish. Some states, such as California and South Carolina, have had standards in place requiring nuclear medicine technologists to have education and hold certification by the Nuclear Medicine Technology Certification Board (NMTCB) or American Registry of Radiologic Technologists (ARRT). Many states, like Georgia and North Carolina, do not have any language whatsoever governing anyone who injects radiopharmaceuticals and images patients.
For more than 10 years the hope for resolution rested upon the Consistency, Accuracy, Responsibility and Excellence (CARE) in Medical Imaging and Radiation Therapy bill, which would force imaging centers and institutions to use certified technologists in order to obtain federal reimbursement for imaging. However, it would not require states to develop state licensure or modify existing licensing procedures.
In the possible event that the CARE bill does not pass again this year, how can states advocate nuclear medicine technologist certification as a standard requirement for practicing? A new tool is Part Z of the Conference of Radiation Control Program Directors (CRCPD) Suggested State Regulations for Control of Radiation, which concerns medical credentialing.
The CRCPD is a non-profit and non-governmental organization dedicated to radiation protection. Most of the membership is made up of state and local governments that regulate the use of radiation sources. However, federal organizations like the Nuclear Regulatory Commission (NRC), Departments of Energy and Homeland Security, Food and Drug Administration - Medical Devices, Federal Emergency Management Agency, and many others work as partners with the CRCPD. In 1959 individual states were given their own authority aside from the NRC and were allowed maintain their own radiation safety programs. They were called Agreement States. In the past it was all too often that radiation protection policies, rules and laws were inconsistent with other state and local groups. The CRCPD strives to maintain continuity of language for all levels of radiation control and it writes guidelines for facilitation of that goal.
One type of guideline the CRCPD writes is its suggested state regulations (SSRs), which are living documents that address matters of radiation regulation. These guidelines are suggested models for states to assist in creating their own rules. Some of these include Part C - Licensing of Radioactive Materials, Part F - X-Rays in Healing Arts, and Part G - Use of Radionuclides in the Healing Arts. Once the draft of an SSR is completed, the federal organizations review and provide feedback. The process is completed and the document is published. When new issues arise and the SSRs need to be addressed, the documents are edited and approved.
One of the CRCPD's latest SSRs is Part Z - Medical Credentialing. This new SSR is a model state licensing guideline and represents the template for suggested language regarding nuclear medicine technologists and what the CRCPD suggests for their function and the operation of equipment. The definition of a nuclear medicine technologist is, "a person, other than a licensed practitioner, who administers radiopharmaceuticals and related drugs to human beings for diagnostic purposes, performs in vivo and in vitro detection and measurement of radioactivity and administers radiopharmaceuticals to human beings for therapeutic purposes. A nuclear medicine technologist may perform such procedures only while under the general supervision of a licensed practitioner who is licensed to possess and use the radiopharmaceuticals involved."
In addition, the Part Z rationale states that since nuclear medicine technologists who pass the ARRT's CT exam are qualified to operate CT equipment, the Part Z needed to be amended to accommodate for them. As long as the nuclear medicine technologist is qualified there can be no argument for health or safety basis.
Also stated in the rationale is the operation of PET/SPECT CT scanners. Nuclear medicine technologists should be allowed to operate a hybrid PET/SPECT CT scanner without having to be a radiographer. Having two technologists, one nuclear medicine and one radiographer is "impractical and unwarranted." CT is now part of the student curriculum and, as such, students are tested in entry-level certification exams. Consideration for nuclear medicine technologists, seasoned or new and if necessary, "can be given to requiring these individuals to also complete a typical manufacturer's training course for new CT operators. Such courses are usually 15 hours in length, and include equipment operation, contrast media, sectional anatomy and CT radiation protection." This can impact current state licensure issues.
If the CARE bill does not pass, the CRCPD's SSR Part Z - Medical Credentialing is what states can use to facilitate licensure. In addition, states that do not license nuclear medicine technology or even under regulate it can use this document. Should the CARE bill pass, this document can be provided to the Secretary of Health and Human Services to aid in writing the implementation of the law. This is a victory for nuclear medicine technology.
Conference of Radiation Control Program Directors
CRCPD SSR Part Z Medical Credentialing
CRCPD SSR Part Z Medical Credentialing Rationale
Cindi Luckett-Gilbert, MHA, CNMT, PET, FSNMTS, is PET specialist for Shertech Pharmacy.