Comment Letter Submitted to Montana Board of RadiologicTechnologists in the Matter of the Proposed Amendment of ARM

June 30, 2003

Comment Letter Submitted to Montana Board of RadiologicTechnologists in the Matter of the Proposed Amendment of ARM

May 7, 2001

Board of Radiologic Technologists
301 South Park Avenue
P.O. Box 200513
Helena, Montana 59620-0513

RE: In the matter of the proposed amendment of ARM 8.56.402, 8.56.409, 8.56.602, 8.56.602A, 8.56.602C and 8.56.607

Dear Sir/Madam:

I am writing on behalf of the more than 6,000 members of the Society of Nuclear Medicine Technologist Section (SNMTS), to support the licensing of the various imaging and therapy modalities proposed in the referenced rule making. SNMTS and other organizations are currently seeking federal legislation to require state licensure of the various imaging and radiation therapy modalities as a means of improving patient safety. The proposed amendments to this rule are in keeping with that effort.

I must admit that when I first read 8.56.402(6), I was confused as to the Board's intent. When read in conjunction with the requirement for an ARRT wallet card set out in 8.56.402(5)(b), as written, the language implies that an individual must first be certified as a radiologic technologist and then certified in one or more of the additional modalities. I would omit reference to the ARRT wallet card in 8.56.402(5)(b), as a general requirement as it is only indicia of certification for some of the modalities referenced in the rules.

An alternate approach to the provisions of 8.56.402(6) would be language like:

An applicant who has been certified by the appropriate credentialing agencies in one or more disciplines and/or specialty areas within the radiologic sciences is eligible for licensure as a medical imaging technologist or radiation therapist in the appropriate disciplines and/or specialty areas.

This approach makes it clear that many of the individuals working in the modalities covered by the rule are not radiologic technologists and are certified by organizations other than ARRT.

8.506.409(3)(e) could include the nuclear medicine technology certification board (NMTCB) as one of the credentialing bodies for the bone mineral densitometry (BMD) modality. BMD is part of the education curriculum for Nuclear Medicine Technologists and some nuclear medicine departments perform BMD procedures.

8.506.409(3)(f) appears to have a typographical error. Nuclear Medicine Technologists are certified by either the ARRT or the Nuclear Medicine Technology Certification Board (NMTCB). In (f) the two certifying bodies are run together and I would suggest the insertion of a "," after "ARRT" to correct this. I would also revise the second to last line of 8.506.409(3)(f) to read, "… (radiopharmaceuticals) to produce images for diagnosis or to treat various disorders." and omit the final sentence/line.

Finally, the amended rule does not appear to cover the new "dual mode" scanners, i.e. CT/SPECT, CT/PET, etc. In California, which is a state that requires licensure of nuclear medicine technologists, when a scanner is operating in the dual mode, a nuclear medicine technologist trained to use the dual mode scanner is required because of preparation and injection of the radioactive tracer. If the scanner is being operated only in the CT mode, then a radiologic technologist educated in CT may operate the scanner. As these dual mode scanners are becoming more prevalent you might want to include language covering the personnel who will operate them in each of the modes.

I appreciate the opportunity to comment on these proposed amendments. They are a positive step in helping to assure quality medical care to patients in Montana.

As I will not be able to attend the hearing on May 9, if you have any questions about these comments, I can be reached at 703-708-9773 or by email at wuffelman@snm.org.


Sincerely,

William R. Uffelman
General Counsel and Director of Public Affairs
Society of Nuclear Medicine