CMS has omitted language that would require registered radiologic technologists to perform all radiography procedures billed within the Medicare system. By leaving out a measure requiring that registered radiologic technologists must perform procedures, CMS is conceding that uneducated, unqualified and unprepared personnel could perform radiologic technology duties.

The field of radiology encompasses individuals who are academically prepared and clinically competent in their modality of expertise within the professional practice discipline. Many of these modalities utilize ionizing radiation that has the potential to be harmful to patients and the general public if utilized by individuals who are not academically and clinically trained. Radiologic Technologists have the academic and clinical competencies specifically in areas pertaining to radiation biology, radiation safety, radiopharmacy, as well as associated instrumentation. On the other hand, nurses do not have the academic preparation nor clinical expertise in these important aspects of professional practice. Simply stated, nurses are not qualified to be performing radiology procedures and allowing them to do so would put patient safety and public health at risk.

So what can you do? Let your voice be heard. Comment Now! Ask CMS to include language in the physician fee proposal that all radiography procedures billed within the Medicare payment system be performed only by registered radiologic technologists.

To comment, go to: Medicare Program: Payment Policies under the Physician Fee Schedule and also to Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems. Please submit comments to both proposals. The public comment period is open until September 6, 2016.

OSRT is always looking out for the safety of consumer patients as well as our fellow Radiologic Technologists! Help us help you!