RESPONSIBILITIES OF THE X-RAY SUPERVISOR (REGISTERED USER)
Definition of Supervision: responsibility for, and control of, quality, radiation safety,
and technical aspects of all X-ray examinations and procedures.
Chief radiologist or their designees (meaning other radiologists and/or physicists) are
responsible for ensuring that the fluoroscopic equipment under their jurisdiction is used
safely and effectively.
In establishing a procedures manual for the use of fluoroscopic equipment, they shall
be guided by the ALARA.
Licentiates (meaning physicians) who may use and supervise the use of fluoroscopic and
ancillary equipment: Must be holders of current and valid Radiology
Supervisor and Operator certificates.
Credentials may be validated on the RHB website.
Must be holders of current and valid Fluoroscopy Supervisor and Operator permits within the
limits of their professional licenses and their competency regarding the use of fluoroscopic
equipment.
Regarding the use of fluoroscopy equipment by holders of technologist fluoroscopy permits:
Diagnostic radiologic technologists who hold current and valid technologist fluoroscopy
permits may use fluoroscopy equipment under the supervision of a licentiate (as just described).
As a real-life example of this, in a previous job, I was asked to operate a c-arm for a
surgeon performing an ORIF (open reduction internal fixation) of a foot.
This surgeon, operating in the state of California, did not possess a supervisor and operator
permit.
In this scenario, I had previously been made aware of his frequent requests, so I had to
inform him of his options, which were very few.
He could order plain film x-ray views during surgery, where the technologist could take
a non-fluoroscopic portable x-ray machine into the OR and he would need to wait for
the CR images (at that time) to be developed.
Option 2 required a physician enter the room who had a current and valid supervisor and
operator permit for the duration of the surgical portion requiring c-arm guidance.
Or option 3, which he didn’t like at all, was to simply not use imaging guidance for
his surgical procedure.
Luckily, he was able to find another surgeon with a supervisor and operator permit to be
present.
Supervisors and Operators as well as technologists who hold fluoroscopy permits are required
to prominently display a copy of their certification document at every facility where they use
fluoroscopic equipment.
This can be the actual certificate itself or a copy if you have more than one employer.
It can also be a printed list with each holder’s full name, certificate number, and expiration
date listed, which takes up far less wall space if you work in a larger imaging department.
It should be noted, however, that whichever way your department posts these, it is important
for someone to update it regularly to ensure unexpired certificates are not on display.
You should also avoid having certificates posted for employees who have since left the
organization, and to keep them current enough so that new employees’ certificates are
visible.
You may be asking yourself, “why do I need to know all of this?” and I can assure you
it’s a basic expectation.
Yes, it will most likely be the responsibility of someone in leadership to acquire these
and keep their display current, but there are times when an accrediting organization
may ask you about them.
The last CMS inspection I experienced in California, I was asked about these very things, in addition
to the review of our annual fluoroscopic inspection logs.
CMS is the Centers for Medicare and Medicaid Services, and they will schedule routine inspections,
but can also randomly inspect a hospital without notice.
I can recall the inspector finding the display of certificates and permits issued by the
California Radiation Health Branch, and he asked me, “how do you know these are valid?”
At first, I simply pointed out the expiration dates listed on the certificates, but the
point he was making was more along the lines of “how do you know they haven’t been
suspended?” as he questioned further.
Anyone can go to the RBH website and search by certificate number, full name, or last
name at the website displayed here.
In addition to the “why do I need to know this?” question, I suppose it’s only normal
that you ask, “why should I care?”
Well, again, being a technologist as opposed to a technician involves being a healthcare
professional, meaning you should be up-to-date on rules and regulations concerning your field
and scope of practice.
But, I’d also like to add this: Regardless of accrediting body, whether it be CMS or
even the Joint Commission, just two examples of hospital accrediting bodies, failure to
comply with their accreditation standards may mean you will be required to correct the
unmet standards, or it could mean penalties or fines for your organization.
But it could also influence the revenue earned by your facility.
If accreditation standards go continuously unmet, you may lose accreditation.
Any range of these short-comings may influence the amount of Medicare and Medicaid reimbursement
for examinations and procedures already being performed.
That will not only influence your organizations finances, but ultimately will affect your
own.
As this video is being created, we’re seeing more and more federal cuts to Medicare…
the reasons are beyond the scope of this presentation, but we should be doing everything within our
scope to maintain the highest level of reimbursement for the work we perform.