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<strong>CMS</strong>-1403-FC<br />

not a recognized accrediting body under the current<br />

regulation at §486.104.<br />

Before an x-ray technology program can be <strong>approved</strong> by<br />

JRCERT, the American Society of Radiologic Technologists<br />

(ASRT) must approve the program’s curriculum. Prior to<br />

1992, the curriculum for x-ray technology programs was<br />

based on 24 months, which is reflected in the current<br />

regulations at §486.104. ASRT no longer bases its<br />

evaluation on program duration, but rather on program<br />

requirements. Thus, a program could be less than 24 months<br />

in duration and still be eligible for JRCERT approval and<br />

accreditation if its curriculum was ASRT <strong>approved</strong>. Because<br />

§486.104(a)(1) reflects the outdated 24-month standard,<br />

some x-ray technicians who actually meet community<br />

standards for education and training do not meet Medicare<br />

standards as they stand.<br />

Since the current Medicare requirements in<br />

§486.104(a)(1) are outdated, referencing organizations that<br />

no longer perform the stated function and requiring a<br />

specific duration of training that is no longer the<br />

community standard, we proposed to revise the regulation to<br />

reflect the current requirements. References to schools<br />

<strong>approved</strong> by the CEAMA or the AOA will be deleted, and<br />

approval by JRCERT will be added. In addition, we proposed<br />

718

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