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

that the requirement for formal training of not less than<br />

24 months in duration be deleted, since this criterion <strong>has</strong><br />

not <strong>been</strong> part of the criteria established by entities that<br />

evaluate and approve x-ray technology programs since 1993.<br />

We proposed to retain the 24-month criterion in<br />

§486.104(a)(2) and (a)(3) (affecting persons obtaining<br />

training prior to July 1, 1966) as program duration was one<br />

determinant of program quality at that time. To address<br />

those who completed their training after July 1, 1966 but<br />

before January 1, 1993, the time period during which CEAMA<br />

and the AOA were approving training programs, we proposed<br />

the addition of a new paragraph §486.104(a)(4) to this<br />

section. <strong>This</strong> addition will reflect the standards for<br />

credentialing activities during this time frame.<br />

The following is a summary of the comments we received<br />

and our responses.<br />

Comment: Commenters suggested an alternate<br />

requirement for qualification as an x-ray technologist,<br />

namely American Registry of Radiologic Technologists (ARRT)<br />

certification. The commenters also stated that restricting<br />

recognition to only graduates of JRCERT accredited<br />

educational programs could create a shortage of<br />

radiographers eligible to furnish procedures.<br />

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