Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
Response: We agree that certification by the ARRT is
widely recognized; however, ARRT certification is
voluntary, and therefore, may not be required as a
condition of employment. Requiring ARRT certification
would present an additional expense and testing obligation
that individuals who are otherwise qualified might not
choose to incur. Such a requirement would also make it
necessary for those who are already working in the field to
obtain ARRT certification if they are not already
certified.
The goal of our proposed revision was to update our
regulations to reflect the accurate accrediting entity and
program requirements for x-ray technology programs. As it
stood, the regulation was inaccurate by referencing
organizations that no longer approve and accredit x-ray
technology programs, and by specifying an outdated 24-month
program requirement. It was not our intention to consider
imposing new or additional qualification requirements for
technicians.
In accordance with existing regulations, we will
continue to recognize as qualified those individuals who
have successfully completed a program of formal training in
x-ray technology in a school approved by the JRCERT, as
well as those who have earned a bachelor’s or associate
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