• ASRT Announcement

Joint Commission CT Response

Jul 11, 2016

RE: New Requirements for Diagnostic Imaging Services – Urgent Update

Dear Ms. Marshall:

The American Society of Radiologic Technologists (ASRT) appreciates the opportunity to participate in, and comment on, the Joint Commission’s proposed standards for personnel performing diagnostic computed tomography (CT).

In a communication published on June 17, 2016, The Joint Commission stated that Note 1, as part of HR.01.02.05, EP 19, has been deleted and implementation of HR.01.05.03, EP 26, is suspended. The ASRT respectfully submits the following comments in regard to the recent urgent update to the new requirements for diagnostic imaging services.

HR.01.02.05 EP 19, Note 1
The ASRT understands that some health care facilities, specifically critical access hospitals, might encounter staffing difficulties if the standard requiring certification in CT is enacted. We also agree that the provision of CT services at all health care facilities is a critical component of efficient, effective and safe diagnosis.

The ASRT is disappointed that Note 1 was removed from HR.01.02.05, EP 19, especially in the standards for Ambulatory Care Organizations (ACOs) and Hospitals. Removing Note 1 from HR.01.02.05, EP19 sends the message to medical imaging technologists and their employers that being educationally prepared and clinically competent in CT is not necessary to provide safe, high-quality CT procedures.

As outlined in the ASRT Practice Standards for Medical Imaging and Radiation Therapy, ASRT and its members support standards the require technologists to be certified in their area(s) of practice. We also back the position emphasizing that certification is the most valid way to document technologist qualifications and competency when performing procedures. Also, ASRT’s Computed Tomography Practice Standards state that technologists who perform CT procedures should obtain postprimary certification in CT. The ASRT believes that personnel who have completed education and achieved certification, specifically in CT, by the American Registry of Radiologic Technologists (ARRT) or Nuclear Medicine Technology Certification Board (NMTCB), provide the safest, highest-quality care to patients undergoing CT procedures.

The ASRT believes that medical imaging personnel in both ambulatory care organizations and hospitals have the resources available to obtain the structured education and clinical examinations to qualify to sit for either the ARRT or NMTCB CT certification exams, and that all personnel performing CT in ACOs or hospitals should have CT certification to maintain compliance with the Joint Commission standards.

HR.01.05.03, EP 26
The ASRT is disappointed that HR.01.05.03, EP26 was suspended. The ASRT believes that, at minimum, completing the structured education to qualify for certification should be required by all personnel performing diagnostic CT examinations, as there are no barriers to access educational products designed for this purpose. Suspending HR.01.05.03, EP26 sends the message to medical imaging technologists and their employers that being educationally prepared in CT is not necessary to provide safe, highquality CT procedures.

The ASRT does not understand how requiring this standard would adversely affect patient access to CT services. Structured, or didactic, education required to prepare and qualify for both the ARRT and NMTCB CT certifications is widely available to all medical imaging professionals and can be completed even in the most remote areas of the United States. Several organizations offer online courses that meet or exceed the requirements for qualifying for certification. Most of the online courses are offered as self-learning activities, so medical imaging personnel can complete these at their own pace without the need to travel. In addition, we have had several CT technologists ask us if the rule to suspend the education component means that it will revisited in the future? Can you please clarify for CT technologists who have asked about this measure?

The ASRT hopes that The Joint Commission will continue to move toward requiring certification for personnel performing diagnostic CT.

Thank you for your consideration of ASRT’s comments. If we can provide additional information, please do not hesitate to contact me or Liana Watson, ASRT's Associate Executive Director for Operations and Governance.

Sincerely,

Sal Martino, Ed.D., R.T.(R), FASRT, CAE
Executive Director and Chief Executive Officer
American Society of Radiologic Technologists

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