Questions and Answers for Stakeholders


Below are some questions to consider asking external stakeholders about licensure or regulatory issues the affiliate may be working on.

Other medical imaging professional organizations and certification bodies:

  • What are the current issues in the state facing their profession?
  • Are they interested in seeking a legislative or regulatory remedy to the issue?
  • Would they participate with your state affiliate society in seeking licensure or provide input on draft bills or regulations?
  • Is the other stakeholder group willing to share select expenses such as state lobby day, trips to the capitol or media outreach?
  • Are the other stakeholder groups willing to lobby state lawmakers by sharing calls to action with their members?

State-level hospital association, medical association, radiologist organization and medical board:

  • Would they be supportive of your affiliate society seeking licensure in the state? Why or why not? Do they want to work with the affiliate in drafting legislation or are they willing to review bill drafts?

R.T. licensure board, Radiation Control Program Office, Department of Environmental Safety:

  • Do these organizations support changes in statute or regulations to improve professional standards or expand licensure to include other imaging disciplines?
  • What method of changing standards do they recommend? Do they need statutory authority through legislation or do they have flexibility to amend regulations without specific direction from the legislature?

Physician specialty associations and other allied health care professional organizations:

  • Do they support or oppose legislative or regulatory changes to standards for medical imaging and radiation therapy professionals?
  • How strong is their support (or opposition)? Are they willing to compromise or work to come up with alternatives if needed?
  • Are there indications that allied health professions would seek to be given the same status as licensed practitioners (M.D./D.O., dentists, chiropractors, podiatrists) exempting them from R.T. licensure requirements?
  • Are these other groups willing to meet requirements for radiation-specific education and clinical assessment?


It will be easier to communicate with stakeholders by drawing from the strategic plan and SWOT analysis that was created when the affiliate society initiated its advocacy campaign. Below are a few questions the affiliate should be prepared to answer. In order to prepare talking points the affiliate society board may want to brainstorm more questions and answers during the action planning process.

Are there some other methods of determining competence in order to protect the public, such as certification by a professional association, use of a proficiency examination or some other method? If so, licensure may not be necessary.

There may be alternative methods of achieving the primary objective ensuring certified radiologic technologists are practicing in the state. However, the voluntary nature of some of the alternatives presents an inherent weakness in that many individuals may not meet the qualifications of a certification organization. In this regard, the implementation of a state licensure program is more effective in controlling the practice of uncertified individuals than equipment operation regulations. The development of an enforceable licensure program can result in the greatest protection to the public from unnecessary exposure to ionizing radiation and the highest quality radiologic patient care.

Outline the benefits of having properly educated and certified individuals preform medical imaging and radiation therapy procedures.

Patient safety can be increased and unnecessary radiation exposure can be decreased if examinations are performed by educationally prepared and clinically competent radiologic technologists.

Be able to identify required competencies and the training or education needed to qualify for certification.

Educational programs preparing radiologic technologists, competency assessment through certification and an enforceable state licensure program are the elements needed to “ensure” that technologists are able to provide safe, high quality patient care. The public can never be one hundred percent sure of the professional competence of medical personnel, including radiologic technologists. However necessary steps to assess the competence of radiologic technologists  admitted to practice in a state can assure employers, hospitals and patients. The educational curriculum for radiologic technology is competency based, including measurable performance objectives.Certification examinations from nationally recognized organizations like the ARRT or Nuclear Medicine Technologist Certification Board are also criterion-referenced, performance-based examinations that have demonstrated the high ideals of utmost validity and reliability. Therefore the question of competence has been addressed in radiologic technology from both approaches of high quality education and valid, reliable testing.

Does the cost to the public, radiologic technologists and the employing institution justify the establishment of an occupational licensing system?

Costs involve such factors as establishment and maintenance of a licensing board or other control mechanism, periodic review of qualifying certification examinations, establishment of a record-keeping system, verification of records and so forth. Licensure is the best method available to determine the competence of a particular occupational group and create a system that enforces professional standards. For this reason the cost may be of secondary importance.

As with most any endeavors in life, there is a cost-vs.-benefit analysis to be undertaken when considering the implementation of a licensure program for any occupation, including radiologic technology. Already demonstrated in the serious nature of the utilization of ionizing radiation as a diagnostic and therapeutic tool for the diagnosis and treatment of disease and trauma. However, being realistic and cognizant of the increasing costs in health care and the current state of the economy in health care, questions relative to the implementation and operational costs of a licensure program must be addressed. Many states have already implemented licensure programs and have solved the high-cost item of developing an examination by contracting with the American Registry of Radiologic Technologists or other certification organizations for the adoption of a national certification examination as the state licensing examination. This has the effect of not reinventing the wheel. Also in terms of ongoing operational costs relative to the licensure endeavor, many states have adopted the policy of using license fees as a mechanism  to conduct the licensure program. Overall, the impact on the state budget and the effect on the health care economy is minimal.

What economic impact will the proposed licensure have on the labor market?

Again, this enters into the cost-vs.-benefit analysis indicated above; does the cost of licensure justify the increased assurance that patients are being cared for by a qualified radiologic technologist? The objective, as in the case of radiologic technology, is to restrict individuals allowed to practice radiologic technology to the extent of only those individuals having met accepted standards of education and certification, leading to qualification for state licensure. The objective is to improve the quality of care in each state. In terms of radiologic technology, the long-standing licensed states of California and New York have not demonstrated appreciable increases in the average salaries of radiologic technologists after implementation of state licensure programs. The ultimate matter of patient care must continually be kept in mind as one contemplates the cost and the benefits of such a program.