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X-rays are high on the list of services patients expect urgent care centers to provide when needed. Currently, however, a dearth of qualified technicians can make guaranteeing that they can do so somewhat challenging.
The November issue of JUCM will start an in-depth discussion of how the industry can best approach meeting that challenge for the benefit of the patient and the individual operator. One essential part of that discussion will be answering the question of who, exactly, can perform x-rays in the urgent care center.
Qualifications aside, the answer is more complicated than you might think. So, we thought it would be beneficial to give you an overview of just how differently every state in the U.S. approaches the issue. As Alan Ayers, MBA, MAcc points out in Who Can Take X-Rays in an Urgent Care Center?, the first piece in our series, “Nearly all states require a licensed radiologic technologist (RT) to take x-rays and prohibit others from doing so.1,2 In fact, only a handful of states, do not impose any regulatory restrictions in this area.”3
The table that follows provides valuable insights.
(Note: Certification from the American Society of Radiologic Technologists requires an associate degree from an accredited school.)
| State | Regulatory Authority (URL) | Full RT License | Limited Scope License | Limited Scope Procedures |
|---|---|---|---|---|
| Alabama | Alabama Department of Health, Office of Radiation Control X-Ray Compliance Branch https://www.alabamapublichealth.gov/radiation/xray-compliance.html | No license required | Pass state-approved Industrial Radiology Exam Complete 480 hours of on-the-job training | N/A |
| Alaska | State of Alaska Dept. of Health and Social Services, Section of State Laboratories, Radiologic Health Program https://health.alaska.gov/dph/Labs/Pages/radiological/default.aspx | No license required but must complete state prescribed training in radiology technology | N/A | N/A |
| Arizona | Arizona Department of Health Services Medical Radiologic Technology https://www.azdhs.gov/licensing/special/index.php#mrt https://www.azdhs.gov/documents/licensing/special/mrtbe/steps-to-cptr-certification.pdf?v=20220701 https://qa.azsos.gov/public_services/Title_12/12-02.htm | ARRT Certification or Equivalent | 210 Training Hours 480 Clinical Hours Pass ARRT Limited Scope of Practice in Radiography Exam Must work under direction of licensed practitioner | X-ray, limited to chest and extremities |
| Arkansas | Arkansas Department of Health Radiologic Technology Licensure Program https://www.healthy.arkansas.gov/programs-services/topics/radiologic-technology-licensure-program https://ssl-adh.ark.org/programs-services/topics/frequently-asked-questions-radiologic-tech | ARRT Certification or Equivalent | 180-Day Temporary License Pass ARRT Limited Scope of Practice in Radiography Exam Must work under supervision of licensed practitioner | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam, including: Chest Extremities Skull/sinus Spine Podiatry |
| California | California Department of Health, Radiologic Health Branch (RHB) https://www.cdph.ca.gov/Programs/CEH/DRSEM/Pages/RHB.aspx https://govt.westlaw.com/calregs/Document/IC369D8F05A2011EC8227000D3A7C4BC3?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default) | ARRT Certification or Equivalent | Limited Permit X-Ray Technician School Diploma Pass state-approved radiology safety and limited scope exams | Limited scope permit required for each area: Chest Dental Extremities Leg-podiatric Skull Torso-skeletal DEXA |
| Colorado | Colorado Department of Public Health and Environment – X-Ray Certification Unit https://cdphe.colorado.gov/xray https://oitco.hylandcloud.com/CDPHERMPop/docpop/docpop.aspx | No state license required; must pass ARRT Exam | No license required 80-hours didactic hours 480 hours clinical training Perform 80 hands-on imaging procedures Pass ARRT Limited Scope of Practice in Radiography Exam 24 continuing education hours every 2 years | N/A |
| Connecticut | Connecticut State Department of Public Health – Radiographer Licensure https://portal.ct.gov/DPH/Practitioner-Licensing–Investigations/Radiographer/Radiographer-Licensure-Requirements | ARRT Certification or Equivalent | N/A | N/A |
| Delaware | Delaware Department of Public Health – Office of Radiation Control https://dhss.delaware.gov/dph/hsp/orcradtechs.html https://www.dhss.delaware.gov/dph/hsp/orcfaq.html | ARRT Certification or Equivalent | Attend approved study course Pass ARRT Limited Scope of Practice in Radiography Exam | X-ray, must pass state-approved exam in each category: Dental Limited scope medical Bone densitometry |
| District of Columbia | N/A | N/A | N/A | |
| Florida | Florida Department of Health – Council on Radiation Protection https://www.floridahealth.gov/licensing-and-regulation/radiologic-technology/index.html http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0468/0468.html | ARRT Certification or Equivalent | Pass ARRT Limited Scope of Practice in Radiography Exam Must work under supervision of licensed practitioner 12-hours continuing education every 2 years Complete department-approved course of study | All licensed may perform “basic diagnostic radiography” Separate license required for podiatry |
| Georgia | Georgia Department of Community Health https://gsrt.wildapricot.org/licensure https://rules.sos.ga.gov/gac/391-3-17 | No license required but must complete state prescribed training in radiology technology. | N/A | N/A |
| Hawaii | State Department of Health Indoor and Radiologic Health Branch https://health.hawaii.gov/irhb/radforms/ https://health.hawaii.gov/irhb/files/2013/07/radtechguide.pdf | ARRT Certification | N/A | N/A |
| Idaho | Idaho Department of Health and Welfare https://publicdocuments.dhw.idaho.gov/WebLink/DocView.aspx?id=5513&dbid=0&repo=PUBLIC-DOCUMENTS&cr=1 | N/A | N/A | N/A |
| Illinois | Illinois Emergency Management Agency https://public.iema.state.il.us/iema/radiation/radtech/radtechlogin.asp https://www.ilga.gov/commission/jcar/admincode/032/03200401sections.html | ARRT Certification or Equivalent | Pass ARRT Limited Scope of Practice in Radiography Exam Must work under direction of licensed practitioner | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam, including: Chest Extremities Skull/sinus Spine |
| Indiana | Indiana State Department of Health Division of Radiology and Weights & Measures https://www.in.gov/health/cshcr/medical-radiology-services/ https://www.in.gov/health/files/A00052.PDF | ARRT Certification or Equivalent | Complete department-approved study course Pass ARRT Limited Scope of Practice in Radiography Exam | Any radiographic procedure except: Mammography Contrast Fluoroscopy Portable surgery imaging C-arm imaging |
| Iowa | Department of Public Health https://idph.iowa.gov/permits-to-operate/general-radiologic-technologist https://idph.iowa.gov/permits-to-operate/limited-radiologic-technologist | ARRT Certification or Equivalent24 hours continuing education every 2 years | Complete state-approved online course Pass ARRT Limited Scope of Practice in Radiography Exam 12 hours continuing education every 2 years | X-ray, must complete state-approved courses in each category: Chest Spine Extremities |
| KS | Kansas State Board of Healing Arts http://www.ksbha.org/professions/LRT.shtml http://www.ksbha.org/documents/publications/PracticeHandbook_LRT.pdf | ARRT Certification or Equivalent 12 hours continuing education in 12 months preceding renewal | N/A | N/A |
| Kentucky | Kentucky Board of Medical Imaging and Radiation Therapy https://kbmirt.ky.gov/Pages/index.aspx | ARRT Certification or Equivalent 24 hours continuing education in 2-year period | Complete state-approved limited licensure course Pass state limited scope exam. | General license allows X-ray of: Thorax, lungs, ribs Abdomen Skull and sinuses Extremities Pectoral girdle, hips, pelvis Spine Separate license required for Podiatry DXMO |
| Louisiana | Louisiana State Radiologic Technology Board of Examiners https://lsrtbe.org/ Louisiana Board of Medical Examiners (Limited Scope in a Physician’s Office) https://www.lsbme.la.gov/licensure/private-radiological-technologists https://a.storyblok.com/f/150540/4ac605eeaf/radiologic-techicians.pdf | ARRT Certification | Complete board-approved course Must work under supervision of licensed physician in private practice setting | General x-ray in private practice setting under physician supervision |
| Maine | Radiologic Technology Board of Examiners https://www.maine.gov/pfr/professionallicensing/professions/radiologic-technology-board-examiners | ARRT Certification or Equivalent 24 hours continuing education in 2-year period | Complete state-approved limited licensure course Pass ARRT Limited Scope of Practice in Radiography Exam 24 hours continuing education in 2-year period | X-ray, must complete supervised procedures during training for each category, then may perform for each category passed: Skull, sinuses Spine Chest Extremities |
| Maryland | Maryland Board of Physicians – Allied Health Licensing https://www.mbp.state.md.us/licensure_ahapp.aspx https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gho§ion=14-5B-01&enactments=False&archived=False | ARRT Certification or Equivalent 24 hours continuing education in 2-year period | N/A | N/A |
| Massachusetts | Commonwealth of Massachusetts Radiation Control Program https://www.mass.gov/radiation-control https://malegislature.gov/Laws/GeneralLaws/PartI/TitleXVI/Chapter111/Section5L | ARRT Certification or Equivalent 20 hours in 2-year period | N/A | N/A |
| Michigan | Michigan Occupational Safety and Health Administration https://www.michigan.gov/leo/bureaus-agencies/miosha/divisions/technical-services-division/rad-safety/frequently-asked-questions | N/A | N/A | N/A |
| Minnesota | Minnesota Department of Health – X-Ray Program https://www.health.state.mn.us/communities/environment/radiation/xray/index.html https://www.revisor.mn.gov/statutes/cite/144.121 | ARRT Certification or Equivalent 24 hours continuing education in 2-year period | Pass state-approved exam Operators practicing before 2008 grandfathered | May only perform radiography on regions passed on state-approved exam |
| Mississippi | Mississippi State Department of Health – Professional Licensure Division (RT) http://www.msdh.state.ms.us/msdhsite/_static/30,0,82.html http://www.msdh.state.ms.us/msdhsite/_static/resources/140.pdf Mississippi State Board of Medical Licensure (Limited XR) https://www.msbml.ms.gov/Licensure/Limited_X-Ray_Machine_Operators https://www.msbml.ms.gov/sites/default/files/Licensure/Limited%20X-Ray/radteclaw.pdf | ARRT Certification or Equivalent 24 hours continuing education in 2-year period | 12 hours state-approved education 12 hours continuing education in 2-year period | May perform radiography on: Chest Abdomen Skeletal structures |
| Missouri | Missouri Department of Health and Senior Services – Missouri Radiation Control Program https://health.mo.gov/ https://health.mo.gov/safety/radprotection/pdf/xray-operator-requirements.pdf | N/A | N/A | N/A |
| Montana | Montana Department of Labor & Industry – Board of Radiologic Technologists https://boards.bsd.dli.mt.gov/radiologic-technologists/license-information/radiologic-technologist https://boards.bsd.dli.mt.gov/radiologic-technologists/license-information/limited-permit-xray | ARRT Certification or Equivalent | Complete 104-hour board-approved course OR students who have completed half of ARRT-recognized RT program Pass ARRT Limited Scope of Practice in Radiography Exam6 hours continuing education annually | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam, including: Chest Extremities Skull/sinus Spine |
| Nebraska | Nebraska Department of Health and Human Services https://dhhs.ne.gov/licensure/pages/medical-radiography.aspx https://dhhs.ne.gov/licensure/Documents/Medical%20Radiography%20Practice%20Act.pdf https://www.nebraska.gov/rules-and-regs/regsearch/Rules/Health_and_Human_Services_System/Title-172/Chapter-093.pdf | ARRT Certification or Equivalent | Pass ARRT Limited Scope of Practice in Radiography Exam 24 hours continuing education in 2-year period | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam, including: Chest Extremities Skull/sinus Spine Ankle and foot Bone density |
| Nevada | Nevada Division of Public and Behavioral Health https://dpbh.nv.gov/Reg/Radiation_Control_Programs/ https://www.leg.state.nv.us/nac/nac-459.html | N/A | N/A | N/A |
| New Jersey | State of New Jersey Department of Environmental Protection – Radiation Protection Element https://www.state.nj.us/dep/rpp/tec/index.htm https://www.state.nj.us/dep/rpp/tec/LicInfo.htm | ARRT Certification or Equivalent | Limited Chest – Complete 350-hour board-approved course Limited Orthopedic – Complete 1,400-hour board-approved course Pass board-approved exam or equivalent | X-ray, must obtain license for each area of practice, including: Chest Orthopedic Podiatric Dental Licenses also available for: Fusion Imaging CT Urologic fluoroscopy |
| New Hampshire | State of New Hampshire Office of Professional Licensure and Certification Board of Medical Imaging and Radiation Therapy https://www.oplc.nh.gov/board-medical-imaging-and-radiation-therapy http://www.gencourt.state.nh.us/rsa/html/XXX/328-J/328-J-11.htm | ARRT Certification or Equivalent | Complete board-approved course of study in limited x-ray machine operation Pass board-approved exam | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam or equivalent, including: Chest Extremities Skull/sinus Spine Ankle and foot Bone density |
| New Mexico | New Mexico Environment Department – Medical Imaging and Radiation Therapy Program https://www.env.nm.gov/rcb/medical-imaging-radiation-therapy-program/ https://www.srca.nm.gov/parts/title20/20.003.0020.html | ARRT Certification or Equivalent | Complete state-approved limited radiology program Pass state-approved exam or equivalent 24 hours continuing education in 2-year period | X-ray, limited to: Viscera of thorax Extremities Axial/appendicular skeleton Foot, ankle, lower leg Dental |
| New York | New York State Department of Health https://www.health.ny.gov/professionals/doctors/radiological/ https://www.health.ny.gov/environmental/radiological/radon/docs/part_89.pdf | State-approved exam or ARRT Certification or Equivalent 12 hours continuing education annually | N/A | N/A |
| North Carolina | North Carolina Department of Health and Human Services – Radiology Compliance Branch http://reports.oah.state.nc.us/ncac.asp?folderName=%5CTitle%2010A%20-%20Health%20and%20Human%20Services%5CChapter%2015%20-%20Radiation%20Protection https://www.ncsrt.org/legislative | N/A | N/A | N/A |
| North Dakota | Medical Imaging and Radiation Therapy Board https://www.ndmirtboard.com/ https://www.ndmirtboard.com/lic/LimitedX-RayMachineOperator.asp | ARRT Certification or Equivalent | Must already be PA, RN/LPN, Tech, PT/PTA, or petition the board Completed board-approved course of study Complete 31 clinical competency exams ARRT LXMO exam 12 hours continuing education per 2-year period | X-ray, limited to: Chest/ribs Abdomen Extremities Foot/ankle Skull/sinuses Spine Other procedures may be performed during emergency with provider order and personal supervision |
| Ohio | Ohio Department of Health – Radiologic Licensure https://odh.ohio.gov/know-our-programs/radiologic-licensure/radiologic-licensure https://odh.ohio.gov/know-our-programs/radiologic-licensure/general-info-fees/radiologic-licensure-radiographer-requirements https://codes.ohio.gov/ohio-administrative-code/rule-3701-72-02 | State-approved exam or ARRT Certification or Equivalent 24 hours continuing education in 2-year period | Complete state-approved education program or be enrolled in RT program Complete state-approved clinical education program Pass state-approved exam 12 continuing education hours in radiation safety | X-ray, complete competency-based clinical modules for each area, including: Chest and abdomen Extremities Skull/sinus Spine Podiatric Bone density |
| Oklahoma | Oklahoma Medical Board https://www.okmedicalboard.org/radiologist_assistants#laws-rules https://www.okmedicalboard.org/radiologist_assistants/download/483/RALaw.pdf | N/A | N/A | N/A |
| Oregon | Oregon Board of Medical Imaging https://www.oregon.gov/obmi/resources/Pages/default.aspx https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=1418 | ARRT Certification or Equivalent | Complete board-approved course of study Complete board-approved clinical study Pass ARRT Limited Scope of Practice in Radiography Exam Must work under supervision of licensed practitioner 18-24 hours continuing education per 2-year period (dependent on number of anatomical areas certified) | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam including: Skull/sinus Spine Chest Extremities Podiatric |
| Pennsylvania | Pennsylvania Department of State – State Board of Medicine https://www.dos.pa.gov/ProfessionalLicensing/BoardsCommissions/Medicine/Pages/Radiology-Technician-Licensure-Requirements-Snapshot.aspx http://www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/049/chapter18/subchapEtoc.html&d=reduce | ARRT Certification or Equivalent 24 hours continuing education per 2-year period | Pass ARRT Limited Scope of Practice in Radiography Exam | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam including: Skull/sinus Chest Extremities |
| Rhode Island | State of Rhode Island Department of Health https://rules.sos.ri.gov/regulations/part/216-40-05-34 | ARRT Certification or Equivalent | N/A | N/A |
| South Carolina | SC Radiation Quality Standards Association https://www.scrqsa.org/ https://cdn.ymaws.com/www.scrqsa.org/resource/resmgr/Governance/Final_Rules_and_Procedures_J.pdf | ARRT Certification or Equivalent 24 hours continuing education in 2-year period (excluding first renewal) | Complete board-approved course of study Pass board-approved exam | May apply for limited license in the following areas: General Chest only Chiropractic Podiatric Bone density |
| South Dakota | South Dakota Department of Health https://doh.sd.gov/providers/licensure/xray.aspx https://sdlegislature.gov/Rules/Administrative/17498 https://sdlegislature.gov/Rules/Administrative/17500 | No state license required. ARRT Certification, another state license, or 40 hours training required to operate 5 hours continuing education per 3-year period | No state license required. ARRT Certification, another state license, or 40 hours training required to operate 5 hours continuing education per 3-year period | N/A |
| Tennessee | Tennessee Department of Health – Board of Medical Examiners https://www.tn.gov/health/health-program-areas/health-professional-boards/me-board/me-board/xray-operators.html https://publications.tnsosfiles.com/rules/0880/0880-05.pdf | ARRT Certification or Equivalent | Complete state-approved training course Pass ARRT Limited Scope of Practice in Radiography Exam | X-ray, must be certified for each area: Chest Extremities Spine Skull/sinus |
| Texas | Texas Medical Board https://www.tmb.state.tx.us/page/licensing-full-medical-radiologic-technologist https://www.tmb.state.tx.us/page/licensing-limited-medical-radiologic-technologist | ARRT Certification or Equivalent | Pass ARRT Limited Scope of Practice in Radiography Exam Pass Texas Medical Jurisprudence Exam | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam including: Skull/sinus Spine Chest Extremities Podiatric |
| Utah | Utah Department of Commerce – Division of Occupational and Professional Licensing https://dopl.utah.gov/rad/ | ARRT Certification or Equivalent 24 hours continuing education per 2-year period | Pass ARRT Limited Scope of Practice in Radiography Exam 10 hours continuing education per 2-year period | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam including: Skull/sinus Spine Chest Extremities Podiatric |
| VT | Vermont Secretary of State – Office of Professional Regulation Radiologic Technology Licensing https://legislature.vermont.gov/statutes/fullchapter/26/051 http://www.vtlmi.info/licocc.cfm?page=index#L | ARRT Certification24 hours continuing education per 2-year period | N/A | N/A |
| Virginia | Virginia Department of Health Professions – Board of Medicine https://www.dhp.virginia.gov/Boards/Medicine/AbouttheBoard/RegulatedProfessions/RadiologicTechnology/ http://www.dhp.virginia.gov/media/dhpweb/docs/med/leg/RadTech.pdf | ARRT Certification or Equivalent | Minimum 50-hour board-approved education course Pass ARRT Limited Scope of Practice in Radiography Exam | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam including: Skull/sinus Spine Chest Extremities Podiatric To perform x-ray of abdomen/pelvis, must have 25 additional clinical hours |
| Washington | Department of Health https://doh.wa.gov/licenses-permits-and-certificates/professions-new-renew-or-update/radiologic-technologist https://app.leg.wa.gov/rcw/default.aspx?cite=18.84&full=true&pdf=true https://doh.wa.gov/sites/default/files/legacy/Documents/Pubs/686046.pdf?uid=6312322ec87bb | Complete board-approved education course Pass state-approved exam or ARRT exam | Complete registration form | X-ray of: Skull/sinus Spine Chest Extremities |
| West Virginia | Medical Imaging and Radiologic Technologists Board of Examiners https://www.wvrtboard.org/ http://www.wvlegislature.gov/wvcode/code.cfm?chap=30&art=23#01 | Complete state-approved education course Pass state-approved exam or ARRT exam | N/A | N/A |
| Wisconsin | Department of Safety and Professional Services https://dsps.wi.gov/Pages/Professions/RadiographerLicensed/Default.aspx https://docs.legis.wisconsin.gov/statutes/statutes/462/03/1/b | ARRT Certification or Equivalent | Complete board-approved course of study Pass board-approved exam | X-ray of: Chest Extremities (excluding pelvis/hips) Foot and ankle Spine |
| Wyoming | Board of Radiologic Technologists Examiners https://radiology.wyo.gov/ https://docs.google.com/document/d/1JVoRBb4Us3dNpjRu2z54nae-YDXvzNbGl_oaxKznFV4/edit https://drive.google.com/file/d/1jVv-cFttz5cdYOimYv9eu4eZBUp2StaF/view | ARRT Certification or Equivalent | Pass ARRT Limited Scope of Practice in Radiography Exam | X-ray, all areas/modules passed on Limited Scope of Practice in Radiography Exam including: Skull/sinus Spine Chest Extremities Podiatric |
References
- See Buchanan v Dept of Health. 322 So. 3d 238, 239 (Fla. DCA 2021).
- Commonwealth v Kattupalli, 221 A.3d 238 (Pa. Super. Ct. 2019).
- Individual State Licensure Information. American Society of Radiologic Technologists. Available at: https://www.asrt.org/main/standards-and-regulations/legislation-regulations-and-advocacy/individual-state-licensure.
For more on this timely and important topic, watch for the November and December issues of JUCM.
What Qualifies Someone to Take X-Rays in the Urgent Care Center? It All Depends on Where You’re Located