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SOCIETY OF NUCLEAR MEDICINE TECHNOLOGIST SECTION POSITION ...

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    SOCIETY OF NUCLEAR MEDICINE TECHNOLOGIST SECTION POSITION ... SOCIETY OF NUCLEAR MEDICINE TECHNOLOGIST SECTION POSITION ... Document Transcript

    • SOCIETY OF NUCLEAR MEDICINE TECHNOLOGIST SECTION POSITION PAPER ON LICENSURE *****PREAMBLE***** In 1981, Congress passed the Consumer-Patient Radiation Health and Safety Act (Public Law 97-35). This act mandated the Secretary of Health and Human Services (HHS) to develop minimum accreditation and certification standards and to prepare and transmit to the States a model statute for radiologic procedure safety. This model statute was to provide that: 1. "It shall be unlawful in a State for individuals to perform radiologic procedures unless such individuals are certified by the State to perform such procedures and; 2. Any educational requirements for certification of individuals to perform radiologic procedures shall be limited to educational programs accredited by the State." The act required HHS to issue "final" regulations in 1982. Not until July 1983 did the HHS publish minimum standards, and were of particular note, "proposed" standards. On August 14, 1985, a suit of noncompliance was filed in U. S. District Court, D. C. by the American Society of Radiologic Technologists (ASRT) (Plaintiff) against Margaret M. Heckler, Secretary-HHS and the U. S. Department of Health and Human Services (HHS) (Defendants). Because of the action filed by the ASRT, final regulations were published on December 11, 1985 in the Federal Register.
    • ***PREAMBLE: POSITION PAPER ON LICENSURE*** According to the Position Paper on Licensure (Revised 6/80and 2/94) of the Society of Nuclear Medicine Technologist Section (SNMTS), it states that in states which have enacted legislation to regulate and register radiologic and nuclear medicine technologists, the SNMTS will work to insure there is appropriate recognition of: Nuclear Medicine Technology Certification Board (NMTCB), Verification of Involvement in Continuing Education (VOICE), Society of Nuclear Medicine (SNM) and Society of Nuclear Medicine Technologist Section (SNMTS). In states that have not adopted such legislation, the SNMTS will proactively participate to supply accurate data regarding the practice of nuclear medicine technology in that state. It is imperative that the best interests of the health care community, the state's fiscal condition and that of nuclear medicine technology be protected.
    • POSITION PAPER ON LICENSURE Licensure of allied health personnel is a topic of rapidly growing importance to regulatory agencies at the federal, state, and local levels as well as to professional organizations and its members. Owing to increasing interest in and concern about licensure, the SNMTS has developed the following position on licensure for nuclear medicine technologists. Formed in 1970, the SNMTS is a professional organization embracing scientific and educational activities, which satisfy its membership needs. The SNMTS is the only professional organization singularly dedicated to nuclear medicine technology and related activities. The Technologist Section's ongoing objectives are to maintain the identity and quality of nuclear medicine technologists and to provide the continuing development, improvement, and expansion of nuclear medicine technology for the betterment of health care services. The SNMTS is committed to assuring adequate education and competency of nuclear medicine technologists. To guarantee this objective for nuclear medicine technologists, the Section has provided in-depth activities and on-going involvement in the development of voluntary certification examinations for nuclear medicine technologists (Addendum A). The Nuclear Medicine Technology Certification Board, (Addendum B), sponsored by the Section, has developed and published a comprehensive task analysis of nuclear medicine technology which is the basis for the NMTCB certification examination and which has been integrated into its criterion reference examination (Addendum C). The Section has direct input into and has accepted obligations for the collaborative development of minimum education essentials for
    • nuclear medicine technology. Additionally, the Section has direct input into and accepted participatory technology for the Committee on Allied Health Education and Accreditation (CAHEA) Joint Review Committee on Educational Programs in Nuclear Medicine Technology (Addendum D). Further, the Section is actively involved in the preparation and conduct of scientific and educational meetings consisting of approved and documented continuing educational programs for the nuclear medicine professional. A. NUCLEAR MEDICINE DEFINED Nuclear medicine is the medical specialty that utilizes the unique properties of radioactive and stable nuclides to make diagnostic evaluations of the anatomic or physiologic conditions of the body and to provide therapy with unsealed radioactive sources. This utilization includes the administration of radiopharmaceuticals to a patient and the subsequent imaging of its distribution in organ systems and/or laboratory assay procedures. The professional role of the nuclear medicine technologist is to assist the licensed physicians in the conduct and evaluation of clinical procedures, including the preparation, calibration, quality control and administration of radiopharmaceuticals, as well as the operation of both imaging, radioassay instruments and computer systems. B. ELEMENTS OF LICENSURE The following important elements of licensure should be considered:
    • 1. Uniformity and consistency of licensure regulations and reciprocity among all states are of utmost pragmatic priority. National standards used as criteria for certification, licensure, employment and requirements for reimbursement (Medicare/Medicaid and National Health Insurance) are imperative. The Section is actively supporting the development of national standards for certification as sponsored by the National Commission of Health Certifying Agencies and the U. S. Department of Health and Human Services. (Addendum E) 2. In any licensure approach that is initiated, individuals currently employed as nuclear medicine technologists must be allowed to perform the nuclear medicine technology procedures for which he has been trained. Fractionalization may result if differently trained individuals are allowed by law to only perform procedures on humans or on specimens from humans. Conceptually, a licensure approach is to assure competency among practitioners. Excluding individuals from the right to practice is not the answer. Also of practical importance is the mechanism for licensure of a practitioner of nuclear medicine technology in sparsely populated regions where one health professional is performing in more than one health occupation (e.g., nuclear medicine and diagnostic radiology). A general license may be needed in these situations. 3. The Technologist Section believes that certification examinations are the central points of all licensure approaches. Currently, the Nuclear Medicine Technology Certification Board prepares and administers an examination in nuclear medicine technology and could provide this examination in a licensure program. The duality of credentialing and task analysis activities presents a unique and impressive interrelated framework upon
    • which to evaluate the competency of nuclear medicine technology in the delivery of health care. 4. Essentials of education and accreditation of educational programs are important facets in striving for professional competency and should be incorporated into a licensure approach. The Technologist Section and the Society of Nuclear Medicine are two of the sponsoring organizations of the Joint Review Committee on Educational Programs in Nuclear Medicine Technology, which is the review and evaluation body that grants approval to allied health education programs. 5. Acceptable levels of on-the-job training should be evaluated and included as acceptable criteria for licensure eligibility. Examinations must be developed in concert with the minimum educational essentials and task analysis for individuals not qualifying for voluntary national certification. 6. Demonstration of continued competency should be included in any licensure approach. Performance assessment methods are means of striving for continued competence. Continuing education is one of the primary objectives of the Technologist Section and is considered by the Technologist Section as the first step towards the assurance of continued competence. The Section implements numerous continuing educational programs annually on the national, regional and local level. To Verify and assess the involvement of participants in these educational programs, the Section has implemented its own system of review and approval of continuing education units (CEU's) as defined by the Office of Education. This system, Verification of Involvement in Continuing Education (VOICE) records all VOICE approved activities of a SNMTS member to account for and document his involvement in SNMTS approved continuing education
    • activities. Performance assessment methods may include recertification and/or evaluation techniques such as self-assessment questionnaires. Performance assessment methods and/or continuing education programs can fulfill the important objectives of assuring competency. C. LICENSURE APPROACHES There are three approaches that can be taken to implement state licensure: 1. Individual state licensure in which each state establishes its own criteria and minimum standards for educational program accreditation, technologist certification and licensure. 2. States would be required to adopt federal standards or develop more stringent state requirements. 3. State licensure through state acceptance and adoption of national certification. The federal government has assisted in the establishment of the National Commission of Health Certifying Agencies (NCHCA), a national (non-federal) certification system. National standards for certification agencies are now being established through a collaborative effort of the federal government, professional associations, state governments, recognized certifying organizations and other interested parties. States implementing licensure should be encouraged to adopt national certification granted by only those certifying organizations adhering to the certification standards established by the NCHCA. State licensure boards and certifying agencies should be encouraged to collaborate in the development of licensure examinations for individuals
    • within that particular state who do not or cannot meet the eligibility requirements for national certification. D. RECOMMENDATION AND POSITION The first and second approaches are not preferred due to potential unique individual state requirements and possible interstate non-compatibility or non-reciprocity. The third approach-- state licensure through state acceptance and adoption of national certification--is the most practical approach. Since this allows for state control and adaptation to fulfill local needs, the national standards would be adopted by the states, thus maintaining uniformity and consistency and facilitating reciprocity and mobility between states. State adoption of national standards would be likely because of requirements for reimbursement under federal health insurance programs that services must be provided by health professionals who have been licensed or certified according to national standards. Additionally, this approach also is most amenable to the incorporation of the elements relating to licensure listed above. In conclusion, the Technologist Section believes that the above supported licensure approach is important as a way of maintaining competency and public protection. In developing licensure, the interaction of accreditation, certification, continuing education, national standards development, and licensure must be carefully considered since all of these will have an important effect on the competency of nuclear medicine technologists and the quality of the health care they provide.
    • ADDENDUN A CERTIFYING EXAMINATIONS There are currently two voluntary certifying examinations in nuclear medicine technology given by: The Nuclear Medicine Technology Certification Board (NMTCB) and The American Registry of Radiologic Technologists (ARRT). The NMTCB is the only certifying agency the Technologist Section is currently involved with since the Section determined the other agency was not adequately meeting the certification needs of nuclear medicine technologists. The successful completion of the NMTCB examination is considered to demonstrate entry level competence. Satisfactory completion of either of the examinations is frequently considered a prerequisite for employment as a nuclear medicine technologist.
    • ADDENDUM B THE NUCLEAR MEDICINE TECHNOLOGY CERTIFICATION BOARD The assessment of knowledge and skills necessary for a nuclear medicine technologist to perform competently is a challenging and critical activity. The necessity for nuclear medicine technologists to evidence their competence during the remainder of their professional lifetime is becoming increasingly critical as increasing demands are placed on the health care system. To meet these challenges, the Nuclear Medicine Technology Certification Board (NMTCB) was founded and incorporated in 1977 under the initial sponsorship of the Society of Nuclear Medicine Technologist Section and the Society of Nuclear Medicine. The primary purpose of the NMTCB is to administer an examination totally relevant to the competent practice of nuclear medicine technology. To identify knowledge and skills to be assessed, a comprehensive task analysis has been performed. Based on this analysis, judgements are made regarding the content and skills to be assessed, the desired statistical characteristics of the test, and the directions that are provided to the exam item writers. All material is developed to assess the knowledge needed for competent daily job performance as a nuclear medicine technologist and is now being assessed through the written certification examination produced which is administered by the NMTCB and the American College Testing Program (ACT) in a cooperative effort.
    • ADDENDUM C CRITERION REFERENCED EXAMINATIONS Criterion reference examinations are given to identify candidates for examination who have achieved a minimum acceptable level at career entry level. Criterion referenced measurement is concerned with how an individual meets a predetermined minimum level or standard of performance of an examination as opposed to how he ranks in comparison to the others in the test group (norm referenced measurement). In other words, the cutoff point for pass/fail is determined before the test is administered. The nature of the subject matter in nuclear medicine technology certification examinations, which is related to patient care, dictates that a predetermined level of minimum acceptable performance should be required rather than the measurement of differences among individuals. There are two ways to establish the minimum acceptable level. The first would be to identify the "required' subject matter of those questions on an examination of at least 200 items. The large amount of knowledge to be tested and the difficulty of maintaining a consensus of opinion in all geographic locations, educational institutions, and laboratories as to the appropriateness of this "required" subject matter would make this approach impractical. Another way in which a minimum acceptable level can be established is to construct an examination of questions on a variety of subject matters and levels of difficulty. Each question can serve as a means of identifying those examinees that have at least a minimally acceptable level of knowledge and those who are not acceptable. The NMTCB is based on criterion
    • referenced examination methodology and has administered a fully criterion referenced examination. ADDENDUM D JOINT REVIEW COMMITTEE ON EDUCATIONAL PROGRAMS IN NUCLEAR MEDICINE TECHNOLOGY The Joint Review Committee is responsible for evaluation and periodic re-evaluation of educational program in nuclear medicine technology, including scheduling site evaluations, designation of evaluator teams, and development of accreditation recommendations. The Joint Review Committee is composed of representatives from professional associations that have an interest in nuclear medicine technology. They are: The Society of Nuclear Medicine, The Society of Nuclear Medicine Technologist Section, American College of Radiology, American Society of Clinical Pathologists, American Society of Radiologic Technologists.
    • ADDENDUM E THE NATIONAL COMMISSION OF HEALTH CERTIFYING AGENCIES The effective development of national standards for certification is requiring initial and collaborative efforts among all bureaus and agencies of the federal government, professional organizations, state governments, recognized credentialing organizations, and other interested parties. To this end, the National Commission of Health Certifying Agencies (NCHCA) was formed in 1977. The SNMTS had an appointed representative on the steering committee which was the formative group of the NCHCA. The SNMTS and the NMTCB are provisional members of the commission and the NMTCB had its representative elected to the initial Executive Council of the NCHCA.