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Texas State Board of
Podiatric Medical Examiners

Physical Address: 333 Guadalupe, Suite #2-320; Austin, Texas 78701
Mailing Address: P.O. Box 12216; Austin, Texas 78711
Phone: (512)-305-7000
Facsimile: (512)-305-7003
www.tsbpme.texas.gov

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Radiology Technicians

(Updated: Sunday, December 13, 2015 @ 5:00 pm)

The purpose of this page is to explain and clarify the requirements for a Texas State Board of Podiatric Medical Examiners' (TSBPME) "Podiatric Medical Radiological Technician" Registration (i.e. Non-Certified Technician (NCT); Non-Certified Technician-Podiatric (NCT-Podiatric); Podiatric Medical Assistant (PMA)) as there appears to be some confusion involving the myriad of regulatory provisions.

For TSBPME purposes, whether a person is a NCT, NCT-Podiatric or a PMA, he/she is called a "Podiatric Medical Radiological Technician" by virtue of performing non-dangerous/non-hazardous Podiatric (i.e. Foot/Ankle) radiological procedures in the office/practice and under the supervision of a licensed Podiatric Physician.

Be advised, pursuant to Acts of the 84th Texas Legislature (2015; SB202; Sunset provision), the (parent) "Medical Radiologic Technologist Certification Program" (Texas Occupations Code Chapter 601) was transferred from the Texas Department of State Health Services - Professional Licensing and Certification Unit (DSHS) to the Texas Medical Board (TMB) ... effective September 1, 2015. This program transfer does NOT change the fact that any person performing Podiatric (i.e. Foot/Ankle) radiological procedures must be under the supervision of a licensed Podiatric Physician physically present on the premises and must ultimately be registered with the TSBPME as a "Podiatric Medical Radiological Technician". As the TMB continues implementing the program transfer from DSHS, please continue to check this webpage for any updates. Furthermore, although SB202 was effective on September 1, 2015 ... the DSHS program transfer to the TMB is up for Sunset review again in March 2016. We anticipate in the future that all references to DSHS will be changed to the TMB as the TMB incorporates all related DSHS laws/rules.

Bottom Line: Any person performing Podiatric (i.e. Foot/Ankle) radiological procedures as defined in Board Rule §382.7 "Non-Certified Podiatric Technician's Scope of Practice" must be under the supervision of a licensed Podiatric Physician physically present on the premises and must ultimately be registered with the TSBPME as a "Podiatric Medical Radiological Technician". This includes whether a person is a Non-Certified Technician (NCT); Non-Certified Technician-Podiatric (NCT-Podiatric) or a Podiatric Medical Assistant (PMA).

► What is a Non-Certified Technician (NCT); Non-Certified Technician-Podiatric (NCT-Podiatric)?

  1. A “Non-Certified Technician” (NCT; NCT-Podiatric) is a person who has completed the DSHS Rules 25 Texas Adm. Code, §140.518(d) "Mandatory Training Programs for Non-Certified Technicians" course; the 67-125 Hour course.

  2. NCT’s (NCT; NCT-Podiatric) are defined as persons performing radiological procedures (X-rays) for medical purposes, who are not DSHS-Certified Medical Radiologic Technologists (MRTs) nor Limited Medical Radiologic Technologists (LMRTs).

  3. For NCT's (NCT; NCT-Podiatric), the DSHS - Medical Radiologic Technologist Certification Program (now at the TMB) maintains a mandatory “NCT Registry” of persons who have completed an approved NCT (NCT; NCT-Podiatric) training program (Texas Occupations Code §601.202 & DSHS Rules 25 TAC §140.511 & §140.519). The purpose of the "NCT Registry" is to provide a mechanism for consumers or employers to ascertain or verify that a person performing radiologic procedures has successfully completed a training program in accordance with DSHS laws/rules.

  4. Please click HERE for a March 23, 2009 DSHS Memorandum further explaining the "NCT Registry" and related Continuing Education provisions.

  5. A NCT (NCT; NCT-Podiatric) may not perform a radiological procedure which has been identified as "Dangerous" or "Hazardous" as defined in DSHS Rule 25 Texas Adm. Code §140.516.

► What is a Podiatric Medical Assistant (PMA)?

  1. A "Podiatric Medical Assistant" (PMA) is a person who has completed the DSHS Rules 25 Texas Adm. Code, §140.522(e) "Alternate Training Requirements" course; the Texas Podiatric Medical Association (TPMA) 20 Hour course.

  2. PMA's are defined as persons performing radiological procedures (X-rays) for medical purposes, who are not DSHS-Certified Medical Radiologic Technologists (MRTs) nor Limited Medical Radiologic Technologists (LMRTs) nor Non-Certified Technicians (NCT; NCT-Podiatric).

  3. For PMA's, the DSHS - Medical Radiologic Technologist Certification Program (now at the TMB) allows a PMA to voluntarily be on the “NCT Registry” of persons who have completed an approved NCT training program (Texas Occupations Code §601.202 & DSHS Rules 25 TAC §140.511 & §140.519). The purpose of the "NCT Registry" is to provide a mechanism for consumers or employers to ascertain or verify that a person performing radiologic procedures has successfully completed a training program in accordance with DSHS laws/rules.

  4. Please click HERE for a March 23, 2009 DSHS Memorandum further explaining the "NCT Registry" and related Continuing Education provisions.

  5. A PMA may not perform a radiological procedure which has been identified as "Dangerous" or "Hazardous" as defined in DSHS Rule 25 Texas Adm. Code §140.516.

Who am I?

♦ Question: I am a "Podiatric Medical Radiological Technician" working under the supervision of a licensed Podiatric Physician ... how do I know if I am a Non-Certified Technician (NCT); Non-Certified Technician-Podiatric (NCT-Podiatric) or a Podiatric Medical Assistant (PMA) and must I also be on the TMB (formerly DSHS) "NCT Registry"?

♦ Answer: Please refer to the table below to determine who you are and with whom you must be registered. (Further details follow below.)

"Podiatric Medical Radiological Technician" Training Type: Which training course did you complete?:
(Look at your Training Program Certificate)
Are you working under a Podiatric Physician?: Then you must register as a "Podiatric Medical Radiological Technician" with the: Must I also be on the TMB "NCT Registry"?:
Non-Certified Technician
(NCT)
Non-TPMA
Full 125 Hour Course; DSHS Rule §140.518(d)
Yes TSBPME Yes / Required
Non-Certified Technician-Podiatric
(NCT-Podiatric)
Non-TPMA
Partial 67 Hour Course; DSHS Rule §140.518(d)
Yes TSBPME Yes / Required
Podiatric Medical Assistant
(PMA)
TPMA Alternate
20 Hour Course; DSHS Rule §140.522 (e)
Yes TSBPME No / Voluntary

December 2015 TMB "Non-Certified Technician" registration (renewal) notice.

♦ Question: In December 2015 I received a "Non-Certified Technician" registration (renewal) notice from the TMB. Why did I receive this? What should I do?

♦ Answer: You received the "Non-Certified Technician" registration (renewal) notice from the TMB because you are on the (DSHS) "NCT Registry". At some point, you applied with DSHS to be on the "NCT Registry". Now that the program transfer from DSHS is being implemented by the TMB, the TMB is renewing "NCT Registry" registrations in accordance with SB202 (84th Session/2015; Sunset) which also requires that DPS/FBI Fingerprint Criminal History Background Checks be completed. If you are a NCT (NCT; NCT-Podiatric), you must remain on the "NCT Registry" and follow TMB instructions. If you are a PMA, the "NCT Registry" is voluntary. (Nevertheless, if you are a NCT, NCT-Podiatric or a PMA and are performing Podiatric (i.e. Foot/Ankle) radiological procedures in the office/practice of a licensed Podiatric Physician, you must ultimately be registered with the TSBPME as a "Podiatric Medical Radiological Technician".) (Further details follow below.)


 TSBPME "PODIATRIC MEDICAL RADIOLOGICAL TECHNICIAN" REGISTRATION & RENEWAL

1) First and foremost, any person performing Podiatric (i.e. Foot/Ankle) radiological procedures in the office/practice of a licensed Podiatric Physician (other than the Podiatric Physician himself/herself) must ultimately be registered with the TSBPME as a "Podiatric Medical Radiological Technician".

2) Proof of successful completion of mandatory DSHS specified training (copy of certificate) must accompany the TSBPME "Podiatric Medical Radiological Technician" application in order for the TSBPME "Podiatric Medical Radiological Technician" application to be processed. If proof is not attached, the TSBPME "Podiatric Medical Radiological Technician" application will be returned. Mandatory training is set forth in the DSHS Rules 25 Texas Adm. Code §140.518(d) relating to "Mandatory Training Programs for Non-Certified Technicians” (i.e. NCT; NCT-Podiatric) and/or 25 Texas Adm. Code §140.522(e) relating to "Alternate Training Requirements" for “Podiatric Medical Assistants” (PMA).

3) NOTE: The "PMA" course is the one, and only one, offered by the Texas Podiatric Medical Association (TPMA); this is the 20 Hour "Alternate Training Requirement" PMA course (25 Texas Adm. Code §140.522(e)) and is not the 67-125 Hour "Mandatory Training Programs for Non-Certified Technicians” (i.e. NCT; NCT-Podiatric) course (25 Texas Adm. Code, §140.518(d)).

4) TSBPME "Podiatric Medical Radiological Technician" Initial Registration Application & Renewal Fee: $35.00

Please visit the Board's "Veteran's" webpage to obtain additional information for Texas Veterans & Military Service Members/Veterans & Military Spouses.

U.S. Military Application (Initial Registration Application & Renewal) Fee Waiver
Note: For Current Active Duty U.S. Military Service Members, Spouses of Current Active Duty U.S. Military Service Members and U.S. Military Veterans.
Pursuant to Texas Occupations Code §55.009 (SB 807; 84th Session/2015; effective 09/01/2015), the Initial Registration Application & Renewal Fee for Current Active Duty U.S. Military Service Members, Spouses of Current Active Duty U.S. Military Service Members and U.S. Military Veterans is Waived.
Texas Occupations Code §55.001 “Definitions” provides that: “(1-a)  "Military Service Member" means a person who is currently serving in the Armed Forces of the United States, in a reserve component of the Armed Forces of the United States, including the National Guard, or in the state military service of any state. (1-b)  "Military Spouse" means a person who is married to a Military Service Member who is currently on Active Duty. (1-c)  "Military Veteran" means a person who has served in the Army, Navy, Air Force, Marine Corps, or Coast Guard of the United States, or in an auxiliary service of one of those branches of the Armed Forces.”
In order to apply this U.S. Military Initial Registration Application & Renewal Fee Waiver, the applicant must submit to the Board along with the requisite complete registration application:
Current Active Duty U.S. Military Service Members: Submit your current military orders and a copy of your military ID.
Spouses of Current Active Duty U.S. Military Service Members: Submit that Member’s current military orders, that Member’s military ID and marriage certificate.
U.S. Military Veterans: Submit a copy of your DD 214 (if discharged from the U.S. Armed Forces) for each period of service. Be sure to submit a copy of the entire DD 214 form showing “Type of Separation” (discharged) and “Character of Service” (honorable, dishonorable, etc.).
Thank You for your service to the United States of America!!!

5) Click Here To: Complete & Print the TSBPME Application for "Podiatric Medical Radiological Technicians."

6) A $25.00 Penalty Fee must be added to the TSBPME $35.00 Registration Application Fee if the applicant is already taking X-rays in the Podiatric Physician's office/practice.

7) Read 22 Texas Adm. Code Chapter 382 of the TSBPME Board Rules regarding "Non-Certified Radiologic Technicians" (this means "Podiatric Medical Radiological Technicians") for regulations specific to Podiatric (i.e. Foot/Ankle) practice in a Podiatric Physician’s office.

8) Read "Questions & Answers #27" from the Board's website which asks: "Does a Radiology Technician certification authorize a person to operate (office) lower extremity MRI equipment? Does a Radiology Technician certification authorize a person to operate a mobile fluoroscopic machine such as the Orthoscan Mobile DI?"

9) TSBPME "Podiatric Medical Radiological Technician" renewals will be mailed during the last week of November and are due December 31st of each year ($35.00 Renewal Fee). Late fees ($25.00) will be assessed for untimely renewals.

10) Please be sure to keep your office address current with us because your renewal will be mailed to your primary office address. To update your address please contact Veronica Coronado, Staff Services Officer, at Veronica.Coronado@tsbpme.texas.gov or Fax written notice to (512)-305-7003.



RENEWING WITH THE TSBPME OR THE TMB (formerly DSHS) "NCT REGISTRY"

Non-Certified Technicians (NCT; NCT-Podiatric) ... those person’s (DSHS Rule 25 Texas Adm. Code, §140.518(d)) performing Podiatric “Foot/Ankle” radiological procedures in a Podiatric Physician’s office (as opposed to DSHS-Certified Medical Radiologic Technologists (MRTs); Limited Medical Radiologic Technologists (LMRTs)), are required to ultimately submit registration with the TSBPME as a "Podiatric Medical Radiological Technician" and must also be placed on the TMB (formerly DSHS) "NCT Registry”.

In general, one must be initially NCT (NCT; NCT-Podiatric) trained in accordance with DSHS specifications to perform NCT (NCT; NCT-Podiatric) radiological procedures. The DSHS (training) “NCT Registry” registration is mandatory for NCT's (NCT; NCT-Podiatric). Failure to renew "NCT Registry" registration with the TMB (formerly DSHS) results in removal from the TMB “NCT Registry” (25 TAC §140.519(d)(4)). Removal from the TMB “NCT Registry” can result in the NCT's (NCT; NCT-Podiatric) inability to perform radiological procedures. Failure to renew TSBPME "Podiatric Medical Radiological Technician" registration with the Texas State Board of Podiatric Medical Examiners will result in the inability to perform radiological procedures in a Podiatric Physician’s office/practice.

Again, those NCT’s (NCT; NCT-Podiatric) who complete all the necessary DSHS specified training, must register with the mandatory TMB “NCT Registry.” Again, those NCT’s (NCT; NCT-Podiatric) who perform radiological services under the direction or instruction of a Podiatric Physician are ultimately required to register with the TSBPME as a  "Podiatric Medical Radiological Technician" pursuant to Board Rule 22 Texas Adm. Code Chapter 382 in order to perform procedures on the “Foot/Ankle.” (Reference: Texas Occupations Code §601.152 and §601.252.)

NCT’s (NCT; NCT-Podiatric) who choose to be placed on the mandatory TMB “NCT Registry” should also renew TMB registration (& maintain DSHS Continuing Education requirements) with the TMB “NCT Registry,” in order to remain on the TMB “NCT Registry.” The purpose of the mandatory TMB “NCT Registry” for NCT's(NCT; NCT-Podiatric) is to inform consumers and employers that the NCT (NCT; NCT-Podiatric) has completed the required training (DSHS Rule 25 TAC §140.518). If an NCT (NCT; NCT-Podiatric) does not renew registration with the TMB and falls off the “NCT Registry,” it will be the responsibility of the employer to verify that the individual he/she has employed as his/her NCT (NCT; NCT-Podiatric) has completed all the necessary training (DSHS Rule 25 TAC §140.518; 25 TAC §140.511; 25 TAC §140.519). This is a TMB (formerly DSHS) regulatory requirement construed in accordance with Texas Occupations Code Chapter 601 (state law).

Again, staff employed by a Podiatric Physician who are acting as an NCT (NCT; NCT-Podiatric) should be familiar with the DSHS related rules.

Podiatric Medical Assistants (PMA) ... those persons (DSHS Rule 25 Texas Adm. Code, §140.522(e)) performing Podiatric “Foot/Ankle” radiological procedures in a Podiatric Physician’s office (as opposed to DSHS-Certified Medical Radiologic Technologists (MRTs); Limited Medical Radiologic Technologists (LMRTs); Non-Certified Technicians (NCT's; NCT-Podiatric)), are also required to ultimately submit registration with the TSBPME as a "Podiatric Medical Radiological Technician" but may also voluntarily choose to be placed on the TMB (formerly DSHS) "NCT Registry”. Once a PMA is on the TMB "NCT Registry", he/she must maintain all "NCT Registry" requirements to remain registered with the TMB.

Again, staff employed by a Podiatric Physician who are acting as a PMA should be familiar with the DSHS related rules.

Failure to renew registration with the TMB (formerly DSHS) "NCT Registry" results in removal of the NCT (NCT; NCT-Podiatric) or PMA from the TMB "NCT Registry." Failure to renew TSBPME "Podiatric Medical Radiological Technician" registration with the Texas State Board of Podiatric Medical Examiners will result in the inability to perform radiological procedures in a Podiatric Physician's office/practice. Persons (NCT; NCT-Podiatric; PMA) who can evidence proof of having taken the appropriate DSHS specified training course and upon (current) TSBPME "Podiatric Medical Radiological Technician" registration will be allowed to perform Podiatric (i.e. Foot/Ankle) radiological procedures.



THEREFORE, IN ORDER TO TAKE PODIATRIC X-RAYS
  1. An individual must first complete the NCT or NCT-Podiatric (67-120 Hour course; DSHS Rule 25 Texas Adm. Code, §140.518(d)) or the PMA (20 Hour TPMA Course; DSHS Rule 25 Texas Adm. Code, §140.522(e)) training specified by the DSHS - Medical Radiologic Technologist Certification Program. (DSHS regulation)

  2. Once training is completed, a NCT or NCT-Podiatric must then register and maintain themselves with the mandatory TMB “NCT Registry” for NCT's (NCT; NCT-Podiatric). (DSHS regulation)

  3. Once training is completed, a PMA may then register and maintain themselves voluntarily with the TMB “NCT Registry”. (DSHS regulation)

  4. In order to then perform Podiatric “Foot/Ankle” radiological procedures in a Podiatric Physician’s office/practice (your employer), a NCT or NCT-Podiatric or PMA must ultimately be registered with the TSBPME as a "Podiatric Medical Radiological Technician" so that we have a record of which Podiatric Physician will be supervising you for safe practice. (TSBPME regulation)

  5. TSBPME "Podiatric Medical Radiological Technician" registrations must be maintained annually.



PODIATRY NCT / NCT-Podiatric & PMA TRAINING OPPORTUNITIES (& DSHS FORMS)

DSHS List of Approved NCT / PMA Training Programs (Discontinued; December 2015)

DSHS Forms: http://www.dshs.state.tx.us/mrt/mrt_forms.shtm (Discontinued; December 2015)

Please note that although NCT/NCT-Podiatric & PMA training programs/courses are combined on the DSHS list, the PMA course is the one, and only one, offered by the Texas Podiatric Medical Association (TPMA). Again the TPMA course is the 20 Hour "Alternate Training Requirement" (DSHS Rule 25 Texas Adm. Code, §140.522(e)) PMA course and is not the 67-120 Hour "Mandatory Training Programs for Non-Certified Technicians” (NCT; NCT-Podiatric) course (DSHS Rule 25 Texas Adm. Code, §140.518(d)).

Texas Podiatric Medical Association (TPMA) - PMA Training Course Information:

Click here for the TPMA Online Radiology Training Course.

TPMA Podiatric Medical Assistant Radiology Training
918 Congress Ave., Ste. #200
Austin, TX 78701
Voice: (512)-494-1123/800-TEX-FOOT
Fax: (512)-494-1129/800-633-9235
Web: http://www.txpma.org
Contact: Joe E. Martin, DPM
Cats: podiatric
DSHS Certificate: #TP015


DSHS - MEDICAL RADIOLOGIC TECHNOLOGIST CERTIFICATION PROGRAM

MRT parent program pending full transfer to & implementation by the Texas Medical Board (TMB).

DSHS Agency: Texas Department of State Health Services - Medical Radiologic Technologist Certification Program

DSHS Questions: Direct them to DSHS by Phone at (512)-834-6617, by Fax at (512)-834-6677, or by e-mail to mrt@dshs.state.tx.us (web: http://www.dshs.state.tx.us/mrt).

DSHS Laws: “Medical Radiologic Technologist Certification Act; Texas Occupations Code Chapter 601”                                                            

DSHS Rules: “Medical Radiologic Technologists; 25 Texas Administrative Code, Part 1, Chapter 140, Subchapter J”



DSHS - RADIATION CONTROL PROGRAM & OFFICE X-RAY MACHINE INSPECTIONS

The DSHS “Radiation Control Program” regulates the uses of radiation in Texas. The regulatory program is designed to prevent unnecessary radiation exposure to the public and perform vital, core public health functions guided by the Texas Department of State Health Services regulatory philosophy.

Unlike the DSHS “Medical Radiologic Technologist Certification Program,” the DSHS “Radiation Control Program” does NOT register NOR certify Medical Radiologic Technologists (MRTs); Limited Medical Radiologic Technologists (LMRTs); Non-Certified Technicians (NCT's; NCT-Podiatric); Podiatric Medical Assistants (PMA's) NOR do they issue Continuing Education Credits. They do however ensure that X-ray Machines are safe and in compliance with DSHS standards.

Every Podiatric Physician’s office/practice is required to have their X-ray Machines registered with the DSHS “Radiation Control Program.” DSHS Radiation Control Inspectors/Investigators travel the state to ensure the safety of X-ray Machines and to also ensure that staff operating such machines are appropriately trained (as evidenced by the DSHS “Registry” or NCT/PMA training certificate) and ultimately registered with the TSBPME as a "Podiatric Medical Radiological Technician" if performing Podiatric “Foot/Ankle” X-rays in a Podiatric Physician’s office/practice. Again, Podiatric Physician office/practice NCT’s / PMA's must evidence their DSHS training and ultimate registration with the TSBPME as a "Podiatric Medical Radiological Technician" should they be asked by a DSHS Inspector/Investigator (upon DSHS inspection).

♦ Question: What are the DSHS "Radiation Control Program" laws/rules/regulations for their X-ray Machine Inspections so that I can ensure my equipment is safe for the public and my office/practice/staff?

♦ Answer: Texas Health & Safety Code §401.064 "Inspection of X-Ray Equipment" (DSHS Laws) provides that: "(a) The executive commissioner shall adopt rules relating to the frequency of department inspections of electronic products. (b) In adopting the rules, the executive commissioner shall consider the threat to human health and safety that the electronic products may present. (c) The executive commissioner shall adopt an inspection interval of five years for routine inspections of electronic products that present a minimal threat to human health and safety. (d) The executive commissioner by rule shall require a person who inspects medical, podiatric medical, dental, veterinary, or chiropractic electronic products to have special training in the design and uses of the products. (e) The department shall conduct inspections of medical, podiatric medical, dental, veterinary, and chiropractic electronic products in a manner designed to cause as little disruption of a medical, podiatric medical, dental, veterinary, or chiropractic practice as is practicable. (f) In adopting rules under this section relating to the inspection of medical, podiatric medical, dental, veterinary, and chiropractic electronic products, the executive commissioner shall solicit and follow the recommendations of the State Board of Dental Examiners for the inspections of dental electronic products, the Texas State Board of Podiatric Medical Examiners for the inspection of podiatric medical electronic products, the Texas Medical Board for the inspection of medical electronic products, the State Board of Veterinary Medical Examiners for the inspection of medical electronic products used in the practice of veterinary medicine, and the Texas Board of Chiropractic Examiners for the inspection of chiropractic electronic products, unless in conflict with federal statutes or federal rules."

The DSHS "Radiation Control Program" has additional regulations (DSHS Rules) which are found in Chapter 289 of 25 Texas Administrative Code - Part 1 - Subchapter E. The TSBPME strongly encourages all license holders to be familiar with all DSHS "Radiation Control Program" laws/rules/regulations to ensure public safety.