October 15, 2014
Assemblyman Herb Conaway, Jr., M.D.
Delran Professional Center
8008 Rt. 130 North, Bldg. C, Suite 450
Delran, NJ 08075
Assemblyman Raj Mukherji
433 Palisade Ave.
Jersey City, NJ 07307
Dear Assemblyman Conaway and Assemblyman Mukherji:
The American Society of Radiologic Technologists (ASRT) and the New Jersey Society of Radiologic
Technologists (NJSRT) would like to thank you for introducing Assembly Bill 3763 and taking action to
create licensure standards for magnetic resonance imaging technologists.
The ASRT is a national professional society that represents more than 152,000 medical imaging and
radiation therapy professionals, including 5,350 in New Jersey. The NJSRT is one of our state affiliates.
We support the establishment of educational and certification standards for MR technologists because
state licensure helps ensure that patients undergoing MRI procedures receive safe, diagnostic services
from technologists who meet the appropriate qualifications.
After reviewing the bill and its proposed language, ASRT and NJSRT would like to address some
important concerns:
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MR is only one form of non-ionizing radiation. Using the generic term “non-ionizing radiation”
may lead to confusion and raise concerns from groups representing medical professionals who
administer other forms of non-ionizing medical radiation. For example, nurses use ultraviolet
radiation to treat jaundiced infants and sonographers use sound waves in ultrasound
examinations.
The bill does not include the ASRT Educational Curriculum for Magnetic Resonance Imaging
Technologists. ASRT, in partnership with other MRI and educational societies, has developed
and published the nationally-recognized educational curriculum for MRI since 2006. This
curriculum is followed by all MRI educational programs accredited by the Joint Review
Committee on Education in Radiologic Technology (JRCERT), the educational accreditation
organization recognized by the radiologic technology profession.
The Commission on Accreditation of Allied Health Education (CAAHEP) does not accredit
educational programs in radiologic technology or radiation therapy. Radiologic technology and
radiation therapy educational programs are programmatically accredited by the Joint Review
Committee on Education in Radiologic Technology (JRCERT).
The American Registry of Magnetic Resonance Imaging Technologists (ARMRIT) does not
publicize the number of MRI technologists it certifies in New Jersey. However, nearly 1,100 MR
technologists in New Jersey are certified by the American Registry of Radiologic Technologists
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(www.arrt.org/Registration/Census). The ARRT has been in existence since 1922, offers
certification examinations in 16 specialized areas of medical imaging and radiation therapy, and
is recognized by all states with licensure programs for radiologic technologists.
As the national association representing MR technologists, radiologic technologists and radiation
therapists ASRT issues practice standards for all medical imaging and radiation therapy
specialties. ASRT’s practice standards do not recognize ARMRIT as a credential for MR
technologists.
To address these concerns, ASRT and NJSRT respectfully suggest the following amendments to the bill:
1. Replace the term “non-ionizing radiation” with “magnetic resonance” or “magnetic resonance
imaging” throughout the bill. This distinction will clarify that the bill relates specifically to MR
and not to other forms of non-ionizing radiation such as ultrasound or ultraviolet light.
2. Amend the new definition (q) to read:
q.
"Magnetic resonance imaging technology" means magnetic resonance imaging or
the use of equipment emitting non-ionizing magnetic resonance radiation on human
beings for diagnostic or therapeutic purposes under the supervision of a licensed
practitioner.
3. Amend Section 5 to read:
f.
A person holding a license as provided by this act P.L.1981, c.295 (C.26:2D-24
et seq.) shall use medical equipment emitting ionizing or non-ionizing magnetic
resonance radiation on human beings only for diagnostic or therapeutic purposes on a
case-by-case basis at the specific direction of a licensed practitioner, and only if the
application of the equipment is limited in a manner hereinafter specified.
4. Amend Section 6 to read:
a.
There is created a Radiologic Medical Imaging Technology Board of Examiners
which shall be an agency of the Commission on Radiation Protection in the Department
of Environmental Protection and which shall report to the commission. The board shall
consist of two commission members appointed annually to the membership of the board
by the chairman of the commission, and 13 additional members appointed by the
Governor with the advice and consent of the Senate. Of the members appointed by the
Governor, two shall be radiologists who have practiced not less than five years; one shall
be a licensed physician who has actively engaged in the practice of medicine not less than
five years; one shall be a licensed dentist who has actively engaged in the practice of
dentistry for not less than five years; one shall be a licensed podiatrist who has actively
engaged in the practice of podiatric medicine for not less than five years; one shall be an
administrator of a general hospital with at least five years' experience; one shall be a
health physicist who has practiced not less than five years; three two shall be practicing
radiologic technologists; one shall be a or magnetic resonance imaging technologists,
with at least five years of experience in the practice of radiologic technology, or magnetic
resonance imaging technology, as the case may be, and holders of current certificates
issued pursuant to this act; two shall be members of the general public; and one shall be a
representative of the department designated by the Governor pursuant to subsection c. of
section 2 of P.L.1971, c.60 (C.45:1-2.2).
5. Amend Section 8 to read:
a.
(1)
The program of diagnostic x-ray radiologic technology, other than for
magnetic resonance imaging, shall be at least a 24-month course or its equivalent, as
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determined by the board. The curriculum for this course may follow the Committee on
Allied Health Education and Accreditation (CAHEA) Commission on Accreditation of
Allied Health Education Programs (CAAHEP) Joint Review Committee on Education
in Radiologic Technology (JRCERT) standards; provided that the standards are not in
conflict with board policies.
(2)
The program for magnetic resonance imaging technologists shall be
determined by the board. The curriculum for this program may follow the standards of
the American Registry of Magnetic Resonance Imaging Technologists (ARMRIT) or
American Society of Radiologic Technologists Magnetic Resonance Curriculum, or
its successor, provided that the standards are not in conflict with board policies.
b.
The program of radiation therapy technology shall be at least a 24-month course
of study or its equivalent, as determined by the board. The curriculum for the course may
follow the Committee on Allied Health Education and Accreditation (CAHEA)
Commission on Accreditation of Allied Health Education Programs (CAAHEP) Joint
Review Committee on Education in Radiologic Technology (JRCERT) standards;
provided that the standards are not in conflict with board policies.
c.
The board shall establish criteria and standards for programs of chest
radiography, podiatric radiography, orthopedic radiography, urologic radiography and
dental radiography educational programs involving the limited license use of ionizing
radiation, and approve the programs upon a finding that the standards and criteria have
been met.
6. Amend Section 9 to read:
d.
(1)
The board may accept, in lieu of its own examination, for a radiologic
technologist candidate or radiation therapist candidate, other than a magnetic
resonance imaging technologist candidate, a current certificate of the American
Registry of Radiologic Technologists issued on the basis of a registry examination
satisfactory to the board, provided that the standards of that agency are at least as
stringent as those established by the board.
(2)
The board may accept, in lieu of its own examination, for a magnetic
resonance imaging technologist candidate, a current certificate of the American Registry
of Magnetic Resonance Imaging Technologists (ARMRIT) or current registration in
magnetic resonance technology by the American Registry of Radiologic
Technologists (ARRT), issued on the basis of a registry examination satisfactory to the
board, provided that the standards of that agency are at least as stringent as those
established by the board.
7. Amend Section 11 to read:
(9)
Has applied ionizing radiation or non-ionizing radiation magnetic resonance
radiation, as the case may be, to a human being without the specific direction of a duly
licensed practitioner as defined herein; or to any person or part of the human body
outside the scope of his specific authorization;
(10)
Has acted or is acting as an owner, co-owner, or employer in any enterprise
engaged in the application of ionizing radiation or non-ionizing magnetic resonance
radiation to human beings for the purpose of diagnostic interpretation, chiropractic
analysis, or the treatment of disease;
(11)
Has expressed to a member of the public an interpretation of a diagnostic x-ray
film, magnetic resonance image or fluorescent image;
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Thank you for your consideration and your commitment to patient care. Please let me know if we can
help clarify any of these important points. We look forward to working with you to establish standards
and licensure for magnetic resonance technologists in New Jersey.
Sincerely,
Christine J. Lung, CAE
ASRT Vice President of Government Relations & Public Policy
Cc:
Chairman Thomas Giblin, Assembly Committee on Regulated Professions
New Jersey Society of Radiologic Technologist Board of Directors
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