FDA-Required Physician Qualifications for Mammography - 10/31/2003
The Food and Drug Administration's (FDA) regulations that went into effect April 28, 1999, under the Mammography Quality Standards Act (MQSA) have a unique exemption that may impact whether a radiology resident may be qualified to legally interpret mammograms immediately upon completion of his or her residency training. In addition to licensure, certification (or formal training) and formal CME, the FDA requires that a physician interpret, under direct supervision, the mammograms from 240 patients in the six months immediately before he or she starts interpreting mammograms. However, if the physician passes his or her board exam in diagnostic radiology at the first allowable time, the FDA allows the interpretation of these 240 mammograms to be within a 6-month period anytime in the last two years of the residency program. A summary of the FDA requirements follows along with examples of documentation you must provide to your facility for the annual MQSA inspection. You can find more complete information on the FDA's MQSA regulations on the FDA Policy Guidance Help System at http://www.fda.gov/cdrh/mammography/robohelp/START.HTM.
Physician Qualifications for Interpreting Mammograms
(if initially qualified after the FDA's Final rules, April 28, 1999)
| Requirements | Documentation Examples | ||
| Initial Qualifications | Credentials |
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| Initial Medical Education | 60 hours category I CME
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| Initial Experience |
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| New Modality Training (e.g., digital) | 8 hours of training |
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| Continuing Experience | 960 examinations/24months (Physicians failing to maintain continuing experience must requalify prior to performing independent mammographic interpretation.) |
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| Continuing Education | General | 15 category I CME's/36 months (Physicians failing to maintain continuing education must requalify prior to performing independent mammographic interpretation.) |
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| Modality specific (e.g., digital) | Include 6 category I CME in each mammographic modality used by the interpreting physician |
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Sample Residency Letter – Final Regulations
[Official Letterhead of Residency Program]
{..Date of Letter..}
To Whom It May Concern:
Dr. { name } successfully completed his/her residency in diagnostic radiology on { date }. During the period of his/her residency program { inclusive dates }, Dr. { name } received the following training and experience specific to mammography:
1. At least three months { or may include exact amount of training } of training in the interpretation of mammograms, including instruction in radiation physics, radiation effects, and radiation protection.
[NOTE: this paragraph may be deleted if the resident has passed the diagnostic radiology certifying examinations and become a diplomat of the American Board of Radiology (ABR), the American Osteopathic Board of Radiology (AOBR), or the Royal College of Physicians and Surgeons of Canada (RCPSC).]
2. At least 60 hours of documented continuing medical education in mammography.
[NOTE to residency program director: These 60 hours may be included in the three months of training described in #1, it does not have to be an additional 60 hours of training.]
3. Read or interpreted, under the direct supervision of an interpreting physician, the mammograms from the examinations of at least 240 patients within the 6-month period of { give dates of 6-month period },
or,
if the resident physician passed the certifying board examination in diagnostic radiology at the first allowable time, the 6-month period could have been any time within the last 2 years of the residency program { give dates of 6-month period }.
[NOTE: The "first allowable time" means the earliest time that a resident physician is eligible to take the certifying examination.]
________________________________________
[Signed by an official of the Residency Program]
________________________________________
[Must include signing official's title: e.g., Chairman of Program, Director of Residency Education, Director of Mammography Section]
©FDA DMQRP
