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Advocacy and Persistence Pays Off In California
Change Can Actually Happen!
After the hard work and support of dedicated cardiovascular professionals, the California Department of Public Health has issued two notices recently that acknowledge the ability of a non-licensed professional to perform fluoroscopic duties under the direct supervision of a licensed supervisor and/or operator. This is in response to the advocacy push of the registered cardiovascular invasive specialists (RCISs) and graduates of accredited cardiovascular invasive program (CVTs) as well as educators and invasive professional societies. The interpretation of Title 17, a state regulation in California, raised considerable concern from the cardiovascular community because the interpretation prevented non-RTs from providing support during fluoroscopy. The interpretation of Title 17 limited the RCIS’s and CVT’s scope of practice with regards to performing the scrub role due to not being able to move the patient, the image intensifier, or change the magnification on the fluoroscopy equipment while the equipment was energized. Due to this interpretation the most qualified individuals to be performing invasive cardiovascular procedures and providing the best patient care were being excluded and even denied employment due to this regulation.
Due to the work of two very dedicated individuals, Edward Pezanoski and Elizabeth Barrow who spear headed the advocacy push in CA at the grass roots level and lobbied for resources and help from the invasive cardiovascular societies and the cardiovascular allied health care professional community made CHANGE HAPPEN! After countless years of presenting documentation of the RCIS and CVT graduates’ education, experience and credentialing process, the Department of Health has acknowledged the ability of a non-licensed allied health care professional to perform fluoroscopic support under the direction of a licensed supervisor and/or operator.
On September 15, 2014, an “Information Notice” was issued from the California Department of Public Health clarifying fluoroscopy permit requirements following regulatory changes that became effective October 1, 2013. As a result of those changes, fluoroscopy is no longer defined in regulation as a radiologic examination, but rather as a technique used to produce visible images. Previous policies and guidance concerning fluoroscopy permit requirements are superseded by this Notice. The notice explained that only a qualified person (permitted individual) may initially establish or re-establish spatial resolution, determine exposure factors, and/or expose a patient to x-rays in a fluoroscopy mode. A licentiate may use fluoroscopy equipment independently, provided he/she holds either a Radiology Supervisor or Operator (S&O) certificate or a Fluoroscopy Supervisor or Operator permit. It also goes on to say that a non-permitted person may move the equipment or the patient when the equipment is not energized or when the fluoroscopy equipment is being operated in the automatic exposure control (AEC) or automatic exposure rate control (AERC), the non-permitted individual may move the patient or the equipment at the request of and under the direct oversight and personal supervision of a qualified person.
On September 30, 2014, an Exemption to California Code Title 17 was issued by the Radiologic Health Branch which superseded the “Information Notice” issued September 15th. The exemption defines that a holder of an S&O permit or certificate is able to grant an exemption for non-permitted individuals to support procedures using fluoroscopy. The exception outlines the conditions that must be met in order for a “non-permitted” individual to perform the work of positioning the patient or equipment at the direction of a licentiate (which includes physicians as well as holders of fluoroscopy supervisor and operator permit or radiology supervisor or operator certificate).
The exemption officially declares that RCISs and CVTs can perform within their scope of practice while in the scrub role providing that the fluoroscopy equipment is on AEC or AERC mode, and the professional is positioning the patient and the equipment under the direction of permitted licentiate. Fluoroscopy settings in most invasive procedures are generally done AEC or AERC mode, therefore the allied health care invasive cardiovascular professionals can now practice fully within their scope of practice which will allow for the best practice for patient care.
The support of the invasive cardiovascular professionals throughout this journey has been astounding and it is essential that other states and invasive professionals know that CHANGE CAN HAPPEN! The Society of Cardiovascular Invasive Professionals (SICP) would like to take a moment and thank each and every one of you for taking the time to sign the petition that was put forth is support of this effort and for any other contribution big or small you might have made to this advocacy effort. It seems very daunting trying to change a state regulation or law but the request for such a change must come from constituents and professionals of that particular state to be taken seriously. If there is a group of individuals willing to put the blood, sweat and tears needed to make a change it is possible and there is support out there.
However, even though the Department of Public Health has issued Exemption to Code Title 17 allowing the RCIS and CVTs to work within their scope of practice there is still work to be done in California. At the October Radiologic Technology Certification Committee (RTCC) meeting, the committee tried twice to have the exemption notice withdrawn by the Department of Public Health but luckily the committee was unsuccessful. However the RTCC was able to pass two other motions, one of which was to set up a subcommittee to look for what they deemed a “better” solution than having the Exemption to Code Title 17. The second motion that was passed is to request that the CA Department of Public Health strike the words about positioning a patient DURING fluoroscopy, which would put the RCIS and CVT community right back to square one and this is unacceptable. Therefore, the support of this matter has to remain vigilant and persistent or our success could be short lived.
If you would like further information or have any questions about the changes in CA fluoroscopy regulations or have questions on how to proceed to make a change in your state please contact SICP at email@example.com call 919-861-4546.
Advocacy Database & Petition
SICP has created an advocacy database to establish a communication channel for the purposes of providing you with updates on SICP's advocacy efforts and mobilizing grassroots efforts.
*As of 9/15/14, the California Dept. of Public health updated their fluoroscopy permit requirements to now allow the RCIS to move the patient or equipment at the request of and under the direct supervision of a qualified person.*
Currently FL, KY, MD, ME, MN, NC, NM, NV, OR, RI, and SC are facing issues similar to what RCISs were facing in California prior to the 9/15/14 notice, with the interpretation and enforcement of radiation laws limiting the scope of practice for RCIS and CVT grads despite these graduates receiveing adequate training in radiation physics and safety specifically focused on the use of fluoroscopy. We are asking these states to support the graduates of CAAHEP Accredited Invasive Cardiovascular Technology Programs (Cardiovascular Technologists) and the Credential of Registered Cardiovascular Invasive Specialist (RCIS) as the minimum training required for providing safe patient care in the cardiac cath lab and allow the RCIS to operate the cath lab x-ray system under the supervision of the cardiologist.
We have created a petition requesting that these states update their interpretation of their radiation laws.
Please take a minute to add your contact information to our advocacy database and sign the petition. We will not use the information you provide on the form to contact you in regards to anything outside of our advocacy efforts and will never share your information with outside parties.
*Are you facing a similar challenge in your state? Email firstname.lastname@example.org.*
The state and federal governments have an obligation to protect the health and safety of the general public. It is our job to educate them on the expertise that the RCIS credential demonstrates so that minimum standards for the profession can be set by creating limited licensure in states where licensure currently does not exist.
SICP is working hard to research each state’s current statutes, create targeted educational materials and mobilize grassroots efforts. We would like to provide you with updates on these efforts and reach out to you when it is critical that elected officials hear from each and every one of us as the professionals and experts in our field. Please help us create a strong and unified voice by signing up to receive advocacy updates from SICP.
You might be asking, “Can we really make a difference”?
- Legislators know that just one phone call or letter represents the views of hundreds of people who have an opinion on the issue but did not take the time to communicate. They want to hear from you.
- Legislators count every phone call, e-mail, and letter on a given issue. Several legislators have been quoted as saying it only takes as few as five people reaching out about an issue for them to raise it to a higher priority level.
It’s time to make our voices heard. Please take a moment to add your contact information to our database.
Together we can make a difference!
Questions? Email email@example.com