Texas State Board of
Podiatric Medical Examiners

(Updated March 5, 2010)

The purpose of this page is to explain and clarify requirements for a 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.

ANY person performing PODIATRIC (i.e. Foot/Ankle) radiological procedures as defined in Board Rule 22 Texas Adm. Code §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 Texas State Board of Podiatric Medical Examiners. This includes whether a person is a "Non-Certified Technician" (i.e. NCT; NCT-Podiatric) or a "Podiatric Medical Assistant" (i.e. PMA).

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

TEXAS STATE BOARD OF PODIATRIC MEDICAL EXAMINERS (TSBPME)

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 Texas Department of State Health Services (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 Texas Department of State Health Services Rules 25 Texas Adm. Code, §140.518 relating to "Mandatory Training Programs for Non-Certified Technicians” (i.e. NCT; NCT-Podiatric) and/or 25 Texas Adm. Code §140.522 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) and is NOT the 120-hour "Mandatory Training Programs for Non-Certified Technicians” NCT course (25 Texas Adm. Code, §140.518).

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

5) Click Here to 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) TSBPME "Podiatric Medical Radiological Technician" renewals will be mailed during the first week of December and are due December 31st of each year ($35.00 Renewal Fee). Late fees will be assessed for untimely renewals.

9) 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 Christine Riffe, Staff Services Officer, at Christine.Riffe@tsbpme.texas.gov or Fax written notice to (512)-305-7003.

TEXAS DEPARTMENT OF STATE HEALTH SERVICES (DSHS)

►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).

1. A “Non-Certified Technician” (NCT; NCT-Podiatric) is a person who has completed the Texas Department of State Health Services Rules 25 Texas Adm. Code, §140.518 "Mandatory Training Programs for Non-Certified Technicians" course; the 120-hour course.

2. NCT’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).

3. For NCT's, the Texas Department of State Health Services - Medical Radiologic Technologist Certification Program maintains a MANDATORY “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 "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 their "Registry" and related Continuing Education provisions.

5. An NCT 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.

Podiatric Medical Assistant (PMA)

1. A "Podiatric Medical Assistant" (PMA) is a person who has completed the Texas Department of State Health Services Rules 25 Texas Adm. Code, §140.522 "Alternate Training Requirements" course; the 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's; NCT-Podiatric).

3. For PMA's, the Texas Department of State Health Services - Medical Radiologic Technologist Certification Program allows a PMA to VOLUNTARILY be on the “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 "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 their "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.

Previously, at the February 6, 2006 TSBPME Board Meeting, a question was asked relating to confusion surrounding the need for NCT’s to register with the DSHS (formerly the Texas Department of Health), as well as being registered with the licensing board (in this case, the TSBPME) for the (podiatric) medical practitioner under whose instruction or direction the registered individual is practicing. (It is noted that the DSHS rules changed on/about November 20, 2008.) That previous response encompassed a time period from 2006-2009.

The following is current/updated as of March 5, 2010.

Question Presented:

Whether or not those NCT individuals performing radiological procedures under a Podiatric Physician must be registered with the DSHS "Registry" and with the TSBPME as a "Podiatric Medical Radiological Technician"?

Response:

► NCT’s, such as those person’s (DSHS Rule 25 Texas Adm. Code, §140.518) 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 DSHS NCT “Registry.”

In general, one must be initially NCT trained in accordance with DSHS specifications to perform NCT radiological procedures. The DSHS (training) “Registry” registration is MANDATORY for NCT's. Failure to renew NCT registration with DSHS results in removal of the NCT from the DSHS “Registry” (25 TAC §140.519(d)(4)). Removal from the DSHS “Registry” can result in the NCT's 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 who complete all the necessary DSHS specified training, MUST register with the MANDATORY DSHS “Registry.” Again, those NCT’s 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 who choose to be placed on the MANDATORY DSHS “Registry” should also renew DSHS registration (& maintain DSHS Continuing Education requirements) with the DSHS “Registry,” in order to remain on the DSHS “Registry.” The purpose of the MANDATORY DSHS “Registry” for NCT's is to inform consumers and employers that the NCT has completed the required training (DSHS Rule 25 TAC §140.518). If an NCT does not renew registration with the DSHS and falls off the “Registry,” it will be the responsibility of the employer to verify that the individual he/she has employed as his/her NCT has completed all the necessary training (DSHS Rule 25 TAC §140.518; 25 TAC §140.511; 25 TAC §140.519). This is a 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 should be familiar with the Texas Department of State Health Services (DSHS) related rules.

► PMA's, such as those persons (DSHS Rule 25 Texas Adm. Code, §140.522) 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 DSHS NCT “Registry.” Once a PMA is on the DSHS NCT "Registry," he/she must maintain all "Registry" requirements to remain registered.

Again, staff employed by a Podiatric Physician who are acting as a PMA should be familiar with the Texas Department of State Health Services (DSHS) related rules.

► Failure to renew registration with the DSHS "Registry" results in removal of the NCT or PMA from the DSHS "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 who can evidence proof of having taken the appropriate DSHS specified training course and upon (current) TSBPME registration will be allowed to perform radiological procedures.

1. An individual MUST first complete NCT (120-hour course; DSHS Rule 25 Texas Adm. Code, §140.518) OR PMA (20-hour course; DSHS Rule 25 Texas Adm. Code, §140.522) training specified by the DSHS - Medical Radiologic Technologist Certification Program. (DSHS regulation)

2. Once training is completed, an NCT MUST then register and maintain themselves with the MANDATORY DSHS “Registry” for NCT's. (DSHS regulation)

3. Once training is completed, a PMA MAY then register and maintain themselves VOLUNTARILY with the DSHS “Registry” for NCT's. (DSHS regulation)

4. In order to then perform PODIATRIC “Foot/Ankle” radiological procedures in a Podiatric Physician’s office/practice (your employer), an NCT or PMA must ultimately APPLY & 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.

►DSHS List of Approved NCT / PMA Training Programs  

►DSHS Forms: http://www.dshs.state.tx.us/mrt/mrt_forms.shtm

► Please note that although NCT / 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 this TPMA course is the 20-hour "Alternate Training Requirement" (DSHS Rule 25 Texas Adm. Code, §140.522) PMA course and is NOT the 120-hour "Mandatory Training Programs for Non-Certified Technicians” (DSHS Rule 25 Texas Adm. Code, §140.518) NCT course.

► Texas Podiatric Medical Association (TPMA) PMA course contact information:

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 to have their X-ray machine 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.