The Kentucky Society of Radiologic Technologists (KSRT) opposes enactment of HB61

Currently, HB 61 is with the Committee on Committees in the Senate. We respectfully request you to contact your legislator and the Committee members listed here to voice your opinion.\

To Whom it may Concern,

House Bill 61, which would change the definition of LXMO, was introduced on January 4, 2022 and is now with the Committee on Committees in the Senate, relates to Limited X-ray Machine Operators (LXMO). Currently LXMOs are prohibited from working in facilities where contrast studies, fluoroscopy, nuclear medicine and radiation therapy procedures are performed such as in a hospital, cancer center or independent diagnostic testing facility.

HB 61 would allow LXMOs to be employed by such facilities if he or she was employed by the facility as an operator of a source of radiation:

Amendments would read as follows: (In BOLD)

9 (a) "Limited X-ray machine operator" means an individual who performs limited radiographic procedures in facilities where contrast studies, fluoroscopy, nuclear medicine, or radiation therapy procedures are not performed.

   (b) Notwithstanding paragraph (a) of this subsection, an individual who holds a limited X-ray machine operator license may continue to be employed as a limited X-ray machine operator by a facility in which contrast studies, fluoroscopy, nuclear medicine, or radiation therapy procedures are performed if he or she was employed in that capacity by that facility:

1. Prior to the facility performing contrast studies, fluoroscopy, nuclear medicine, or radiation therapy procedures; or

2. Prior to the effective date of this Act.

10 Medical imaging technologist" means an individual who has completed an accredited educational program in radiography, nuclear medicine, or other imaging modality recognized by the board and who is licensed and granted privileges under this chapter. Other than a limited X-ray machine operator who meets the qualifications of subsection (9) (b) 1. or 2. of this section, only an individual licensed as a medical imaging technologist shall be employed to perform medical imaging at a facility where contrast studies, fluoroscopy[fluoroscopic], nuclear medicine, or radiation therapy procedures are performed;

The Kentucky Society of Radiologic Technologists (KSRT) opposes enactment of this bill citing that allowing limited x-ray machine operators to perform imaging examinations where contrast studies, fluoroscopy, nuclear medicine and radiation therapy procedures are performed is NOT in the best interest of patient safety. The limited education and clinical rotations associated with the LXMO curriculum in certificate programs, when compared to the Registered Radiologic Technologist degree programs, does not support or prepare LXMO certificated holders for employment by organizations that have nuclear medicine, radiation therapy, fluoroscopy, and or inject contrast. Difficulties in self-regulation and lack of awareness from management and/or physician director regarding scope of practice could potentially result in ethical and legal violations. Clinical education of radiologic technology students from accredited colleges and universities would also be in jeopardy as a LXMO cannot oversee the clinical rotation of a student pursuing a Radiologic Technology degree further hindering the number of clinical sites available to universities and colleges. Patients expect a degreed professional who is didactically prepared and clinically competent to deliver their care. Thus, it is imperative to set solid boundaries of where a LXMO can work without the fear or pressure of them operating outside their scope of practice, however unintentional. HB 61 blurs these boundaries and opens the door for medical errors and decreases in the quality of patient care for organizations who may employ LXMOs.

Thank You,

KSRT, INC.  Board of Directors