The Radiation Safety Section reviewed the requirements for mammography authorization in Part 135 - Radiation Control of the Public Health Code.  As a result of this review, we have reconsidered our interpretation of Section 13523(2)(g)(iv), one of the requirements for mammography interpreters.  That section requires each mammography interpreter to interpret not less than 520 mammographic examinations each year.

We had previously interpreted that paragraph to require the mammography physician interpreter to (1) have read 520 cases under supervision in the 12 months prior to reading mammograms independently and (2) to continue to read 520 cases every 12 months after being qualified to read mammograms.  We had, in effect, interpreted this as both an initial experience requirement and a continuing experience requirement.  Upon reconsideration, we now interpret this paragraph as a continuing experience requirement only.  There are no initial experience requirements in section 13523(2)(g).  As of this date, we will no longer require mammography physician interpreters to demonstrate that they have read 520 cases under supervision prior to reading independently.

We will continue to enforce section 13523(2)(g)(iv) as a continuing experience requirement.  A mammography interpreter will have 12 months after becoming qualified to demonstrate compliance this requirement.  After the initial 12 months, they will have to demonstrate that they have read 520 cases in a rolling 12 month period.

We remind mammography facilities they are still subject to the requirements of the federal Mammography Quality Standards Act (MQSA).  MQSA requires interpreting physicians to have read or multi-read at least 240 mammographic examinations in the 6-month period immediately prior to the date that the physician qualifies as an interpreting physician under MQSA.  This interpretation or multi-reading shall be under the direct supervision of an interpreting physician. 

Physicians who become board certified at the first allowable time may interpret or multi-read at least 240 mammographic examinations under supervision in any 6-month period during the last 2 years of their diagnostic radiology residency.

We have updated our publication BHS/HFS-895 - Summary of Interpreting Physician Qualifications.  An updated copy of this publication is attached and can be found on our website.