Interpreting Physician Continuing Experience
Citation:
900.12(a)(1)(ii)(A): All interpreting physicians shall maintain their qualifications by meeting the following requirement: Following the second anniversary date of the end of the calendar quarter in which the requirements of paragraph (a)(1)(i) of this section were completed, the interpreting physician shall have interpreted or multi-read at least 960 mammographic examinations during the 24 months immediately preceding the date of the facility’s annual MQSA inspection or the last day of the calendar quarter preceding the inspection or any date in-between the two. The facility will choose one of these dates to determine the 24-month period.
Discussion:
The term “starting date” is used to describe the date on which an interpreting physician, radiographic technologist, or medical physicist has met all initial MQSA requirements and must begin to meet the continuing requirements for his or her specialty.
Any of the following options may be used to determine if the interpreting physician’s continuing experience requirement has been met:
Option 1: The inspector counts back 24 months from the date of the inspection. For example, if the inspection is conducted on November 10, 1999, the relevant time period would be determined by counting back 24 months from November 10, 1999 to November 10, 1997.
Option 2: The inspector counts back 24 months from the end of the previous full calendar quarter immediately preceding the inspection date. For the inspection date of November 10, 1999, the relevant time period would be determined by counting back from the end of the previous calendar quarter, i.e., September 30, 1999, to October 1, 1997.
Option 3: The inspector may also count 24 months from any date between the inspection date and the end of the previous full calendar quarter. This could be the case if the facility’s records are updated to such a date, i.e., between September 30, 1999, and November 10, 1999, in the above example.
FDA recommends that the facility try to consistently use the same dating option for all interpreting physicians and other personnel providing services to it. However, this is not required.
It is important for interpreting physicians who interpret at multiple facilities to update all facilities on the number of mammograms interpreted at other sites to ensure that their recorded experience is complete and accurate. Since the interpreting physician will not know more than a few days in advance when a facility for which he/she interprets will be inspected, updates should occur frequently (at least quarterly).
Physicians may document continuing experience by obtaining a letter, table, or printout from each facility, signed by a responsible facility official, stating that he/she has interpreted a given number of mammograms at the facility in a given time period. Alternatively, signed copies of facility logs could be provided.