MQSA Requirements for Mammography Technologists

A complete guide to MQSA mammography requirements for technologists covering everything from MQSA certification to MQSA mammography continuing education (CE) requirements

MQSA Requirements for Mammography Technologists

In this guide, we’ve put together everything mammography technologists need to know about MQSA requirements and certification, from what MQSA is to the MQSA CE requirements mammography technologists need to meet to maintain MQSA compliance, and what to do to get requalified if you failed to meet your MQSA requirements.

Table of Contents

What is MQSA?

MQSA stands for Mammography Quality Standards Act, a law enacted by Congress in 1992 with the intent of ensuring that all women could have access to quality mammography examinations in order to detect breast cancer early, when it is most treatable. The MQSA was amended in 1998 and 2004. The United States Food and Drug Administration (FDA) oversees and enforces the accreditation and certification provisions of the MQSA.

In order to offer mammography services, a facility must be MQSA certified. Offering mammography examination services without MQSA certification is illegal. If a facility fails to pass MQSA accreditation, they must stop providing mammography services at once, and may only resume services when they have corrected the indicated issues, applied for reinstatement, and received certification once more.

In order for a facility to be MQSA certified, it must be accredited by an approved body. Currently, the the American College of Radiology (ACR), the state of Arkansas, and the state of Texas are approved as MQSA accrediting bodies.

To achieve and maintain MQSA certification, a facility must:
  • undergo periodic reviews of its clinical images
  • have an annual survey conducted by a medical physicist
  • meet the MQSA quality standards for personnel qualifications, equipment, radiation dose, quality assurance programs, and recordkeeping and reporting
  • undergo an annual inspection by federally trained and certified federal or state personnel

As personnel involved in the production and processing of mammograms, radiologic technologists who perform mammographic procedures are required to have specific qualifications and meet certain MQSA requirements in order to perform mammography examinations.


How Do I Get MQSA Certified?

This is a commonly asked question, but it’s a bit misleading. You, the radiologic technologist, do not get MQSA certified. You don’t receive a stamp or a certificate or any such thing. It’s the facility that gets certified. You, as the radiologic technologist who performs mammography procedures, are a part of the facility’s overall MQSA certification process, and you must demonstrate compliance with the MQSA requirements for technologists.

Now, let’s take a look at what qualifications you need to have and what ongoing requirements you need to meet to be MQSA compliant.

Do I need to have a certification in mammography to perform mammography examinations?

No, you don’t need to have a certification in mammography. But there are some initial MQSA and state requirements that you do have to meet before you can legally perform mammography exams under the MQSA. Let’s take a look at those below.


Initial MQSA Requirements for Mammography Technologists

You must have ONE of the following:
  • A general radiography state license
  • OR
  • A general certification in radiography from and FDA-approved body (the American Registry of Radiologic Technologists ® (ARRT ®)
AND have completed ALL of the following;:
  • 40 contact hours of documented training in mammography under the supervision of a qualified instructor. These hours must include training in breast anatomy and physiology, positioning and compression, quality assurance and quality control techniques, and the imaging of patients with breast implants
  • 25 mammography examinations conducted under the direct supervision of an MQSA-qualified individual
  • 8 hours of training in each of the mammography modalities you will be using in performing mammography exams. These include full-field digital mammography, digital breast tomosynthesis, screen film mammography, and xeromammography
    An important note here: Before you can begin to perform unsupervised mammographic examinations in a new modality, you must complete at least 8 hours of continuing education in that new modality
A Special Case:

If it just so happens that you qualified as a radiologic technologist before April 28, 1999, under the FDA’s interim regulations of December 21, 1993, your initial MQSA requirements differ a bit. Take a look at the chart below for simplified comparison of requirements offered by the FDA’s Policy Guidance Help System.

Radiologic Technologist Qualification Worksheet This worksheet may be used by facilities to help ensure that their personnel meet all applicable requirements prior to providing mammography services.
Initial Qualifications Met Before 4/28/99 (INTERIM) Initial Qualifications Met After 4/28/99 (FINAL)
Need one of the following: Need one of the following:
General radiography license (any state) General radiography license (any state)
General certification (ARRT or ARCRT) General certification (ARRT)
Need one of the following: Need one of the following:
  • 40 hours of mammography training
  • ARRT (M)
  • CA Mammography Certification
  • AZ Mammography Certification
  • NV Mammography Certification
  • Completion of prior FDA accepted course or training
  • 40 hours of mammography training including the following subjects:
  • Breast Anatomy
  • Physiology
  • Positioning/Compression
  • QA/QC
  • Breast Implants
(attestation allowed if training completed prior to 10/1/94) 25 supervised patient exams (generally up to 12.5 hours can be counted toward the 40 hours, but must be documented)
START DATE _____________
(The later of 10/1/94 or date the last initial qualification was completed)
8 hours initial training in additional mammographic modality used (if applicable)
DATE COMPLETED ________________

Source: FDA Policy Guidance Help System, MQSA, Radiologic Technologist Overview. Available here.

Once you’ve met the initial MQSA mammography ce requirements, you can begin performing unsupervised mammography procedures. But you’ll need to bear in mind that mammography technologists have ongoing MQSA requirements to meet in order to continue to conduct mammography exams. We’ll lay out everything you need to know about your ongoing requirements below.


Ongoing MQSA Requirements for Mammography Technologists

MQSA Mammography Continuing Education Requirements

Once you have met your initial requirements to perform unsupervised mammography exams, you will need to have taught or earn 15 continuing education (CE) credits in mammography in the 36 months immediately preceding your facility’s annual MQSA inspection.

  • If you’re earning your CE credits/CEUs through teaching a specific mammography course, bear in mind that you can only count these toward the required 15 once, no matter how many times you taught the course in those 36 months
  • No fewer than 6 CE credits/CEUs need to be related to each of the mammography modalities you use
  • An important note here: The FDA Policy Guidance Help System lists the following notice regarding the MQSA 6 CE credit requirements specific to new mammographic modalities.
    • Note: FDA is exercising its enforcement discretion and is delaying enforcement of the six hour new modality continuing education requirement indefinitely.
    • Compliance with this requirement will be assessed for each individual during the first facility inspection performed after all of the following date benchmarks have taken place:
    • June 30, 2002, or
    • The third anniversary of the end date of the calendar quarter in which he or she met their initial requirements, or
    • The third anniversary date after he or she began using the new mammographic modality

On the recommendations from the National Mammography Quality Assurance Advisory Committee and the Institute of Medicine, the FDA intends to propose removing the requirement for mammography modality-specific continuing education credits and has delayed the enforcement of this particular requirement indefinitely.

What if my facility’s inspection is scheduled for less than 36 months since I met my initial MQSA mammography requirements?

If less than 36 months have passed between the date you qualified to perform mammographic procedures independently and the date of your facility’s annual MQSA inspection, you won’t be evaluated on continuing education requirements. Don’t worry. You’re fine.

A Great Resource If You Have Questions About the MQSA CE Requirements

If you have a really specific question about CE credits and CEUs, the FDA’s Policy Guidance Help System for the MQSA offers an exceptional set of answers to unique CE credit questions, such as what sorts of things do and don’t count for CE credits and what to do to be MQSA compliant if you met your initial requirements but did not start working in mammography until much later.

For more information and answers to your MQSA questions, call the MQSA Facility Hotline at 1-800-838-7715. You can also fill out a contact form at the MQSA Program Contact page.

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How can I know when my MQSA CE credits are due?

Check with your facility supervisor for the date of your upcoming MQSA inspection. Typically, MQSA inspectors will count your CE credits for the 36 months prior to the date of the annual inspection. But some inspectors may use a quarterly reporting system, which may affect your timeframe. Your facility supervisor will be able to tell you when your credits are due.

Can I count my 15 MQSA CE credits toward My ARRT ® CE requirements?

Yes! You can count your 15 MQSA CE credits toward your 24 ARRT ® CE credits requirement. But note that the reverse is not necessarily true.

Can I count applications training I received at work toward my MQSA requirements?

Yes, credits you earn during applications training at your facility can be used for FDA and MQSA requirements. However, these might not apply to your state and ARRT ® requirements. For examples, ARRT ® guidelines allow for technologists to apply a maximum of 8 CE credits earned through applications training per biennium (provided they were issued by an approved provider).

MQSA Mammography Continuing Experience Requirements

Mammography technologists also have MQSA continuing experience requirements to meet in order to maintain MQSA compliance. Technologists must complete a minimum of 200 mammograms within the 24 months immediately preceding their facility’s annual MQSA inspection. Check with your facility supervisor regarding the 24-month timeframe for your facility

What documentation do I need to provide at at the time of MQSA inspection?

At the time of your facility’s annual inspection, you need to provide your state licensure, board certification, documentation of your initial training requirement, and certificates of completion for 15 CE credits during the 36-month period prior to the inspection. You also will need to provide documentation that you have met the MQSA continuing experience requirement of performing 200 mammograms during the 36 months prior to the inspection.

Requalification: What do I do if I failed to meet the MQSA CE requirements?

If you if you fail to meet either or both the MQSA continuing education requirements or the continuing experience requirements at the time of your facility’s annual inspection, you must stop performing unsupervised mammography examinations immediately. Below, we outline what to do for each requirement in order to become requalified under MQSA regulations.

What to do if you fail to meet the MQSA mammography continuing education requirements

You need to earn the remaining credits to bring your total up to 15. You will not be allowed to perform unsupervised mammography exams until you have met this requirement. Under the FDA’s Interim regulations, a technologist was given 90 days to complete the required CE credits while still being permitted to perform mammography exams. Under the final regulations, this is no longer the case.

What to do if you fail to meet the MQSA mammography continuing experience requirements

To re-establish the MQSA continuing experience requirement, you will not to perform at least 25 mammography examinations under the direct supervision of a qualified radiologic technologist. Once you have completed this requirement, you are permitted to resume performing unsupervised mammography examinations.


Some Final Thoughts on MQSA Requirements

While the MQSA requirements for mammography technologists may seem daunting, it is important to remember that they were put in place to ensure that the women who come to your examination room receive a quality mammography exam that could, potentially, save their lives. With a little planning, a couple of well-timed reminders in your calendar app, and clear communication with your facility supervisor, you’ll be able to meet your MQSA requirements before your facility’s annual inspection. And when you’re ready to start on your MQSA CE requirements, Medical Professionals is proud to offer you our affordable interactive mammography courses.

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