X-Ray Rules Chiropractors Meet When They Move States

When a chiropractor licenses in a new state and plans to take x-rays there, three different rule sets come into play. The first is staff: whether an assistant who positions patients and exposes films needs a state radiography credential, or whether the chiropractic board lets the DC delegate on its own terms. The second is equipment: most states require the x-ray machine itself to be registered with a state radiation control program, separate from any professional license. The third is the board's own CE, which in some states includes imaging hours. A license by endorsement covers none of these automatically.

Imaging scope, meaning which studies a DC may order, take or interpret, is set by each state's practice act and is a question for the board. Below are the credentialing and registration pieces only.

Who on my staff may take x-rays?

This is where states differ most, and where clinics that move a trusted assistant across a state line get caught. Four examples we have verified:

• Florida. Section 468.302, Florida Statutes, bars anyone from using radiation on a human being unless they are a licensed practitioner, which section 468.301 defines to include chiropractic physicians, or hold a certificate under Florida's radiologic technology law and work under a licensed practitioner's supervision. The entry-level credential is the basic X-ray machine operator certificate, which allows general diagnostic radiography under the direct supervision and control of a licensed practitioner in the practitioner's office. An assistant registered with the chiropractic board does not, by that registration alone, hold a radiography certificate.
• Texas. The Board of Chiropractic Examiners lets a licensee delegate a radiologic procedure within the chiropractic scope to an individual with documented training and experience (22 Tex. Admin. Code § 78.5). The DC stays responsible, must document the individual's education, experience or other qualifications before delegating, and the DC or another licensed person with delegation authority must be on the premises while the procedure is performed.
• Arkansas. Chiropractic aides are unlicensed, and the board's applicant information says an aide who takes x-rays needs a state radiologic technology license or certification from the American Chiropractic Registry of Radiologic Technologists (ACRRT).
• Alaska. The board's clinical assistant rules require FCLB's CCCA or an equivalent program for clinical assistants. FCLB itself says the CCCA program is not intended for staff conducting x-rays, so a clinical assistant certification is not a radiography credential (see FCLB's chiropractic assistant credential).

So the same employee could take films in a Texas clinic on the DC's documented delegation, need a state certificate in Florida, and need a state license or ACRRT certification in Arkansas. Check the radiologic technology law, which usually sits outside the chiropractic practice act, as well as the chiropractic board's delegation rule.

Does the x-ray machine need its own registration?

Expect it to, and expect it to be filed with a different agency from the chiropractic board. Texas is the example we have verified: under 25 Tex. Admin. Code § 289.226, no person may use radiation machines except as authorized in a certificate of registration issued by the Department of State Health Services, and a person who acquires a machine before receiving one is still subject to the chapter. Healing arts registrants are also subject to § 289.227 on the use of radiation machines in the healing arts.

Practical points for a new location:

• The registration usually belongs to the facility or the registrant named on it, not to you personally. Buying an existing practice does not always transfer it.
• Shielding plans, inspections and dosimetry rules come from the radiation program, not the chiropractic board.
• Registration fees and inspection schedules are set by the radiation program; budget for them separately from license fees.

Do boards require imaging CE?

Some do. Alaska's biennial renewal requires 32 CE hours, of which eight must be in diagnostic imaging (12 AAC 16.290). The Florida, California, Texas and New Mexico CE rules we have read set general hour totals with required topics such as ethics, risk management or documentation, without a separate imaging line. Our post on chiropractic CE requirements by state has the verified totals.

A checklist before you practice in a new state

1. Read the chiropractic board's delegation rule for radiologic procedures, if it has one.
2. Read the state's radiologic technology law for who may operate x-ray equipment and which credential your assistant would need.
3. Find the state radiation control program and its machine registration requirements before the equipment is installed.
4. Check the board's CE rule for imaging hours.
5. Write down who on staff will expose films and what credential each person holds in that state.

Our state pages under chiropractic licenses by state note assistant rules where we have verified them. The Chiropractic Assistant Registration service ($99 per assistant) covers assistant filings with the chiropractic board, and our Annual Renewal & CE Compliance service ($299 per license, per year) tracks board CE, including any imaging hours. Radiation machine registration is filed with the state health agency, and we flag it on every new-state plan so it does not get missed.