CDPH-RHB X-Ray Supervisor & Operator Permit

RENEWAL OF CDPH-RHB RADIOGRAPHY X-RAY SUPERVISOR & OPERATOR PERMIT (XSOP) - Required Every 2 Years (biennual) (Last Update 15-November-2022)  

BACKGROUND ABOUT AN XSOP

In California a licentiate degree alone (MD, DO, DC, DPM) DOES NOT allow for the use of x-ray or other ionizing radiation on human beings.  In California the professional use of x-rays and other ionizing radiation on human beings takes place through a complex system of certifications for both licentiates (doctors) and non-licentiates (technologists).  This system is different than in most other states and presents challenges when doctors migrate to California.

In California the only licentiates (MD, DO, DC, DPM) allowed to apply x-rays to human beings are those possessing a valid California Department Of Public Health-Radiologic Health Branch (CDPH-RHB) Supervisor & Operator Permit, or a medical radiologist possessing a Radiology Supervisor & Operator Certificate.  The Radiology Supervisor and Operator Certificate is unlimited in scope and issued only to qualified medical radiologists and oncologists by a special non-test-based process.  There are four (4) different supervisor and operator permits, each with varying lesser scopes, that are granted after a rigorous application and testing process.  These four (4) supervisor and operator permits include: 1. fluoroscopy, 2. radiography, 3. dermatology and 4. bone densitometry.  From this point on I will only be discussing the CDPH-RHB RADIOGRAPHY X-Ray Supervisor and Operator Permit (XSOP) because it is used by the Chiropractic profession and most other non-radiologist licentiates.  A CDPH-RHB RADIOGRAPHY X-Ray Supervisor and Operator Permit (XSOP) allows the licentiate to “perform radiography” and "supervise" one or more non-licentiate professionals to include: certified x-ray technologists (RT) and limited x-ray technicians (XT).  X-ray technologists and technicians may practice radiography only under the supervision of a licentiate supervisor and only by written authorization. Licentiate supervisors (licentiates possessing an XSOP) are authorized to both take x-rays themselves and supervise radiography performed ONLY by a certified RT or XT.

WHICH LICENTIATES (DOCTORS) ARE ALLOWED TO "PRACTICE RADIOGRAPHY" IN CALIFORNIA

Every facility that applies x-rays to human beings must have at least one certified permitted supervisor available and on duty when radiographs are being produced. Each supervisor on duty is responsible for all x-ray-related activities at that facility and is required by law to have a legible copy of a CURRENT XSOP posted on the wall of that facility. Misconceptions about which doctors (MD, DO, DC, DPM) can practice radiography in California are common. The short simple answer is that no doctor of any kind (MD, DO, DC, DPM) may use x-rays on human beings (in this case, practice radiography) unless he is also a licentiate supervisor (has an XSOP). It does not matter if there is another doctor in the x-ray room who is a licentiate supervisor. The RHB considers any licentiate supervisor who is supervising a non-technologist practicing radiography to be aiding and abetting a crime. Under CCR, title 17, section 30400(38) the "practice of radiography" is defined as the procedure for creating an X-ray image, and includes one or more of the following: (A) positioning the patient; (B) selecting exposure factors; or (C) exposing the patient and the recording medium to X-rays. Anyone who "practices radiography" as previously defined WITHOUT any of the certifications described above (XSOP, RT or XT) has committed a misdemeanor punishable by jail time and fines. Any permitted supervisor aiding and abetting a non-technologist performing radiography has committed a misdemeanor based on CA Health and Safety Code 107110. Quoting: "It shall be unlawful for any licentiate of the healing arts to administer or use diagnostic, mammographic, or therapeutic X-ray on human beings in this state after January 1, 1972, unless that person is certified pursuant to subdivision (e) of Section 114870, Section 114872, or Section 114885, and is acting within the scope of that certification."  To "practice radiography" in California, any licentiate (MD, DO, DC, DPM) needs BOTH a current license to practice in California AND a current CDPH-RHB Radiography X-Ray Supervisor And Operator Permit (XSOP). BTW, non-permitted individuals (no XSOP, no RT, no XT) can process the images, or perform the required QC, provided they can document adequate training. However, make sure the non-permitted individual does not slip down the slippery slope to practice radiography (position, factor or fire). If you need to acquire an XSOP, I can help.

CONTINUING EDUCATION REQUIREMENTS FOR RENEWAL

Beginning 2004, Section 30403 of Title 17, California Code of Regulations (CCR), administered by the California Department Of Public Health, Radiologic Health Branch (CDPH-RHB aka RHB), requires that all California X-Ray Supervisor And Operator Permit (XSOP) holders earn 10 approved x-ray Continuing Education Credits (CEC) before renewal, which is every two years (biennial).

Quoting the RHB Continuing Education Requirements for Certificate/Permit Renewal: "an approved continuing education credit” means 50 - 60 minutes of instruction received in subjects related to the application of X-ray to the human body and accepted for purposes of credentialing, assigning professional status or certification by the following organizations:
• American Registry of Radiologic Technologists (ARRT)
• Medical Board of California
• Osteopathic Medical Board of California
• California Board of Chiropractic Examiners
• Board of Podiatric Medicine
• Dental Board of California

Subjects related to the application of X-ray to the human body may include X-ray administration, X-ray management, X-ray pathology, X-ray diagnosis and X-ray quality control. However, subjects in MRI, Ultrasound, CPR, or other topics not related to the application of X-rays to the human body cannot be accepted. It is the responsibility of the certificate or permit holder to ascertain the acceptability of courses."

The biennial x-ray requirement administered by the RHB is separate and distinct from the CA BCE annual chiropractic license renewal requirements. There is NO X-RAY CE REQUIREMENT TO RENEW A DC LICENSE. There is a biennial 10 hour x-ray CE requirement to renew a XSOP, which is managed separately by the CDPH-RHB. I recommend that every DC visit the BCE website at www.chiro.ca.gov (LINKS ALSO AT BOTTOM OF THIS PAGE) to confirm that any prospective post-graduate course is approved.

BIENNIAL RENEWAL OF YOUR XSOP

Section 30403 of the CCR also states that you file your renewal paperwork and pay the renewal fee at least thirty (30) days prior to the expiration date of your XSOP, to assure adequate processing time. If you do not renew your XSOP, it will automatically be suspended the day after the expiration date on your XSOP. If your California healing arts license (MD, DO, DC, DPM) is suspended for any reason, your XSOP "shall be invalid pending renewal or reinstatement of the license." CDPH-RHB mails renewal paperwork to all doctors (MD, DO, DC, DPM) possessing an XSOP every two years (biennial) for XSOP renewal. This renewal paperwork should arrive at your listed address 30-45 days before the expiration date on your permit, assuming that the RHB has your current name and address on file. A CDPH statute requires that all supervisors report any change of name or address to CDPH-RHB within thirty (30) days of the change, and failure to do so is not only a violation of that statute, but also a common reason doctors do not get their biennial XSOP renewal paperwork. The RHB is not perfect, and neither is the United States Post Office, and for many reasons a licentiate supervisor may not receive his renewal paperwork. This is where the doctor must be vigilant and realize that his XSOP is about to expire and the renewal paperwork he depends on NEVER ARRIVED. Here is a link to the RHB form to update your name and address:  Name/address change. Browse to the bottom of the page and look under Miscellaneous Forms. 

Make sure the XSOP posted on the wall in your office is the most current one. Some doctors renew and forget to replace the old with the new permit. Look at the expiration date in the lower left corner of your “current” XSOP. If today’s date is over five (5) years beyond the expiration date on the most current permit, then it is permanently expired and cannot be re-activated. The RHB will make you apply and test for a new XSOP. If, however, today’s date is less than five (5) years beyond the expiration date, you can re-activate it without re-testing. Think hard before “letting it go” because getting a new XSOP is both difficult and expensive. Due to the COVID pandemic, phone communication with the RHB is difficult, so you must act fast and on your own.

REINSTATE YOUR ABOUT TO EXPIRE OR EXPIRED PERMIT

If your XSOP is about to expire and you DID NOT receive the renewal paperwork, or if your XSOP expired less than five (5) years ago, and you want to re-activate it, go to CDPH-RHB Applications, browse to Special Renewal Application (SRA) Forms (Use Only if You Did Not Receive a Certificate/Permit Renewal Notice), download SRA Form for Licentiate S&O Certificate or Permits: CDPH 8238 SRA III (PDF), fill it out and send it in with your check and proof of continuing education. Do this by trackable means (certified mail return receipt, etc.). Keep immaculate copies of everything ready to re-mail if the first mailing “gets lost.” You must be able to prove it was mailed. Note RHB Reinstatement Fee Schedule - X-ray Certificates/Permits (PDF) Everything you need is there; you just have to follow through. Keep in mind that if your XSOP has expired, supervising or taking x-rays with an expired permit is a misdemeanor crime. If your license to practice in California (MD, DO, DC, DPM) is suspended for any reason, then the XSOP attached to that license to practice is also automatically suspended. The longer you keep taking x-rays with an expired permit, or no permit, the more severe the penalties will be when you are caught.  RHB health inspectors are experienced detectives who know all the tricks.

APPLY AND TEST FOR A NEW XSOP

If more than five (5) years have passed beyond the expiration date on your most current XSOP, then it has permanently expired and cannot be re-activated. You must file a new application to the RHB for a NEW CDPH-RHB XSOP, and re-sit the NEW examination process. This requires a non-refundable application fee of $127.00, plus a non-refundable testing fee of $275.00 paid over and over again until you pass the test (note fee increase as of September 1, 2017). If you need to apply for a NEW CDPH-RHB Radiography X-Ray Supervisor and Operator permit, do the following:

To apply for a CDPH-RHB Radiography X-Ray Supervisor and Operator permit (XSOP), the applicant must already have a valid license (MD, DO, DC, DPM) to practice in California. Submitting a copy of that license to practice is part of the application process. Go to the applications page on the CDPH-RHB website: CDPH-RHB Applications. Browse down to Licentiates (MD, DO, DC, DPM) - Initial Applications Forms [Do Not Use For Renewal Purposes] and select application form: CDPH 8230 (PDF) - California Licentiate Supervisor & Operator Permits. Print out the 2-page application form, fill it out and send it to the RHB with all supporting documents and a non-refundable application fee of $127.00 (reflects fee increase September 1, 2017). You will be contacted by the RHB within thirty (30) calendar days with instructions on which examinations you must pass within one (1) calendar year to obtain the permit(s). If your application is not acceptable to the RHB, they will contact you with instructions for more documentation, fees, etc., which you must submit within thirty (30) calendar days in order for CDPH-RHB to consider the application acceptable. If your application is approved, you will be directed to the new ARRT/California website to purchase an exam and pay an additional non-refundable exam fee of $275.00 (pays for one exam).  After you purchase an exam date and time, you will be directed to OPTIONAL web-based study materials on the ASRT website costing an additional $349.00. If you do not take the exam within the allotted year, then you must submit a new application and fees to begin the process again. One application gives you the opportunity to take the test multiple times within a one year window. To pass the exam you must receive a score of 75%. You must be aggressive with this process or risk losing considerable time and money.

MY PREP COURSE DESIGNED SPECIFICALLY FOR THE NEW ARRT-ADMINISTERED CDPH-RHB RADIOGRAPHY XSOP EXAM

Since July 1, 2018 the CDPH-RHB Radiography X-Ray Supervisor & Operator Permit (XSOP) exam process transferred from the RHB to the American Registry Of Radiologic Technologists (ARRT). Before this date I offered a mature and quite effective live webinar-based 9 hour prep course to help doctors pass the test and get a XSOP. Because of significant changes in content of the NEW ARRT-administered exam, my entire prep course for the OLD exam was discarded. Targeting the NEW exam, I spent approaching 2,000 hours from July 2018 through August 2020 creating a totally new live webinar-based 12 hour prep course to pass the new ARRT-administered XSOP exam. Since the ARRT exam changes annually, I will never be freed from editing my course. If you are interested in this new live-webinar-based course to prepare you for the NEW ARRT-administered exam, please browse my website to CONTINUING EDUCATION, COURSE DETAILS or go directly to SCHEDULE & PRICING or REGISTRATION & PAYMENT by either clicking the preceding links or following the menus along the top of this page. Please check the SCHEDULE. Thank you.

IMPORTANT REMINDER

The RHB requires all XSOP holders to renew their permit every two (2) years (biennial) with fees & CE credits -- period. The XSOP renewal requirement does not change if you use, or do not use, your XSOP to supervise or take x-rays. It is a separate renewal mailing, unrelated to licentiate (MD, DO, DC, DPM) renewal and not included in your biennial x-ray facility (tube) registration fee. A CDPH statute requires that you report any change of name or address to CDPH-RHB within thirty (30) days of the change, and failure to do so is not only a violation of that statute, but also a common reason doctors do not get their biennial XSOP renewal paperwork 30-45 days prior to expiration. If your XSOP is close to expiring, and you did not receive the CDPH-RHB renewal paperwork, or if it has already expired less than five (5) years, follow the directions above at REINSTATE YOUR ABOUT TO EXPIRE OR EXPIRED PERMIT.

For your protection, keep track, and good records, of your biennial XSOP renewals. LOOK AT THE DATE ON THE LOWER LEFT CORNER OF YOUR XSOP! Every two years you must replace your XSOP displayed on the wall in your office with the current (renewed) copy. This is among the first things a RHB health inspector checks after he/she enters your office. Put this on your list of things you MUST remember to do. Prevent that fear you will feel after learning you must RE-TEST for a NEW ARRT-administered CDPH-RHB Radiography X-Ray Supervisor & Operator permit!

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