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Fluoroscopy operator requirements, application, FAQs

A fluoroscopy operator (FO) is a physician assistant or advanced nurse practitioner who has taken and passed a required test and has approval by the X-ray Certification Unit pursuant to 2.4.5.5 to operate only fluoroscopy systems. There are other individuals that may register as fluoroscopy operators if their scope of practice allows such use, this includes certain registered catheterization specialists.

Fluoroscopy operators can only operate/supervise the use of fluoroscopy machines. Fluoroscopy operators can not perform other x-ray examinations.

Physicians, registered radiologic assistants, radiology practitioner assistants and individuals with certain ARRT registrations do not need to register as a FO.

Colorado requires the registration and biennial renewal of fluoroscopy operators unless the individual meets the exemptions in 6 CCR 1007-1 Part 2, Section 2.4.5.5 (1)(a)(b)(c).

Fluoroscopy operator requirements

Please see below for the list of requirements needed to register as a fluoroscopy operator.

There are two pathways available for registration as a fluoroscopy operator. The first pathway is for physician assistants (PA) and advanced nurse practitioners (APN). The second pathway is for catheterization lab specialists. An additional guidance document on fluoroscopy operator registration is available to assist applicants with navigating the requirements for the two different fluoroscopy operator pathways.

The requirements listed below are for all pathways unless otherwise noted.

Continuing education requirement

Part 2, Appendix 2O, Section 2O.1.1

  • The applicant must complete at least 40 hours of education training on topics that include radiation physics, radiation biology, radiation safety, and radiation management applicable to fluoroscopy. Additional topics applicable to fluoroscopy may apply.

Clinical requirement

Part 2, Appendix 2O, Section 2O.1.2

  • The applicant must complete at least 40 hours of clinical experience in the use of fluoroscopy for guidance in diagnostic and therapeutic procedures under the personal supervision of a licensed physician.

ARRT testing requirement (PA & APN pathway only)

Part 2, Appendix 2O, Section 2O.1.3.1

  • The applicant must obtain a passing score on the American Registry of Radiologic Technologists (ARRT) examination for fluoroscopy operators.
  • Applicants have three attempts to obtain a passing score on the ARRT examination. Each attempt requires an additional application fee and testing fee.
  • A scaled score of 75 or above is passing.

Timing requirement

Part 2, Section 2.4.5.5 (3)(c)

  • Applicants must submit the application for registration as a fluoroscopy operator within one year of completion of the requirements in Appendix 2O.

Failure to pass the ARRT test within three attempts (PA & APN pathway only)

Part 2, Section 2.4.5.5 (3)(d)

  • If an applicant cannot achieve a passing score within three attempts, the applicant must restart the training required by Appendix 2O

Registration renewal requirement

Part 2, Appendix 2O, Section 2O.2.2

  • Every two years registrants must renew their registration.
  • PA and APN applicants need to include a copy of their DORA license
  • Catheterization lab specialist applicants need to include a copy of their current RCIS/RCES registration or other approved registration.

Registration requirements for RCIS/RCES students

  • RCIS/RCES students working towards their RCIS/RCES certification need to register as fluoroscopy operators. At the time of their first registration, RCIS/RCES students do not need to have completed the education and clinical requirements. RCIS/RCES students must submit all requirements during their first renewal of registration including their RCIS/RCES certification.

Fluoroscopy operator application

Submit the fluoroscopy operator application

Instructions for applying for registration as a fluoroscopy operator

PA/APN pathway

  • Complete the online application (The required R-50 & R-51 forms are now combined into the current online application).
  • Attach all supporting documentation for your continuing education and clinical experience.
    • Application for registration must occur within one year of completing the training requirements.
  • Attach your DORA license.
  • Submit the non-refundable $60 application processing fee.
    • Refer to the online application for additional information on how to make this payment.
  • Upon approval we will email you a letter with instructions and next steps on how to complete the testing portion with ARRT.
    • Additional testing fees apply.
  • If you need to retake the FO ARRT exam, please complete the application linked above. Please note: additional application fees and testing fees apply to each attempt.

Catheterization lab specialist pathway

  • Complete the online application (The required R-50 & R-51 forms are now combined into the current online application).
    • Catheterization lab specialists applicants have two years from first application to complete the clinical and education requirements. Applicants must submit all supporting documentation for completion of the clinical and education requirements at time of first renewal.
  • Attach your DORA license (if applicable).
  • Attach your RCIS/RCES certification or other approved registration (if applicable).
  • Attach your signed attestation letter, which states you will only perform fluoroscopy exams under personal supervision of a qualified physician.
  • Submit the non-refundable $60 application processing fee.
    • Refer to the online application for additional information on how to make this payment.

Transfers from out-of-state

  • Complete the application linked above.
  • Attach all applicable documents for equivalency review- state license, national board certification, state ARRT test scores, education transcripts and certificate/degree, supporting documentation for completion of your clinicals, DORA license, and any other documentation that supports your completion of the requirements.

Renewal of registration

  • To renew, complete the online application linked above (The required R-52 form is now combined in the current online application).
  • The registrant must submit their CO DORA license (if applicable), national board certification (if applicable), and pay the $60 application fee.

Fluoroscopy operator - frequently asked questions

Who is required to register as a fluoroscopy operator (FO)?

  • The FO registration is for physician assistants and advanced nurse practitioners. There are other individuals that may register as fluoroscopy operators if their scope of practice allows such use, this includes certain registered catheterization specialists. Please read the guidance document on fluoroscopy operator registration to understand the requirements for registration as a fluoroscopy operator. After reading, if you still have questions please reach out to our unit at: cdphe.hmxraycomments@state.co.us or call 303-692-3448.

I am already a registered fluoroscopy operator in another state (other than Colorado); does my fluoroscopy registration automatically carry over from state to state?

  • No, it may not directly transfer because states can have different requirements for fluoroscopy operators. For instance, the educational and clinical training requirements may vary. Please complete the online application and attach all supporting documentation including, but not limited to: state license, state ARRT test scores, education transcripts and certificate/degree, and supporting documentation for completion of your clinicals. The X-ray Certification Unit may request additional documentation and testing.

Can I pay for my application fees electronically?

  • Yes, you can make online payments via credit/debit card or electronic check (additional processing fees apply). The X-ray Certification Unit will email you your invoice once your application is up in the queue for processing. This can take up to 7-10 business days, but can occur more quickly depending on the volume of business.

Can I operate fluoroscopy machines as a registered nurse?

  • No, it is not currently within the scope of practice for registered nurses to operate fluoroscopy machines.

If I am a registered nurse, can I apply to register as a fluoroscopy operator?

  • No, it is not currently within the scope of practice for registered nurses to operate fluoroscopy machines. You would need additional credentials in order to apply to register as a fluoroscopy operator.

What do I do if my facility is allowing staff who are not qualified to operate fluoroscopy machines?

Do I still need to register as a fluoroscopy operator if I am not operating the pedal for the machine?

  • Yes, you will need to register. A radiation examination means performing a procedure, including selection of exposure settings, positioning the x-ray system and the patient, and initiating and terminating the exposure. Anyone engaged in conducting any part of the radiation examination must register unless exempted under 6 CCR 1007-1 Part 2, Section 2.4.5.5 (1)(a)(b)(c).  

If I am a registered fluoroscopy operator, do I still need to meet the requirements of regulation 2.6.1 and 2.6.1.5?

  • Yes, all individuals who operate fluoroscopy machines must meet regulations 2.6.1 and 2.6.1.5. Please see this guidance document on fluoroscopy training for additional information.

Can a fluoroscopy operator perform other x-ray examinations?

  • No, fluoroscopy operators can only operate/supervise the use of fluoroscopy machines. Fluoroscopy operators can not perform other x-ray examinations.

How long after training ends does a fluoroscopy operator have to register with the department?

  • Applicants must submit the application for registration as a fluoroscopy operator within one year of completion of the requirements in Appendix 2O.

Are RCIS/RCES students required to apply for fluoroscopy operator registration?

  • Yes, RCIS/RCES students working towards their RCIS/RCES certification need to register as fluoroscopy operators. At the time of their first registration, RCIS/RCES students do not need to have completed the education and clinical requirements. RCIS/RCES students must submit all requirements during their first renewal of registration including their RCIS/RCES certification. 

Are you required to renew a fluoroscopy operator registration?

  • Yes, you must renew your registration if you perform fluoroscopy examinations. Registration is valid for two years.

Are continuing education units required to renew a fluoroscopy operator registration?

  • No, you do not need to submit continuing education units to renew a fluoroscopy operator registration. Please note, at the time of their first renewal, RCIS/RCES pathway registrants will need to submit the rest of the original 40 CEUs required, if they did not have all of them when initially registering.

For additional information

Please contact CDPHE X-ray Certification Unit at: cdphe.hmxraycomments@state.co.us or call 303-692-3448.