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Provisional mammographer requirements, application, FAQs

A provisional mammographer is a person in training to become a qualified mammographer. Registration as a provisional mammographer requires the applicant’s enrollment in or completion of a qualified Mammography Quality Standards Act (MQSA) training program. While in training provisional mammographers can perform mammography exams under the supervision of a registered mammography technologist.

Colorado requires the registration of provisional mammographers in Part 2, Section 2.4.5.4 (3).

Provisional mammographer requirements

Training program requirement

Part 2, Appendix 2M, Section 2M.1, 2M.1.1, and 2M.1.2

  • Registration requires the applicant’s enrollment in or completion of a structured and documented training program that requires 40 hours or more of documented training in the areas of breast anatomy and physiology, positioning and compression, quality assurance/quality control techniques, and imaging of patients with breast implants.
  • The training must also include eight (8) hours or more of documented training in each mammography modality the technologist will use in performing mammography examinations.

Registration requirement

Part 2, Appendix 2M, Section 2M.2

  • The applicant must complete registration with the X-ray Certification Unit prior to completing any examinations on living humans.

Examination requirement

Part 2, Appendix 2M, Section 2M.3

  • While in training, the applicant must perform at least 100 mammography examinations on patients under the supervision of a qualified mammographer.
    • The applicant must perform the initial 25 examinations under personal supervision of a qualified mammographer.
    • The applicant can perform the remaining examinations under direct supervision of a qualified mammographer.
    • The applicant/facility must document all required examinations with the name of the supervised individual, the type of exam/modality, the facility name, the examination date, and the name of the supervising qualified mammographer.

Failure to complete the required training

Part 2, Appendix 2M, Section 2M.2.2

  • The applicant has one year to complete the required training and examinations. The applicant can extend their provisional mammographer registration for an additional year by applying again. Registrants may only renew their registration up to one time.

Registration renewal requirement

Part 2, Appendix 2M, Section 2M.2.2

  • The provisional mammographer registration is valid for one year.
  • Registrants may only renew their registration up to one time.

Provisional mammographer application process

Submit the provisional mammographer application

Instructions for applying for registration as a provisional mammographer

  • Complete the online application (Form R-64).
  • Attach all supporting documentation.
    • Proof of enrollment in or certificate of completion of 40 hour mammography training program which meets MQSA qualification.
    • Attach documentation of current ARRT(R) certification, if already credentialed.
  • 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 your registration letter.
    • Any facility you train at must retain a copy of this letter for the duration of your training.

Registration renewal

  • To renew, complete the online application linked above.
    • Registrant must resubmit all supporting documentation with application and pay the $60 application fee.

Provisional mammographer FAQ

What type of supervision is required for the first 25 exams?

  • The applicant must perform the initial 25 examinations under personal supervision of a qualified mammographer. This means the trainer is in the room with the trainee during the performance of the procedure.

What type of supervision is required for exams after the initial 25 are completed?

  • Additional exams performed, after the initial 25, are under direct supervision. This means the qualified trainer is present in the facility and immediately available to observe, correct, assist, and direct the trainee throughout the performance of a procedure. The trainer is not always required to be present in the room.

I did not complete my mammography training within the first year after approval as provisional mammographer. May I reapply?

  • Yes, you can resubmit a renewal application to extend your provisional mammographer registration for an additional year if you have not passed the ARRT (M) registry or completed the other requirements at the expiration of your initial provisional registration.

Is there a time limit for eligibility to take the ARRT (M) exam?

  • Yes, in order to take the ARRT (M) registry, applicants must complete all ARRT requirements within two years from the completion date of the training course. If the applicant exceeds the two-year period they will need to repeat the clinical mammography exams and complete a refresher course.  

Do I have to be a certified radiology tech with ARRT to be a provisional mammography tech?

  • No, as a provisional mammographer, you may not have obtained your ARRT(R) certification yet, but you can still train under supervision as long as you have met the other requirements. However, to be a fully qualified mammographer with the FDA, they require an ARRT(R) certification with ARRT, 40 supervised, contact hours of documented training specific to mammography, and a minimum of 25 mammography examinations under the personal supervision of a radiologic technologist qualified under 21 CFR 900.12(a)(2). Additionally, the State of Colorado requires obtaining the ARRT(R) (M) certification with ARRT.

Does the provisional mammography registration allow me to practice independently in Colorado?

  • No, a provisional mammographer registration allows you to train under the supervision of a qualified trainer.

What do I do with my provisional mammographer registration? 

  • Each facility, in which you train, must retain a copy of your provisional mammography registration for the duration of your training as proof of your registration in Colorado. Additionally, the trainee should keep a copy of all documentation acquired while in training.

What courses are available for the MQSA qualifying 40 hour mammography training?

  • There is a variety of online or in-person training courses available. Please note there are certain courses that do not meet the MQSA requirements. Please email cdphe.hmxraycomments@state.co.us prior to signing up for your 40-hour course, if you have additional questions regarding courses that qualify.  

Does the CDPHE X-Ray Certification Unit assist with clinical placement for my training?

  • No, clinical placement is up to you and the facility providing the training. You will need to train in a facility accredited with the American College of Radiology (ACR) in mammography. Some facilities may require additional requirements in order for you to train. Please check with individual facilities to secure clinical training.  

What can I expect during my clinical mammography training?

  • You will want to meet all requirements during training, so after completion you can practice independently as a mammographer. These include FDA MQSA requirements, State of Colorado requirements, and ARRT requirements.
  • Please visit the following websites for detailed information regarding specific training requirements.

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.

For additional information

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