Several sections require training under the supervision of a licensed radiologic technologist.  Consider the situation where an individual seeking training at a licensed hospital, which has registered ARRT staff and no licensed staff since that is not required.  Sections affected are 18VAC85-101- 50 A, -60 B(2)(b)(1) and (2), and -70 1.

With respect to bone densitometry, is it the intent that bone densitometry is performed/referred by licensed doctors of medicine, osteopathy, chiropractiv, or podiatry?  In several states there is concern that bone densitometry is being performed with no oversight in pharmacies, and shopping malls.  18VAC85-101-100 appears to limit the scope to these previously mentioned professional groups, and 18VAC85-101-110 appears to delegate this activity to a licensed radiologic technologist.

18VAC85-101-140 appears to restrict the limited licensed radiologic technologist to accept refferals only.  Should this section or section 110 address health screenings that include bone densitometry or other health screenings that use radiographic procedures, such as chest X-rays, CT.  Note: mammography is prohibited in the scope of practice in these regulations and I agree that fluroscopic procedures should as well.