A new bill (HB 72) was introduced on January 7, 2025 in the House and was assigned to the
Licensing, Occupations, & Administrative Regulations Committee on February 4, 2025.

As one of 6,768 registered Radiologic Technologists in the state of Kentucky, we feel that this bill will degrade patient care and potentially endanger the lives of our patients in the Commonwealth. Therefore, as professional radiographers, we strongly oppose HB 72.

Currently, Limited X-ray machine operators (LXMOs) are prohibited from working in facilities where contrast studies, fluoroscopy, nuclear medicine and radiation therapy procedures are performed such as in a hospital, cancer center or independent diagnostic testing facility.

HB 72 would allow LXMOs to be employed by such facilities, based upon the proposed
amendments to KRS 311B.020, which are presented below in BOLD:
(9) "Limited X-ray machine operator" means an individual who performs limited
radiographic procedures that shall not include contrast studies, fluoroscopy,
nuclear medicine, or radiation therapy procedures;
(10) "Medical imaging technologist" means an individual who has completed an
accredited educational program in radiography, nuclear medicine, or other imaging
modality recognized by the board and who is licensed and granted privileges under
this chapter. An individual licensed as a medical imaging technologist or a limited X-ray machine operator shall be employed to perform medical imaging at a facility where contrast studies, fluoroscopy, nuclear medicine, or radiation therapy procedures are performed, but a limited X-ray machine operator may only perform limited diagnostic radiography;

The enactment of this bill which would allow Limited X-ray machine operators to perform imaging examinations where contrast studies, fluoroscopy, nuclear medicine and radiation therapy procedures are performed. This is simply NOT in the best interest of patient safety.

The limited education and clinical rotations associated with the LXMO curriculum in certificate programs, when compared to the registered radiology technology degree programs, does not support or prepare LXMO certificate holders for employment by organizations that have nuclear medicine, radiation therapy, fluoroscopy and/or contrast studies. Difficulties in self-regulation and lack of awareness from management and/or physician directors regarding scope of practice could potentially result in ethical and legal violations.

Clinical education of students seeking an associates or bachelor’s degree in radiologic technology from accredited colleges and universities would also be in jeopardy if Limited X-ray machine operators were allowed to work in these facilities. Many radiologic technology programs within the state of Kentucky are accredited by the Joint Review Committee on
Education in Radiologic Technology (JRCERT), thus have to adhere to strict guidelines. One such guideline requires that the individual with which students train and work with be a registered radiologic technologists. Limited X-ray machine operators are not registered radiologic technologists, thus cannot oversee students during their clinical rotations— further hindering the number of clinical sites available to universities and colleges. As a result, this would lead to a reduced number of graduates entering into the profession exacerbating the critical shortage of radiologic technologists that already exists in the state of Kentucky.

Patients expect a degreed professional who is didactically prepared and clinically competent to deliver their care. Thus, it is imperative to set solid boundaries of where a LXMO can work without the fear or pressure of them operating outside their scope of practice, however unintentional. HB 72 blurs these boundaries and opens the door for medical errors and decreases in the quality of patient care for organizations who may employ LXMOs.

As members of the radiologic technology profession, we appreciate the opportunity to present our position on this important matter. We are grateful for your time and consideration and trust that our insights will contribute to an informed decision. We hope you will  thoughtfully consider our perspective as you deliberate on policies that impact our profession.

As professional Radiographers and future Radiographers, we strongly oppose HB 72.

Thank you for your service and dedication to our state.