North Carolina: Oppose Statewide Licensing Framework

What this Legislation Does 

• Creates a new licensing regime + new Board: HB 590 establishes the “Patient Safety in Medical Imaging Act,” citing patient protection from improperly performed imaging and radiation therapy and asserting that quality is increased by requiring education, examination, and licensure. It creates a Medical Imaging and Radiation Therapy Board of Examiners to administer licensure across multiple modalities, including radiography, CT, MRI, nuclear medicine, sonography, radiation therapy, radiologist assistants, and – critically – cardiac electrophysiology specialists and cardiovascular invasive specialists.

 

• Requires a license to perform imaging/radiation therapy; restricts employing unlicensed staff: The UNC School of Government bill summary describes the bill as requiring licensure to perform or offer radiologic imaging/radiation therapy, prohibiting employing non-licensed persons for those functions, and listing exemptions.

 

• Defines “Cardiac electrophysiology specialist” and ties it to fluoroscopy: The bill defines a cardiac electrophysiology specialist as a person registered to perform, under physician supervision, radiographic procedures and studies using external ionizing radiation to produce fluoroscopic images.

 

• Sets EP specialist licensing requirements: For a Cardiac Electrophysiology Specialist License, the bill requires: completion of a Board-approved course of study in cardiac electrophysiology; and current certification in cardiac electrophysiology from Cardiovascular Credentialing International (CCI) or another Board-approved certifying organization.

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• “Grandfathering” for current professionals (but limited): HB 590 directs the Board to issue a license within two years of the effective date to a currently practicing medical imaging professional/radiation therapist/radiologist assistant if they hold current certification recognized by the Board. Important caveat: the text is broad, but it still hinges on certification organization recognition and a time-limited transition, which may not capture all EP lab staffing realities.

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Why HRS and HRA Oppose the Legislation

 

The bill introduces risk in a few practical ways:

 

1. Workforce friction and hiring barriers: The EP specialist license requires a Board-approved course of study and specific certification (CCI or Board-approved equivalent). EP labs often rely on a mix of pathways (on-the-job training, cross-trained catheter lab staff, variable credentialing norms across systems). A new licensure regime can shrink the candidate pool, increase time-to-hire, and create “license gating” for experienced staff who are excellent but credentialed differently.

2. Unclear supervision/operational interpretation risk: The bill repeatedly anchors practice to “supervision of a qualified physician” for EP/cardiovascular invasive work with fluoroscopy. Even if intended as standard oversight, “supervision” language in imaging/radiation contexts can be interpreted rigidly (e.g., physical presence expectations). That concern is amplified by related regulatory debates in NC around radiation protection rules and fluoroscopy operation supervision.

3. Duplicative regulation with unclear incremental benefit for EP: Current systems already manage competency via: hospital credentialing, lab policies, CCI/RCES, vendor training, and physician oversight. Based on that, this bill seems to be regulating a problem that isn’t clearly demonstrated in EP labs, while adding new compliance workload.

4. “Slippery scope” concerns: Even if the bill is workable today, it builds a new Board with authority to set standards, approve certification organizations, set fees, and enforce discipline. Future Board rules could further constrain staffing models.

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HRA Recommended Strategy

 

Position: “Oppose unless amended”

We support patient safety and appropriate standards for imaging professionals. However, without changes this bill creates unintended barriers for EP labs, risks worsening workforce shortages, and may restrict care delivery without clear evidence of benefit.​

 

Hard grandfathering for existing EP lab staff

• Anyone currently functioning in an EP lab role involving fluoroscopy support should be deemed compliant based on employment attestation + physician medical director attestation, not only national certification.

• Extend transition window beyond two years or create an “EP lab endorsement” pathway.

 

Explicit “no new supervision burden” clause

• Add clarifying language that physician supervision does not require continuous physical presence beyond what is already standard for EP procedures (tailor to NC practice norms).

 

Narrow the EP license trigger

• Clarify what tasks require licensure versus tasks that do not (e.g., operating the fluoroscopy unit vs. assisting in procedural workflow).

• Prevent accidental licensing of roles that are not actually operating imaging equipment.

 

Board composition / EP representation

• Ensure EP/cardiology representation or advisory input if the Board regulates EP specialist standards.

 

Avoid bottlenecking certification approvals

• Require the Board to recognize multiple credible certification options (not a de facto single-cert pathway) and to publish approval criteria.

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North Carolina Residents: Take Action 

 

If you live in North Carolina, please take action today to let your State Senators know why you oppose this legislation and advocate for patient safety without the unintended barriers for EP labs or restricting care without clear evidence of benefit.

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