The MAC’s Limited Diagnostic Radiographer Training Program is Now Available. Click Here for More Information! Click Here to Register!
If Your CAs Take X-Rays, You Need to Know About This Upcoming State of Michigan Requirement Deadline!
What You Need to Know!
- Beginning March 13, 2027, CAs, licensed/registered health providers whose scope of practice does not include the performance or taking of x-rays, or other qualified, unlicensed personnel who take x-rays in your office will be required to have completed a 40-hour training course as a limited diagnostic radiographer.
- The MAC’s program is now available!
- If you currently have CAs or other personnel described above taking x-rays in your office, and they do not have a “written statement of assurance” that the individual is “competent to apply machine-produced ionizing radiation to human beings,” complete one ASAP to remain in compliance.
Q: What’s This All About?
A: If you have CAs in the office who operate ionizing radiation equipment (i.e., take x-rays), an upcoming State of Michigan requirement fulfillment deadline could affect your practice!
Effective March 13, 2024, the Michigan Occupational Safety and Health Administration (MIOSHA, adopted new standards for health practitioners’ staff members who take x-ray images. If you use CAs, licensed/registered health providers whose scope of practice does not include the performance or taking of x-rays, or other qualified, unlicensed personnel to take x-rays, they are bound by these new requirements.
Q: Is a Limited Diagnostic Radiographer Required to Obtain a License or Other State Registration to Take X-Rays in Michigan?
A: No. A license (or other registration with the State of Michigan) is not required, nor is the State of Michigan anticipating one in the future at this time. This is just a requirement that the LDR obtain initial training and subsequent continuing education, ensuring their competency to perform their radiographic duties.
Q: Does This Affect Me? Other DCs in My Office?
A: No. If you, as a chiropractor who is licensed to practice in Michigan, or another licensed chiropractor, take all x-rays in your clinic, the new Rules will not affect you at all, as “the performance, ordering, or use of x-ray” is within Michigan’s Chiropractic Scope of Practice [(see MCL §333.16401(1) (e)(ii)(D)]. According to Rule R 333.5209(1), nothing within the Rule “shall be construed to limit or affect in any respect, the… practice of individuals properly licensed under Article 15 of the public health code… with respect to their professions and scope of practice.”
However, if your situation changes, and a CA or other qualified, unlicensed person – or a licensed/registered provider whose scope does not include the taking of x-rays – takes such films, they will be required to obtain the certification.
Q: What Do the Rules Require of CAs Who Take X-Rays?
A: The “Ionizing Radiation Rules Governing the Use of Radiation Machines” create four types of qualifications for non-licensed staff who take x-rays:
- Active
- Temporary
- Limited (Beginning March 13, 2027, and moving forward, most CAs that take in-office x-rays will fall into this category)
- Conditional (see more below – this classification ends March 13, 2027)
Limited status is reserved for individuals who have successfully completed a 40-hour training program relevant to the radiologic science within the limited scope of practice. This training must include both clinical and didactic components.
Upon adoption of the new Rules, staff members who did not have active, temporary, or limited status could obtain conditional status, until three years after the effective date of the new rules (March 13, 2024 – March 12, 2027). These individuals are considered qualified, contingent upon a written statement of assurance that the individual is “competent to apply machine-produced ionizing radiation to human beings.”
Please note: If you currently have CAs or other non-exempt individuals taking x-rays in your office, and you do not have a written statement of assurance in their employment file, your office is in violation of these MIOSHA rules. The MAC Legal Affairs team strongly urges you to complete one immediately. While we have not been informed of any widespread effort by the State of Michigan to enforce the rules, we have heard about isolated incidents. See below for more information and a sample written letter of assurance.
Q: Can My CAs Just Continue on “Conditional Status” After the March 2027 Deadline?
A: No. As of March 13, 2027, conditional status will no longer be recognized by the State of Michigan. Every individual with conditional status, if they wish to continue utilizing x-ray machines after March 13, 2027, must have completed a 40-hour training program.
Q: Does the MAC Training Program Fulfill the 40-Hour Requirement?
A: Yes. The State rules require that the program be “competency-based,” contain both clinical and didactic components, and include the following general categories:
- Fundamentals of healthcare
- Medical terminology
- Patient care and management
- Human anatomy and physiology
- Imaging equipment and radiation production
- Radiation protection and radiobiology
Additional, limited spine programs must include instruction on spine radiographic procedures, and limited extremity programs must contain instruction on extremity radiographic procedures.
The MAC’ affordable, easy-to-use program contains all these elements and includes:
- 28 total hours of didactic training (10.5 hours are currently available, with remaining content being added on a rolling basis)
- A fully developed clinical rubric to guide the required 12 hours of hands-on training, including concrete metrics and a sample competency certificate, where the doctor works directly with and oversees the CA throughout the clinical experience
All remaining didactic content will be completed and uploaded by May 22, 2026, allowing enrollees to start now and seamlessly continue as new material becomes available.
All didactic content is taught by Beverly Harger, DC, Professor of Radiology at Western States Chiropractic College, bringing a high level of expertise and practical application to the program. For more on the MAC program, including special member pricing and more, click here. To register, click here.
Q: When Should My CA Complete Their Training?
A: That is a decision every office must make for themselves. However, keep in mind that once the 40-hour training is complete, the continuing education clock immediately begins. Under the rules, limited diagnostic radiographers are required to obtain 12 hours of continuing education every 24 months after the program’s initial completion. For example:
- If a CA completes their training on August 1, 2026, they must have the required 12 CE hours by August 1, 2028.
- If a CA waits and completes the training closer to the March 13, 2027, deadline, the beginning of the continuing education clock is delayed to a later date.
For what the State considers options for meeting the CE requirements for limited diagnostic radiographers, consult the Rules (specifically, R 333.5213(3).
All limited diagnostic radiographers are required to maintain proof of participation in continuing education activities.
Q: Do We Need to Have a Written Statement of Assurance for Every Staff Member Who Does X-Rays In Our Offices Now?
A: Yes, there should already be a written statement of assurance in the personnel file for every type of staff member described above. The statement of assurance must:
- State that the operator is competent to apply machine-produced ionizing radiation to human beings;
- State the nature of the equipment and procedures the individual is competent to utilize;
- Be signed and dated by a licensed practitioner in the facility; and,
- Be kept on file and made available for inspection by the Michigan Department of Labor and Economic Opportunity (LEO), Radiation Safety Section.
Q: Does the MAC Have a Sample “Written Statement of Assurance” Available?
A: Yes. The MAC’s sample written statement of assurance can be found here.
Sources / Additional Information
- Michigan Department of Labor and Economic Opportunity, Radiation Safety Section, Ionizing Radiation Rules Governing the Use of Radiation Machines, Part 5. Operator Qualifications
- Michigan Department of Labor and Economic Opportunity’s FAQ X-Ray Operator Qualification Rules
Updated May 18, 2026
