Texas Board of Licensure for Professional Medical Physicists
Guidance for the Supervision of Temporary Licensees
This document is intended to guide the supervising medical physicist and the medical physicist with a temporary license (TMP) in complying with the board’s supervision rules in Title 22, Texas Administrative Code (TAC)§601.2. Medical physicists who follow the guidance in this document are practicing within the rules. (It is possible that other practice not described by this guidance might also be in compliance with the rules.)
Title 22 (TAC) §601.2 provides the following definitions:
(22) Supervision--To oversee the work of a medical physicist holding a temporary license in the performance of those duties defined as the practice of medical physics. For the purpose of fulfilling the work experience and examination requirement, the supervisor shall be responsible for the temporary licensee's work during this period. The supervisor assumes the responsibility, and must have the authority, to observe and correct the actions of the individual being supervised. There are three levels of supervision as described in subparagraphs (A) - (C) of this paragraph.
(A) General Supervision--The temporary licensee works under the overall control and direction of the supervisor, but the supervisor's presence is not required during the performance of the work.
(B) Direct Supervision--The supervisor is present in the building or institution and immediately available to furnish assistance and direction throughout the work. The supervisor need not be in the room where the work is being performed.
(C) Personal Supervision--The supervisor is physically present in the room where the temporary licensee is working.
(23) Temporary License--A certificate authorizing an individual to practice medical physics under the supervision of a licensed medical physicist.
Title 22 (TAC) §601.9 includes the following:
(f) The work experience must be under the supervision of a licensed medical physicist holding a license in the specialty area. The work experience must be completed in accordance with a supervision plan approved by the board, signed by both the supervisor and the temporary license holder. The supervision plan shall describe the duration of personal, direct and general supervision with particular attention to the aspects of the work of the temporary licensee that could have the greatest effect on the safety of patients, personnel or the public. The board may audit supervision plans for compliance with this section. Supervisors and temporary license holders should refer to the board's guidance document on supervision for additional information and examples.
(g) A supervisor shall supervise no more than two temporary license holders, unless approved by the board.
(h) A supervisor shall assume responsibility for all of the work conducted under his or her supervision. A supervisor shall approve and sign all formal work product of the temporary license holder, such as reports of machine calibrations, shielding designs, treatment plan reviews, patient specific quality assurance measurements, treatment record reviews, and equipment evaluations.
Supervision is a responsibility that should not be undertaken lightly. The supervisor assumes professional responsibility for the work done by a TMP. The license and professional reputation of the TMP's supervisor are as much at risk in an incident that is the doing of the TMP as if the supervisor had personally caused the incident.
The role of the supervisor is akin to that of the master in an apprenticeship. The supervisor is teaching the TMP, i.e., the apprentice, the profession of medical physics. This teaching requires regular, high quality interactions between the supervisor and the TMP during which medical physics is practiced by the TMP under the guidance of the supervisor. As the TMP grows in professional maturity, it is appropriate for the supervisor to allow the TMP greater responsibility and autonomy, with the understanding that the supervisor will still countersign all work of the TMP and will take full professional responsibility for it as if it were the supervisor's own work.
The supervisor must have a relationship with the TMP that allows the supervisor to observe the work of the TMP and to correct that work if necessary. A supervisor cannot reasonably provide personal or direct supervision to TMPs who are working at different locations. If the TMP and the supervisor work for different employers, if the TMP and the supervisor routinely work in different locations, if the supervisor has an extensive travel schedule and thus is often unavailable, or if the supervisor has not seriously accepted the obligations to teach the TMP and to assume full professional responsibility for the TMP's work, the supervisor should not fill out and sign the Agreement of Supervision Form and the TMP should secure a supervisor who can perform these duties as required by the law and the board's rules.
A supervisor shall not supervise more than two temporary license holders, unless approved by the board. The board may ask for more details of the supervision plan for exceptions to this rule requirement.
The Responsibilities of the Temporary Licensee
The TMP must not practice medical physics without adequate supervision. If the TMP finds him- or herself making independent decisions with no Licensed Medical Physicist to consult for help or no Licensed Medical Physicist to countersign the work (e.g., a shielding recommendation or a treatment plan), the TMP should not be doing the work because the TMP is not adequately supervised.
If the relationship between the supervisor and the TMP changes (for example, because either one of them takes a new job), it is the responsibility of the TMP to secure a new supervisor before continuing to practice medical physics in Texas. Unsupervised practice as a TMP in Texas may not be counted toward the experience requirement for full licensure and would be illegal if counted toward clinical experience for examination by a certifying body.
If the TMP is licensed in more than one specialty, the supervisor must be fully licensed in all of the TMP's specialties or else the TMP must secure more than one supervisor so that all specialties are supervised by fully licensed medical physicists in those specialties. It is the responsibility of the TMP to ensure that his or her supervisors have the required licensed specialties at the time of the application for a temporary license.
A General Progression of Supervision
A supervision plan that consists of personal supervision (as defined above) for the first six months, direct supervision for the remainder of the first year and general supervision in the second year would satisfy the rules. In the second year, the supervisor should be accessible by telephone whenever the TMP and the supervisor are not at the same location.
When a TMP is getting six months' experience in an additional specialty, a period of three months of personal supervision followed by three months of general supervision with ready access to the supervisor by telephone is acceptable.
Medical Physics Residencies
All faculty members of a medical physics residency program should be fully licensed in the specialties that they teach. A supervisor who is on the faculty of a medical physics residency program may delegate day-to-day supervision of residents enrolled in that program to his or her colleagues on the faculty who are fully licensed medical physicists, provided that a fully licensed medical physicist in the appropriate specialty countersigns each item of work product by the TMP and that the formal supervisor shares with the delegate the authority to observe and correct the work of the TMP. It is reasonable for one faculty member to be the formal supervisor of all of the residents, even more than two at a time, and to delegate day-to-day supervision to other qualified faculty members. It is not appropriate for a more senior resident who is still practicing on a TMP license to countersign the work of a more junior resident in lieu of faculty supervision. Although senior residents' teaching junior residents under faculty supervision is entirely appropriate, both should sign a report or chart as supervised trainees and the countersignature of a fully licensed medical physicist is still required. The fully licensed medical physicist who actually supervised an item of work should countersign that work, but the formal supervisor is still ultimately responsible for the work of the TMP. The number of TMPs should not normally exceed two per faculty member.
If other LMPs will be providing supervision, the board asks that each of those LMPs provide a statement that they agree to oversee and take responsibility for the TMP’s work, and to countersign all the TMP’s work products. The board has created a draft Delegated Supervision letter for residency programs, (this is found in the Application for Licensure Packet) which you may use, or you may submit an equivalent document
If there are several fully licensed medical physicists in a group practice, it is acceptable for the supervisor to share supervision duties with his or her fully licensed colleagues as described above for residency programs. Again, if other LMPs will be providing supervision, the board asks that each of those LMPs provide a statement that they agree to oversee and take responsibility for the TMP’s work, and to countersign all the TMP’s work products. The board has created a draft Delegated Supervision letter for group practices, (this is found in the Application for Licensure Packet) which you may use, or you may submit an equivalent document. The number of TMPs should not normally exceed two per fully licensed medical physicist.
In a small practice, such as that of a solo medical physicist who hires a TMP as an assistant, care must be taken to provide sufficient supervision. In a consulting situation, the TMP should never be sent alone to a site that the supervisor has not previously visited or sent alone to work on a piece of equipment or to plan a procedure with which the supervisor is not familiar, even in the period of general supervision. The supervisor must countersign all work of the TMP and take full responsibility for it. It is thus the supervisor's responsibility to assess the readiness of the TMP to progress to a stage of less intense supervision.
If a supervisor would normally suspend his or her practice during a vacation, the TMP should not be allowed to work unsupervised during the supervisor's vacation. If the supervisor has a coverage arrangement with a colleague during vacation time, that coverage should be extended to delegated supervision of the TMP, if the TMP is to keep working during the time that the supervisor is unavailable.
The supervisor should not take on so many TMPs that he or she cannot provide personal and direct supervision during the early stages of each TMP's supervised experience.
Guidance for the Supervision of Temporary Licensees
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