Authorized User-Eligibility: Changes Afoot in the Designation
By Paul E. Wallner, DO, ABR Associate Executive Director for Radiation Oncology; and David Laszakovits, MBA, Director of Communications
In 2004, following an agreement reached with the U.S. Nuclear Regulatory Commission (NRC), the ABR began to add the designation “Authorized User-Eligible” (AU-E) to Initial Certification certificates of certain diagnostic radiology (DR) and radiation oncology (RO) diplomates. The designation was granted to IC awardees whose program directors (PDs) had attested to the ABR to completion of all Accreditation Council for Graduate Medical Education (ACGME) program requirements that included the training and experience (T&E) elements mandated for use of agents requiring written directive, defined in 10CFR35.390, 490, and 690.1
The intent of this added certificate designation was to provide diplomates verification of required documentation for appropriate providers to become AUs of specific radioactive agents. The designation changed nothing in the requirements for T&E and was just one of the pathways available to physicians interested in obtaining AU status from the NRC. The designation did not confer Authorized User status, which has always required a request for, and inclusion of, the provider on individual facility licenses. In addition, the designation had no bearing in some of the 39 Agreement States, which operate their own radiation regulation programs under “Agreement” with the NRC.2 Many of these Agreement States have always required AU applicants to provide the primary documentation noted in the individual NRC regulations.
On March 25, 2022, the ABR Board of Governors (BOG) announced that, effective Dec. 31, 2023,3 the ABR would no longer award certificates with the AU-E designation. The NRC and critical stakeholders had been previously informed of this decision and, after the announcement, the ABR hosted an open webinar to address program director, candidate, and diplomate questions. The webinar was recorded for public access.4 The nature of some questions suggested continued misunderstanding of the BOG decision and the implications in the field of that decision.
The AU-E designation for radiation oncologists never had an intrinsic relationship to board certification. The requirements for AU-E status are defined by the NRC, not the ABR, and are included in program requirements mandated by the ACGME Radiation Oncology Review Committee (RO RC). Training programs are the primary generators of the records necessary to attain both AU-E and AU status and should maintain those records indefinitely. Physicians who are not certified by the ABR, or any other board recognized in this regard by the NRC, are eligible to become AUs if they have completed and documented all elements of the NRC-defined requirements. The ABR has never collected data related to the number of diplomates who use the AU-E status to proceed to AU status or use the designated agents, but we are aware that many never use the qualification. If AU status is not attained within seven years, or it is attained but remains dormant, the diplomate must obtain documentation of the T&E requirements from the program, not from the ABR.
Despite the AU-E designation being unrelated to Initial Certification, the ABR has expended significant staff resources to maintaining the process. The Board has not increased fees to candidates and diplomates in five years, and the BOG ultimately determined that they could not support an increase in fees for a program not linked to the Board’s primary mission and not used by all designated diplomates. The ABR has committed to work with stakeholder organizations, including programs and the ACGME RO RC, and with candidates and diplomates to inform them of the need for development and maintenance of documentation to support AU-E. The Board will engage with these entities, the NRC, and Agreement States to stress the relevance and appropriateness of current T&E requirements to their AU-E designation.
- US Nuclear Regulatory Commission regulations, 10CFR Part 35. https://www.ecfr.gov/current/title-10/chapter-I/part-35?toc=1 . Accessed May 1, 2022
- US Nuclear Regulatory Commission agreement states. https://www.nrc.gov/about-nrc/state-tribal/agreement-states.html Accessed May 1, 2022.
- American Board of Radiology Blog Post, March 25, 2022. https://www.theabr.org/blogs/au-e-designation-process-changing-at-end-of-2023 Accessed May 1, 2022.
- American Board of Radiology Webinar https://www.theabr.org/blogs/authorized-user-eligibility-webinar-recording-and-faqs-available Accessed May 8, 2022.