Provider Approval for Training of an Unlicensed Person Performing Radiography of the Foot

New York State Education Department Approval as a Provider of Training of an Unlicensed Person Performing Radiography of the Foot

(In accordance with Commissioner's Regulations effective October 7, 2004)


This section explains the requirements for becoming an approved provider for training unlicensed persons to perform radiography of the foot in New York State. Once you have read the "Standards" below, please complete the Application for Approval of a Podiatry Radiography Course for Unlicensed Individuals (PDF 20 KB) and send it to the address at the end of the application form along with the supporting materials requested. You must also enclose a check payable to the "NYS Education Department" in the amount of $500. Approval may be granted for a six-year period and may be renewed upon further application (including fee). Providers are required to keep records for the programs they offer and for the individuals successfully completing the course of study. Details concerning the record keeping requirements are included in the "Records" section of the application.

Providers must comply with the applicable requirements of Section 65.7 of the Commissioner's Regulations to obtain State Education Department approval as a provider. Providers are expected to meet or exceed the standards detailed in the application.

If you have questions concerning the requirements, please contact the State Board for Podiatry at podbd@nysed.gov or by telephone at 518-474-3817 ext. 180.

Standard 1 - Organization | Standard 2 - Candidate Application/Admission Requirements | Standard 3 - Course of Study | Standard 4 - Assessment of Learning | Standard 5 - Instructors | Standard 6 - Facilities and Equipment | Standard 7 - Resources | Standard 8 - Records

Standard 1 - Organization

Provider is an approved organization.

Section 65.7(c)(1) of the Regulations of the Commissioner of Education requires sponsors of approved programs to be:

  1. a degree-granting institution that offers programs in the health professions;
  2. a hospital or health facility regulated by Article 28 of the Public Health Law;
  3. a professional association representing the health professions; or
  4. an entity that provides education or training on health care subjects to health professionals.

Standard 2 - Candidate Application/Admission Requirements

Application is complete and submitted.

Section 65.7(c)(2) of the Regulations of the Commissioner of Education requires a formal written application used to admit candidates to the course of study meet the following requirements: be at least 18 years old, have a high school diploma or equivalent, and verification/attestation that the candidate is of good moral character.

In addition, a copy of the organization's refund and cancellation policies must be included.


Standard 3 - Course of Study

Appropriate course work is offered.

Section 65.7(c)(3) of the Regulations of the Commissioner of Education requires that a copy of the proposed curriculum that meets the following requirements be submitted:

  1. includes at least 8 hours of in-person instruction;
  2. includes the following content areas: basic radiation safety for patient and operator, infection control techniques, patient positioning, and production and development of radiographs;
  3. includes appropriate use of radiographic equipment, approved by the New York State Department of Health, under the direct supervision of a licensed podiatrist. The course shall require the candidate to train on and operate radiographic equipment on nonhuman models under the direct in-person observation and supervision of a licensed podiatrist.

Section 65.7(c)(3)(v) of the Regulations of the Commissioner of Education requires that a provider applicant submit a detailed curriculum in written form, which describes learning objectives and competencies achieved by the course of study.


Standard 4 - Assessment of Learning

Written and practical examinations will be offered.

Section 65.7(c)(3)(iv) of the Regulations of the Commissioner of Education requires that candidates demonstrate competency in the operation of radiographic equipment for the purpose of foot radiography through successful completion of a practical examination using such equipment on nonhuman models and a written examination. A description of the method to be used to assess competency in the operation of radiographic equipment and a copy of the written examination to be used to assess competency must be provided.


Standard 5 - Instructors

Course instructors are qualified to teach the course.

Section 65.7(c)(4) of the Regulations of the Commissioner of Education requires the course to be taught by instructors who have demonstrated by training, education, and experience their competence to teach the course content prescribed.

Providers must assure that instructors meet this standard and must:

  1. maintain and use written criteria and procedures to select instructors, including job descriptions, intended to assure that every instructor is qualified by training and/or experience to teach the course; and
  2. maintain and use written procedures to evaluate instructors' performance. Both attendees' written evaluations and assessments by course monitors may appropriately be part of the evaluation of instructors' performance.

Standard 6 - Facilities and Equipment

Adequate facilities and equipment are provided.

Section 65.7(c)(3)(5) of the Regulations of the Commissioner of Education requires providers to provide adequate facilities, equipment, and other physical resources, including but not limited to, the type of radiographic equipment approved by the Department of Health for use by unlicensed persons while under the direct supervision of a licensed podiatrist. The provider must conform to all applicable statutes, rules and regulations relating to radiation safety standards.


Standard 7 - Resources

A provider must demonstrate fiscal capacity to offer the course.

A provider applicant shall submit a budget or statement showing the capability of the organization to fund the costs of the course of study. In addition, information pertaining to the fee(s) charged to each participant and a copy of the organization's refund and cancellation policy must be submitted.


Standard 8 - Records

Providers will maintain records for at least six years from the date of completion of coursework and individuals successfully completing the course will be awarded a certificate of completion.

Section 65.7(d)(3) of the Regulations of the Commissioner of Education requires providers to provide a certificate of completion to individuals successfully completing the course of study within 21 calendar days of completion of the course. The provider must also submit a policy and procedure to assure storage, confidentiality, and retrieval of records for a six-year period. At minimum, the following information must be maintained for each course:

  1. The date(s) and time(s) of the course.
  2. A copy of the certificate of completion for each participant who successfully completed the course of study.
  3. The written application of each participant admitted.
  4. The written curriculum.
  5. Resumé of the instructor(s).
  6. Results of both the written and practical exam for each participant.
  7. The attendance records.

In addition, the provider applicant must attach a signed assurance that:

  1. The records will be maintained at an address specified for six (6) years from the date each course was offered and made available for review by the State Education Department.
  2. A provider will notify the New York State Podiatry Board Office in advance of any change in street address where the records will be maintained.
  3. The provider will respond to any inquiry by the Department regarding those records.
  4. In the event that the provider discontinues offering the course of study, all records shall be transferred to the Department.

Inquiries can be addressed to:

New York State Education Department
State Board for Podiatry
89 Washington Avenue
Albany, NY 12234-1000
Phone: 518-474-3817 ext. 180
E-mail: podbd@nysed.gov

Last Updated: June 11, 2009