Proposed Radiography Rules Could Upend Urgent Care Bottom Lines, Staff Models in NC

December 30, 2025

North Carolina regulators are moving to ban medical assistants (MAs) from x-ray duties, instead proposing that the service should only be delivered by radiologic technologists (RTs) with physician presence.

For decades, North Carolina has operated under a flexible regulatory framework that allowed urgent cares to determine the competence of their x-ray operators. On-the-job training for basic radiographic services—such as chest and extremity x-rays under the supervision of a physician or advanced practice provider—is permitted currently. The new proposed rules directly dismantle this model by mandating that all operators must be fully credentialed RTs.

For urgent care operators, this could limit the availability of x-ray services because of RT shortages, while at the same time increasing costs once MAs can no longer perform the service. Concurrently, State Senate Bill 415 and House Bill 590 aim to establish a “Medical Imaging and Radiation Therapy Board of Examiners” and statutorily create a “Limited Practice Radiographer” license. This legislative approach offers a potential compromise. It creates a legal version of the current on-the-job training model and validates a limited-scope exam, which would allow MAs who pass a specific exam (chest/extremity) to continue to deliver these specified x-ray services legally.

It’s important to note that North Carolina is 1 of only 4 states that currently do not require state licensure or specific credentials for x-ray operators. Observers believe that by mandating the highest level of operator credentialing and rejecting the “limited scope” solution, the policy will destabilize urgent cares throughout the state.

Pathway to a solution: “This threatens staffing models,” says Alan A. Ayers, MBA, MAcc, President of Urgent Care Consultants and Senior Editor of JUCM. “Urgent care operators statewide must join with others in lobbying for SB 415 and HB 590 to create a ‘limited scope’ license, providing a compliant pathway for their existing teams.”

Source: Journal of Urgent Care Medicine