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Issue Background

California Opposes AB387

The California Society of Radiologic Technologists is planning a town hall meeting to discuss the issue with state lawmakers. More information will be posted here when available.

California R.T.s Oppose Minimum Wages for Students

The California Society of Radiologic Technologists opposes the enactment of Assembly Bill 387 and urges all California R.T.s to contact their state lawmakers to voice their opposition to this bill. Assembly Bill 387 would require health care entities to pay allied health students minimum wage for time spent in clinical or experiential training that is required for state licensure. AB 387 fails to recognize that for patient care-related training programs, myriad state and federal laws prohibit students from providing unsupervised care. Because they are in training, these students are not lawfully permitted to deliver care except within strict supervision requirements. They are not employees, and the cost of treating them as such could have the adverse consequence of reducing students’ opportunities to benefit from hospital-provided training and clinical experience, as well as exacerbating workforce shortages.

Specific to the radiologic technology programs, the following compelling reasons should be considered:

1. Hospitals/clinical affiliations may not agree to take the burden of paying students and they could disaffiliate from the educational programs, causing the potential for educational programs to close, creating the reverse effect intended by this bill.

2. Hospital contracts with educational programs may have to be modified to include workers’ compensation and other protection for students which could result in higher cost for the hospitals, patients, programs and students.

3. If students get paid, student and employee responsibilities may be confused,  resulting in the potential for significant patient safety issues for health care facilities.

4. This bill may violate the spirit of the Joint Review Committee on Education in Radiologic Technology (JRCERT) accreditation standards for radiologic technology programs. Specifically, standard 1.2 mandates programs provide equitable learning opportunities for all students, and standard 1.3 mandates programs provide timely, appropriate, and educationally valid clinical experiences for each admitted student. Providing students with a minimum wage could be considered inconsistent with JRCERT accreditation policies and standards. Students receiving wages in relation to clinical hours may be construed by the JRCERT as employees of the institution. This situation has the potential for students to be utilized in lieu of qualified staff, creating liability issues for both the students and the employers, while jeopardizing the quality of patient care.

CSRT opposes AB 387 because it could result in a significant decrease in our ability to partner with local health employers to train the allied health workforce needed to provide care for California’s patients now and in the future. The effects of this significant decrease in capacity within the current training system could exacerbate existing allied health care workforce shortages and put the development of a strong and diverse pipeline of future caregivers in jeopardy.