RADPHYS NETWORK BUILDING · US NATIONWIDE
Compliance · Robbie Hakeem, DABR, DABMP

Do you need a QMP on-site? Remote supervision and what your state requires.

It's the question that decides your entire coverage model: does a Qualified Medical Physicist have to be physically in the building? The answer is neither "always" nor "never" — it's defined by rules, and those rules sit at three different levels. Here's how they line up.

The federal baseline is more permissive than most assume

Medicare's supervision framework has moved steadily away from requiring physical presence. General supervision — the physician furnishing overall direction and control without being present during the procedure — has been the standard for hospital outpatient therapeutic services for years. And as of 2026, CMS has made virtual direct supervision permanent: real-time audio-visual availability satisfies direct supervision for applicable services. Federally, "supervising" no longer means "standing there."

But radiation is governed by your state

Federal payment rules don't override your state's radiation-control program or your facility's license — and that's where the on-site question is actually answered. State requirements vary widely:

  • Licensure states. Several states — including Texas, New York, Florida, and Hawaii — license medical physicists. In those states a physicist must hold a state license to practice, remote or not, and it must match the state the facility is in — not the state the physicist lives in.
  • On-site rules. Some states or facility licenses require the QMP of record, or an authorized user, to be physically present for specific activities. Others permit general supervision with written protocols and periodic on-site oversight.
  • Everything in between. Machine QA, calibration, and commissioning are on-site by nature everywhere; the recurring clinical review often isn't.

The practical answer

For a large share of the recurring physics load — chart checks, second-checks, patient-specific QA, planning — remote or hybrid coverage is viable in many states. Machine QA and certain regulatory roles are on-site. What matters is that you scope the engagement to your state's radiation-control rules and your facility license, confirm licensure where the state requires it, and put in writing which role sits where. "We assumed the physicist was covering that" is exactly the ambiguity a surveyor is trained to find.

Why it pays to have a physicist read the rules

This is genuinely complex, it varies by state, and it changes. A firm that promises full remote coverage everywhere is not reading the regulations; a firm that insists everything must be on-site is quoting you the expensive option out of caution. The correct answer is specific to your state and your license — and it takes a physicist who works inside these rules to scope it right, and to say so plainly when a role has to be on the floor.

Not sure what your state actually requires?

Tell us the state and your facility setup, and we'll map which roles can be remote, which must be on-site, and where licensure applies — scoped to your rules, in writing.