Texas X-Ray Technologists Must Prove Legal Status to Renew Licenses in February

Thousands of Texans who run X-ray, CT and mammography machines will have to hand the state proof that they are United States citizens or lawfully in the country before they can renew their licenses in February. As of mid-September, by the agency’s own count, about a third of them had.

Roughly 7,500 radiologic technologists come up for renewal in that February batch, Chris Palazola, Deputy Executive Director of the Texas Medical Board, told the board that licenses them Sept. 18. About 3,500 had opened an account with the continuing-education service the state now also requires — the second of two conditions that could stop a renewal. About 32 percent had uploaded their citizenship or immigration paperwork. That was reasonable progress, he said, because “we still have about 5 months to go.”

Miss either one and the renewal does not happen. These permits expire Feb. 28 and, in the board’s words, there is “no grace period” for the expiration date. A technologist may not work on a lapsed registration, a penalty of half the fee attaches at once and doubles after 90 days, and the license is cancelled outright a year on. The board’s instruction to licensees without the documents is flat: “you will not be able to renew your license.”

What is unusual about the citizenship requirement is how it arrived. No Texas statute imposes it. The board rests it on a line of federal welfare law barring people without lawful immigration status from receiving a public benefit (8 U.S.C. §1621), which state agencies began reading to cover occupational licenses this year, after Attorney General Ken Paxton withdrew a 2001 opinion that had let them take an applicant’s word.

Four sister agencies — the state licensing department and the nursing, dental and behavioral health boards — wrote the requirement into their rulebooks, which obliged them to publish it and take public comment first. The medical board appears to have imposed it administratively, which means there was never a docket here for anyone to object into.

Where there was a docket, people filed. The licensing department’s version drew 468 comments, overwhelmingly against, from LULAC, Hispanic chambers of commerce and the Texas House Democratic Caucus; the agency adopted it unchanged. Sen. Sarah Eckhardt, an Austin State Senator, wrote in February 2026 that the federal provision is “permissive rather than mandatory” and that the agency had discretion it declined to use. She was writing about that department’s rule, not this board’s. On the other side, the Texas Dental Association told its own board the requirement was appropriate.

The second condition is a 2025 state law, Senate Bill 912, which told health licensing agencies to route continuing education through a tracking system. The medical board chose the commercial service CE Broker and tells licensees they must open an account and log their hours there or nothing moves.

“We call that a hard stop, meaning we cannot process a renewal for a licensee unless they have met that requirement.”

Palazola told the board the law required the service to be free to the agency and to licensees alike, and that “there’s really only one bidder that could meet that requirement.” The statute says less. It bars a tracking system from costing the licensing agency anything and is silent on what it may cost a licensee. Nor is the vendor the only way to comply: the Texas Board of Nursing satisfied the same law by building its own portal. The Dispatch could find no procurement record at the medical board — no solicitation, no bid, no sole-source finding, no contract. The agency and CE Broker announced their arrangement in April 2024, more than a year before the bill passed, and a company representative testified for the bill in April 2025.

The citizenship paperwork runs through a document-upload tool the board built. Palazola said people understood the requirement and were meeting it, then conceded its limits: “It was put together very quickly. It’s not perfect, but… it is working”. Review on the far end is done by hand, and the board asks licensees to allow at least three weeks. The strain is already in its books. The agency told budget writers this year that lawful-presence checks helped push call volume up 29 percent — about 34,000 extra calls — and answered a little over half. Licenses that expired May 31 and had not been renewed were quietly extended a month.

Nobody speaking for radiologic technologists has said anything on the record about either requirement. Online renewal opens 60 to 90 days ahead of the deadline — around December for the first group of technologists to meet both hard stops at once.