image of caduceus
Hardship Exemptions

Senate Bill 674 (2017) amended the statutory requirements for practitioners seeking a hardship exemption.  Applicants seeking an exemption under Section 601.203(b)(1) of the Texas Occupations Code, claiming the inability to attract or retain a MRT, LMRT or NCT, must now be located in a Texas county with a population of 50,000 or less.   

Applicants applying for any hardship exemption under Section 601.203(b) will be required to submit sufficient documentation demonstrating the hardship, as determined by the Board. If you currently have an active hardship exemption that was issued prior to September 1, 2017, and will no longer qualify under the statutory and rule changes, you will be allowed to renew your hardship one additional time under the previous exemptions. Upon expiration of the final hardship exemption individuals who are not appropriately trained as a MRT, LMRT or NCT will no longer be allowed to perform radiologic procedures.  Information about available training programs and the requirements for certification as a MRT, LMRT or NCT can be found on this website.


  • A hospital, federally qualified health center (FQHC) or practitioner may apply for a hardship exemption from employing an MRT, LMRT, or NCT.
  • The applicant must demonstrate a hardship in employing an MRT, LMRT, or NCT, as described in Texas Administrative Code Title 25, Part 1, Chapter 194, Subchapter A, Rule 194.16.
  • The hardship exemption applicant shall not allow a person who is not an MRT, LMRT, or NCT to perform a radiologic procedure until a hardship exemption is granted.
  • The hospital, FQHC, or a practitioner must reapply annually for the exemption and meet the then current requirements for a hardship exemption. Please note that a hospital, FQHC, or a practitioner who does not reapply for an exemption shall not allow a person to perform a radiologic procedure unless the person is a practitioner, MRT, LMRT, or NCT.
  • No more than seven individuals will be allowed to perform radiologic procedures under the hardship exemption, if granted. Fingerprinting and criminal background checks are required by statute (Senate Bill 202) for all persons performing radiologic procedures in the State, including those that are performing the procedures under a Hardship Exemption.  Instructions on the fingerprint process can be found under the Fingerprints tab below.  Criminal history will be taken into consideration as part of the approval process and could potentially result in denial of the request for a Hardship Exemption.  

Hardship Exemption Application

Please note that at this time the Hardship Exemption application is available in hard copy only.


Communication with the Board

Additional information and supplemental forms may be submitted using the US Postal Service or a private overnight delivery service. Board staff will communicate with applicants by e-mail, if an address is provided, or by letter using the US Postal Service.

  • Application and Application-Related Fees


    Hardship Application Fee: The current fee for a Hardship Exemption in Texas is $30.00. The entire fee must be submitted before your application can be assigned and processed.

    The registry application fee includes a $5 Office of Patient Protection fee. This fee is required by statute. The remaining $25 is the fee required by the TMB.



    Hardship Exemption





    Hard copy application

    Application Type

    Agency Fee


    Total charged

    Hardship Exemption  – Application Fee

    $                   25.00

    $       5.00

    $               30.00

    A list of current hardship exemptions are provided in the spreadsheet below.

    TMB Hardship Exemption Approvals



    Physicians, Physician Assistants, and several other types of licensure applicants are required to submit their fingerprints for state and national criminal history background checks. 

    Please note that having a criminal history does not automatically disqualify you from obtaining a license through the Texas Medical Board. For additional information please review the Texas State Auditor’s Guide to Applying for an Occupational License After Conviction or Deferred Adjudication.

    Fingerprinting services are provided through IdentoGo by IDEMIA (formerly known as MorphoTrust USA, LLC) for a fee (see the Fingerprinting FAQs below for the current fees), payable directly to IdentoGo. Results of the fingerprinting will be sent directly to TMB from both the Texas Department of Public Safety Criminal Records and the Federal Bureau of Investigation.

    Please be advised that taking a photo is part of the fingerprinting process and a requirement.  The Department of Public Safety has requested that IdentoGo maintain a 6’ distance when possible and prior to starting the appointment and that they inform the applicant it will be necessary to remove their mask for a photo.  If you choose not to remove your mask, the appointment may not proceed and you will be asked to reschedule your appointment for a later date.


    Please note – applicants for initial licensure should not submit fingerprints for review until after they have submitted the online application. Additionally, fingerprint cards should not be mailed to the TMB.

    Specific instructions for fingerprinting will be provided through the LIST message system for Physician licensure applicants and by email for the following applicants:


    •          Physician Faculty Temporary License (FTL)
    •          Physician Assistant
    •          Acupuncturist
    •          Acudetox
    •          Surgical Assistant
    •          Provisional License
    •          Medical Radiologic Technologist
    •          Limited Radiologic Technologist
    •          Respiratory Care Practitioner
    •          Non-Certified Radiological Technician
    •          Medical Physicist
    •          Perfusionist
    •          Criminal History Evaluation applicants

    Fingerprinting FAQs