Options Following a Failure or Deficiency: Mammography (Revised 10-01-26)
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Modified on: Thu, 1 Oct, 2026 at 2:58 PM
If a facility does not pass accreditation:
The ACR’s final report will provide specific recommendations for improvement.
If this is a unit’s first attempt, the facility should take corrective action on its own.
If this is a unit’s second attempt, the ACR must notify the FDA of its failure. In these cases, the facility must submit documentation of corrective action in order to reinstate.
Facilities may appeal any denial of accreditation and/or submit supplemental information, if applicable.
After a failed outcome, the facility has the opportunity to submit an option form to proceed with accreditation through the following options:
Appeal
Supplemental Review
Repeat
Reinstatement (with Corrective Action)
Withdrawal of the unit in question from the accreditation process entirely
To access your option form, go to “My Final Reports” and click “Select Option” under the option status column.

Option forms are due 15 days after the date they are sent. Please review your final report and options with your lead interpreting physician before completing your option form. Your final report link must be accessed by the lead interpreting physician or facility administrator before the option form is available.
Facility options after unsuccessful attempts at accreditation are outlined here:
Attempt | Accreditation Not Granted | Facility Options |
1st | 1st Deficiency: Facility may continue performing mammography with the unit as long as they have a valid certificate | REPEAT ‘not acceptable’ area(s) (only if more than 60 days on MQSA certificate)REINSTATE by retesting all areas (if 60 days or fewer on MQSA certificate)SUPPLEMENTAL REVIEWAPPEAL decision on original imagesWITHDRAW
|
2nd | 2nd Deficiency (= 1st failure): The ACR strongly recommends that the facility cease performing mammography with the unit | REINSTATE by retesting all areas (with corrective action)SUPPLEMENTAL REVIEWAPPEAL decision on original imagesWITHDRAW
|
3rd | 3rd Deficiency (= 2nd failure): The ACR strongly recommends that the facility cease performing mammography with the unit | REINSTATE after participating in scheduled on-site surveySUPPLEMENTAL REVIEWAPPEAL decision on original images (may not operate until appeal is complete)WITHDRAW
|
Repeats
If a facility has adequate time remaining on its MQSA certificate, it will be given the opportunity to repeat the test that was deficient. If there is not enough time to repeat the tests before the MQSA certificate expires, the facility will have to submit a corrective action plan and reinstate by completing and submitting the application, all testing materials and a reinstatement fee.
If a mammography unit is eligible to repeat, it will automatically be placed in a repeat cycle and submitted by the ACR when the deficiency report is issued. This will assist the facility in getting through the accreditation process in a timely matter. If your facility wants to submit supplemental information, appeal or withdraw from accreditation, you should contact the ACR for instructions. Repeat testing materials and payment are due within 20 days of the final report date. Go to ‘My Testing Packages’ and click 'modify' to access your repeat testing package .
If you are REPEATING a test for a deficiency, only submit images from the deficient test (i.e., all clinical images, both fatty and dense, and/or the phantom). Repeat exams are new exams not previously submitted for ACR review and should be collected after the date on the deficiency report. This allows reviewers to assess the overall improvement in image quality since the previous deficiency and to determine whether the facility took all reviewer comments into consideration.
If the site repeats (or reinstates) and receives a second deficiency, it fails accreditation. The ACR will notify the FDA (or the state certifying body) of this failure. In order to resume the accreditation process, the facility must reinstate.
Reinstatement
Reinstatement requires the facility to fully document its history and address all deficiencies noted in previous reports. An appropriate corrective action plan should be designed by the facility, approved by the ACR before implementation, then fully implemented, and documented to show proof of correction. The ACR may also direct the facility to make some specific corrective action. Once all corrective actions are completed and supporting documentation has been forwarded to the ACR, the facility may receive a 6-month provisional reinstatement certificate from the FDA (or state certifying body) and may go through the accreditation process again.
Corrective Action Plans
Submission of a Corrective Action Plan alone is not enough to obtain a provisional FDA certificate. Although the corrective action plan may discuss the problems the facility had in obtaining accreditation and what they plan to do to correct these deficiencies, these plans must be fully carried out and specifically documented to show proof of correction. That is the primary reason for reinstatement. If facilities were to be reinstated based on what they plan to do and without fully implementing the plan, their past problems might remain uncorrected. This could hinder their next testing cycle for accreditation and ultimately prevent them from obtaining accreditation.
In the event that a facility does not pass accreditation due to positioning:
The ACR typically requires 8 hours of hands-on training to be completed for corrective action. The positioning training documentation must be signed by the MQSA-qualified individual providing the training. If the training is performed at another site, the documentation must include that site's MAP#, address all the deficiencies noted in the previous reports, and include a statement that resultant images were critiqued and acceptable.
The ACR requires that all technologists at the facility receive training – not just the technologist who performed the submitted exam. The ACR specifies that you send your best quality work during accreditation; therefore, if your clinical images do not pass, the ACR must assume that all mammography performed at your facility, by all technologists, is of equal or lower quality. Proper patient positioning is crucial to obtaining consistently high-quality mammograms so that your patients receive the best medical care possible.
If the facility fails again, it will have to participate in a Scheduled On-Site Survey. The Scheduled On-Site Survey is conducted so that an ACR review team (consisting of a radiologist, a medical physicist and an ACR staff mammography technologist) can review the facility’s progress and provide on-site training in areas where help may be needed. This process takes time, and the facility is responsible for payment of a base site-visit fee in addition to all travel expenses incurred by the ACR team.
Supplemental Reviews
If you did not pass accreditation because you inadvertently omitted some information (images or data) from your accreditation submission and would like to have the same examination re-evaluated using supplemental information, you may request a supplemental review; however, you may not submit new cases. During accreditation review, the ACR reviewers assume that the submitted cases were reviewed by the lead interpreting physician and are examples of your best work. Consequently, during a supplemental review, only the original exam will be reviewed. If some images from the original exam were not included, you may be able to submit those images. A supplemental review letter must be uploaded at the time of the supplemental review option selection. A testing packet will be generated allowing your site to edit the data form and/or upload additional images. If uploading additional images, do not re-upload the entire exam.
Appeals
Appeals are typically made due to disagreement with the assessment of image quality based on the submitted images. Facilities that disagree with a deficiency or failure may appeal the determination within 15 days of the final report. An appeal letter must be uploaded at the time of the appeal option selection describing the reasons your lead interpreting physician disagrees with the final outcome.
Images will be forwarded to an arbitrator (a reviewer who did not participate in the initial review) with the originally submitted images, previous reviews and the appeal letter written by the facility. No new images or data will be sent to the reviewer for consideration in the evaluation. The arbitrator’s determination will be final.
If a unit is denied accreditation after an appeal of a failure (second deficiency), the facility has the right to appeal directly to the FDA. However, such an appeal will stop the ACR application process until the FDA renders a decision. Further, the facility making the appeal may not perform mammography during the FDA appeal process. Facilities are not permitted to appeal to the FDA after a first deficiency appeal is denied by the ACR.
You should receive the appeal and/or supplemental results within 30-45 days of the date all required materials were received by the ACR.
If the appeal or supplemental review outcome following the first deficiency is a fail, you may choose to repeat or withdraw the unit in question from accreditation.
Withdrawal of Failed Unit
A failed unit may be withdrawn if the site no longer performs mammography on that unit.
If you are withdrawing your only unit from the accreditation process entirely, the system will prompt you to complete a Facility Closure Memorandum.
Revision History for this Article |
Date | Section | Description of Revision(s) |
12-12-19 | All | Article created; FAQs incorporated; No criteria changes |
2-26-2024 | Mailing address | Updated ACR mailing address from 1891 to 1892 |
| 10-01-26 | All | Added information about supplemental reviews; removed references to film submissions |
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