2022-07-11 18:00:07 - 16

Professional Defense to strengthen the work of the radiologist

CBR Department represents the expert and expertise in legislative, judicial and executive matters. Get to know a little more about this trajectory of dialogues and institutional relationships that aim to strengthen the work of the radiologist

By Marcelo Balbino

Strengthen the sector and defend the interests and activities of radiologists. With this motto walks the Department of Professional Defense of the CBR. Quite a task at such a delicate time, with global challenges such as the Covid-19 pandemic, for example. To give you an idea, in July 2020 the magazine Radiology (Sharper Jr RE) showed a significant decrease, from 40% to 90%, in the volume of work in the USA. In Brazil, studies calculate an index that achieved a reduction of around 70% in laboratory and clinical care.

defesa profissional CBR

If, on the one hand, the news causes some dismay, on the other hand, it signals a very clear path of union, protagonism and strategic struggle around the work of the Radiology and Diagnostic Imaging professional. In this context and in the scenario of many other struggles, the CBR's Professional Defense department stands out.

Focused on political action, but non-partisan, professional defense has the role of strengthening not only the radiologist but also his profession, that is, the specialist and his specialty. In this way, the department represents both, acting in a diplomatic manner on legislative, judicial and executive issues, which also include regulatory bodies.

Dr. Juliana Tapajós, director of Professional Defense at CBR, says that the department works with the objective of promoting actions that can guarantee the full exercise of Radiology and Diagnostic Imaging. That is, it represents the defense of their legitimate rights in ethical and legal matters of professional practice, safeguarding their professional interests, with the purpose of guidance, awareness, issuing opinions, advice and fact-finding related to the professional practice of the specialty.

The importance of Professional Defense, according to Dr. Juliana, focuses mainly on demonstrating the fundamental role and recognition of the value of the specialty for early diagnosis, starting from the well-indicated, well-performed and correctly interpreted exam, representing the specialty in a positive way for all to see. The objective is to make patients, doctors and paying sources appreciate the fact that the Radiologist is an essential part of the clinical team, present and active. A professional who is truly participative and integrated with other specialties for quality and precision medicine.

“We are surrounded by challenges! We see, on a daily basis, other professionals, without the proper technical and scientific training and without the formal qualification by the competent bodies, trying to embark on Image Diagnosis”, signals Dr. Juliana. “The CBR, always attentive to this, has taken the appropriate legal measures, in all spheres, to combat the exercise of the profession, and of the specialty, without the due legal and curricular qualification to practice acts inherent to it. We vehemently defend the private attributions of the medical professional, duly set forth in the Law of the Medical Act 12.842/2013”.

Associates can learn more about and benefit from the program by accessing the CBR website, as well as checking publications on social media that publicize the main actions in the field of defense, commenting and sharing information with their work team. The associate reporting channel and the ethics channel are the recommended places to make your query or report directly to the Professional Defense department. In these instruments, there is a guarantee of secure and confidential communication, treated anonymously, confidentially and impartially. Such denunciations are extremely important for Defense actions, often serving as a substrate for questions before regulatory bodies, paying sources, government bodies and medical entities.

The birth of Professional Defense at CBR

CBR's concern with radiologists and their field of work led to the creation of the CBR Professional Defense Committee, initially coordinated by Dr. Cibele Alves de Carvalho (2019-2020 administration).

The group's first meeting took place in March 2019 and was followed by several strategic meetings with the aim of strengthening the fight of radiologists and the field of work of diagnostic imaging. One of them was held with federal deputy Dr. Zacharias Calil, in Brasilia, with the aim of making the ANS aware of the imbalance in the body's regulations and actions.

Subsequently, the 1st Professional Defense Forum was created, organized by the Radiology Society of Minas Gerais and supported by the CBR. The event dealt with relevant topics such as “Pejoização” and “Cooperative of specialties: an alternative for receiving fees with appreciation of fees?”.

Considered an event of great importance in the history of CBR, the 1st Professional Defense Forum sought to align and strengthen the segment by bringing together ten State Societies, around the challenges in the work of the radiologist, unifying the needs of the profession. On the occasion, the then president of the CBR, Dr. Alair Sarmet Santos (2019-2020), declared that the event was a milestone for the College, in the sense of reinforcing a closer relationship between the presidents of state societies and the board. 

Developed activities

Among the services offered, Dr. Juliana comments that the Professional Defense Commission (2021-2022) has monthly meetings for planning and monitoring actions and currently has representation in practically all regions of the country. The team consists of Cibele Carvalho (MG), Álvaro Campos (PE), Sergio Andrade (MG), Hélio Braga (BA), Carlos Moura (SP), Arthur Vieira (PR), Luís Gasparini (SP), Robson Tadachi ( PA), in addition to Economic and Legal Advice specializing in Radiology and Diagnostic Imaging to act and signal possibilities and alternatives in the face of the numerous challenges of the medical profession.

The work of Professional Defense is wide and involves participation in all medical movements in a joint work mainly with AMB and CFM. Among the activities carried out are:

- Participation in Professional Defense Meetings (AMB)
- Participation in CBHPM Technical Chamber Meetings (AMB)
- Inclusion of new procedures in CBHPM
- Participation in the Technical Chamber of Radiology and Diagnostic Imaging at CFM
- Participation in ANS Committees
- Discussion and Requests for revisions of Normative Resolutions ANS - RN 365, RN 510, RN 512 and TISS standard
- Expansion of ANS NOR coverage
- Maintenance of TUSS tables
- Participation in meetings at ANVISA
- Participation in professional defense discussion forums with other Specialty Societies, CFM, Ministry of Health
- Discussion of strategies for the defense of Medicine in the political sphere, Parliamentary and Economic advice
- Defense of Radiology and Diagnostic Imaging before other specialties
- Publications in the Main Media of CBR
- Report card, workplace and Instagram
- Topics: Technical Responsibility; Eqr; Dynamics of the ANS CBHPM, TUSS and NOR Tables; Communication of Results; Professional Defense Movement of Radiologists of Pernambuco – a success story; Differences between Graduate and Medical Residency
- Management of Associate Consultations and Issuance of Technical Opinions
- Reports to CRMs based on reports from associates
- Participation in the meetings of the Ultrasound, Mammography and CT/RM Committees of the CBR for common guidelines
- Clinic Management Course

recent achievements

Among the recent achievements of the Commission is the victory, obtained in 2021, in a Collective Writ of Mandamus filed in previous years that discussed the calculation basis for the payment of PIS and COFINS on the importation of medical equipment. As a result of this triumph, it was possible for Radiology and Diagnostic Imaging clinics to recover the amounts paid in excess, around 3% of the value of each imported equipment, corrected by the Selic rate.

Also recently, new techniques/inclusions of procedures were incorporated into the CBHPM, based on the relevance of its role in promoting the population's health, with a view to reducing costs and increasing the effectiveness of care. In this sense, the inclusion of new procedures has been one of the main flags in the Professional Defense area, especially since the procedures recently included in the 2021/2022 management, with the due pricing requested by the CBR:

Inclusion of Procedures

AMB TECHNICAL CHAMBER - CNHM No. 055/2021 of 10/18/2021

CodeTermsize US - Dynamic sonographic study
urinary tract (male)
4C postage - Dynamic sonographic study
urinary tract (female)
4C postage USUS - Additional 3D reconstructionSize 3B neurosonography, per fetusSize 4A - Cisternography4C postage – Iron assessment (heart or liver),
by organ
Size 3C - TractographySize 4A diffusionSize 3B - PlanningSize 3C – NeuronavigatorSize 3B


CodeTermsize 0PET-CT review by procedure6C 0Review of Mammography by procedure2C 0Review of Bone Densitometry by procedure2C 0X-ray review by procedure1B 0Review of Computed Tomography by procedure3B 0Magnetic Resonance Review by procedure3C
CodeTermsize 0PET-CT Progressive Report per procedure6C 0Evolutionary Report of Mammography by procedure2C 0Evolutionary Report of Bone Densitometry per procedure 2C 0Evolutionary X-ray report per procedure1B 0Evolutionary report of Ultrasound per procedure3A 0Evolutionary Report of Computed Tomography by procedure3B 0Evolutionary Report of Magnetic Resonance by procedure3C

In addition to the inclusion of procedures, on 02/03/2022 an important meeting was held with ANVISA, on the regulatory framework for Radiology RDC 330, now revoked by RDC 611, in order to safeguard the correct observation of the Radiologist as Technical Responsible in the services of Diagnostic Imaging.

At the time, the sometimes controversial position of some VISAS not applying the norm as recommended was discussed with ANVISA, failing to register the presence of the technician responsible for radiology, duly registered in the CRM.

As a referral, a Virtual Training plan was defined with an inspection script, as well as the intensification of periodic meetings with the local VISAS for the correct inspection of Diagnostic Imaging services. The mandatory presence of a Radiologist as Technical Manager of the Specialized Service was reinforced, as well as support to mobilize all bodies involved in health inspection, through technical notes N0. 35/2020/SEI/GRECS/DIRE1/ANVISA and N0 243/2021/SEI/GRECS/DIRE1/ANVISA.

Another important point, according to Dr. Juliana, is the intense participation of the Defense Commission in periodic meetings with the ANS for the Maintenance of Laws and Regulations such as the revision of RN 365/2014 on Disaccreditation and Replacement of Services; Supervision of the Adoption of the TISS Standard; Mandatory provision of webservice for authorization for all providers; Mandatory availability of XML statements for all providers, among other issues of extreme relevance to the specialty and medical practice.

To learn more about the work of the CBR Department of Professional Defense, visit this link.

* Article published in issue 400 of the CBR Bulletin, in June 2022