Does an ultrasound business need a medical director, an ordering clinician and an interpreting physician?

Medically reviewed by Sina Haeri, MD, MHSA, maternal-fetal medicine physician, on September 20, 2026.

Published September 20, 2026

A diagnostic ultrasound needs two people besides the sonographer: an ordering clinician, who is treating the patient and will act on the result, and an interpreting physician, who reads the study and signs the report. A medical director is a separate role. Whether you need one depends on your state’s rules, the payers you bill and whether you pursue accreditation.

The ordering clinician

The ordering clinician is the physician, nurse practitioner, physician assistant or certified nurse-midwife who is treating the patient, within what state law lets each of them order. They decide the scan is needed, receive the report and manage what it shows. Medicare requires that a diagnostic test be ordered by the treating practitioner, and other payers generally follow the same logic. Someone who never sees the patient can’t fill this role.

The interpreting physician

The interpreting physician reads the images and signs the final report. AIUM’s training guidelines describe who qualifies: a licensed physician with board certification in a field such as radiology or obstetrics and gynecology, or subspecialty certification such as maternal-fetal medicine, along with case volume. The physician generally needs a license in the state where the patient is scanned. This is the role a remote reading service fills.

The medical director, and when one is required

“Medical director” means different things in different rulebooks, which is where most of the confusion starts.

Accreditation. AIUM requires an accredited practice to designate a Director of Ultrasound: a licensed medical provider who meets AIUM’s training guidelines and oversees the quality and appropriateness of the practice’s ultrasound work. Accreditation is voluntary, though some payers require it.

Medicare. A provider enrolled as an independent diagnostic testing facility, fixed or mobile, must have one or more supervising physicians. Each can give general supervision to no more than three sites, and a supervising physician can’t order the tests unless they’re also treating the patient.

State facility rules. Some states license clinics or imaging providers and make a director a condition of the license. Florida is one example. There, an entity that bills third-party payers, including a mobile clinic or a portable equipment provider, generally needs a health care clinic license, and a licensed clinic must have a medical or clinic director. Practices wholly owned by licensed practitioners are among the exemptions.

Ownership. Many states also restrict who can own a business that provides medical services or contracts with physicians. That question belongs with a healthcare attorney in your state.

If you’re cash-pay, unaccredited and in a state with no facility license for what you do, you may not need a medical director at all. You still need an ordering clinician and an interpreting physician.

Can one person hold more than one role?

Sometimes. A physician who treats the patient can order the study and, if qualified, interpret it. A contracted reading physician in another state usually can’t be the ordering clinician, because they aren’t treating the patient. A medical director isn’t automatically the interpreting physician either, so ask each person which role they’re taking on.

Where Ouma fits

Ouma fills the interpreting role: board-certified maternal-fetal medicine physicians read each study and sign the report, and we ask that every diagnostic study carry an order from a licensed clinician who will manage the result. Ouma doesn’t act as the ordering clinician or as a practice’s medical director. Ouma is licensed to practice in all 50 states.

Related: OB ultrasound reads by MFM physicians · Adding diagnostic OB ultrasound to your practice · Who reads OB ultrasounds

Sources

• American Institute of Ultrasound in Medicine. Standards and Guidelines for the Accreditation of Ultrasound Practices. Reapproved April 20, 2026. aium.org
• American Institute of Ultrasound in Medicine. Training Guidelines for Physicians Who Evaluate and Interpret Diagnostic Ultrasound Examinations. Revised November 17, 2025. aium.org
• 42 CFR 410.32 and 42 CFR 410.33. ecfr.gov
• Florida Statutes (2025), section 400.9905 (definitions and exemptions) and section 400.9935(1) (medical or clinic director). 400.9905, 400.9935

General information, not legal advice. Rules differ by state and by payer.