[Histonet] ?New CAP guidelines affect CLIA '88

Morken, Tim Timothy.Morken <@t> ucsfmedctr.org
Tue Apr 27 11:52:10 CDT 2010


Carol wrote: "Will the new CAP guidelines related to "processing" and "grossing" affect CLIA regulations? "

What CAP requires does not "affect CLIA regulations;" it is the other way around. It may be that CAP is simply fine tuning its requirements to better reflect the CLIA regulations.

CAP is a deemed agent by CMS (Centers for Medicare and Medicaid) the Federal agency that implements the CLIA rules. The Joint Commission is another deemed agent. As such they apply and are chosen to enforce the CLIA rules. As deemed agents CAP and JC must enforce the rules, but have some leeway in how they go about it and may emphasize different aspects.+ Certainly CMS has to approve how CAP/JC does that. But what CAP does will not necessarily affect how JC goes about the same task. 

My experience with all three (CAP, JC and federal CLIA inspections) are that CAP emphasizes the technical aspects and secondarily the QA aspects while JC and CLIA emphasize the QA aspects, especially over the entire organization (for instance JC does "tracers" in which they pull all the information about a given patient and follow every path to the ultimate QA documents of every test on that patient - down to who stained the slides and are their competency documents in order).

Tim Morken
Supervisor, Histology / IPOX
UCSF Medical Center
San Francisco, CA  
 
-----Original Message-----
From: histonet-bounces <@t> lists.utsouthwestern.edu [mailto:histonet-bounces <@t> lists.utsouthwestern.edu] On Behalf Of DELIA GARCIA
Sent: Tuesday, April 27, 2010 8:34 AM
To: histonet <@t> lists.utsouthwestern.edu; CarolBarone
Subject: Re: [Histonet] ?New CAP guidelines affect CLIA '88

I too am curious about this issue. Any info would be oh so greatly appreciated.
 
Thanks

--- On Tue, 4/27/10, Barone, Carol <cbarone <@t> NEMOURS.ORG> wrote:


From: Barone, Carol <cbarone <@t> NEMOURS.ORG>
Subject: [Histonet] ?New CAP guidelines affect CLIA '88
To: histonet <@t> lists.utsouthwestern.edu
Date: Tuesday, April 27, 2010, 8:20 AM


Histonetters familiar with CAP and CLIA compliance issue...I am
requesting a clarification:
Will the new CAP guidelines related to "processing" and "grossing"
affect CLIA regulations? I understand they will certainly affect CAP
labs....but do they impact CLIA labs as well? Is there any
grandfathering for experienced technicians who have been doing this for
years (I have 2 techs who "gross" muscle only... on tissue for enzyme
histochemistry -  prior to snap-freezing)......? How does this, if it
does, impact technicians recognized under CLIA as "individuals who
perform high complexity testing..." I know there will be  change for
CAP...will CLIA be following?
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