[Histonet] CAP question on grossing

Lance Erickson Lance.Erickson <@t> ihc.com
Thu Oct 27 08:28:15 CDT 2005

See the new federal register CLIA intrepretive guidelines appendix C
subpart M that are effective April 24, 2003. At
www.cms.hhs.gov/clia/apcsubm.pdf under qualifications of high complexity
testing personnel section 493.1489 (b)(7) it is clear that all tissue
gross examination whether it is color, measurement, or advanced
dissection is considered high complexity testing and individuals
performing this type of testing must qualify under this section. That is
why the new CAP question ANP 11610 was instated and is effective April
28, 2005. CAP must abide by CLIA regulations and CLIA is part of the
Center for Medicare and Medicaid Services which is a section of the US
government's department of Health and Human Services. So if you would
like to maintain your CLIA license and CAP certification and be paid by
Medicare you must abide by the requirements for high complexity testing
personnel for each person performing any kind of gross examination.

Lance Erickson
Anatomic Pathology Supervisor
Primary Children's Medical Center
Salt Lake City, UT

-----Original Message-----
From: histonet-bounces <@t> lists.utsouthwestern.edu
[mailto:histonet-bounces <@t> lists.utsouthwestern.edu] On Behalf Of Luck,
Greg D.
Sent: Wednesday, October 26, 2005 3:35 PM
To: 'Charles.Embrey'; Jesus Ellin
Cc: Histonet <@t> pathology.swmed.edu
Subject: RE: [Histonet] CAP question on grossing

Charles (et.al.),

Where "specifically" is it stated in any regulations (e.g. CLIA '88,
CAP, Federal Register or other source) that "tissue grossing" is defined
as high complexity testing?  Thanks, Greg

Greg Luck, BS, HT(ASCP)
Anatomic Pathology Supervisor
Deaconess Medical Center
800 W. 5th Ave
Spokane, WA 99204
Phone 509.473.7077
Fax 509.473.7133
luckg <@t> empirehealth.org

-----Original Message-----
From: Charles.Embrey [mailto:Charles.Embrey <@t> carle.com]
Sent: Wednesday, October 26, 2005 7:49 AM
To: Jesus Ellin
Cc: Histonet <@t> pathology.swmed.edu
Subject: RE: [Histonet] CAP question on grossing

CAP and CLIA have never made a separation in "transference" from
Ever CLIA statement I have ever read on the subject states that grossing
any tissue is high complexity testing.  "Transference" is not even
recognized in the CAP checklist.  I routinely assist on CAP inspections
and I would love to see a lab try to sell me on "transference".  Of
course it is only a Phase II write up but if the problem is not
documented as corrected the lab can lose its accreditation. Liability
and appropriate pay are other considerations I personally have mentioned
in other e-mails but have been flamed for.  My personal feeling is that
if someone wants to undervalue their talent and work that is up to them.
As long as labs can get techs to do part of the pathologists job for
about a tenth of the pathologist's salary, those people will be prayed

Charles Embrey, PA(ASCP)   

-----Original Message-----
From: Jesus Ellin [mailto:JEllin <@t> yumaregional.org]
Sent: Tuesday, October 25, 2005 7:36 PM
To: Charles.Embrey
Subject: RE: [Histonet] CAP question on grossing

What about transference, our pathologist's are saying that small bx's or
anything that does not require cutting or manipulation falls under this
category. They are saying any registered or registry eligable can do
this portion of the gross.  What needs to happen is have stated black in
white what techs can or can not do.  This not only puts a lot of
liability on the tech, it also is having tech do a PA or pathologist job
at a techs wage, which is not right at all.  Were can someone find out
what the scale is for grossing tech's?  I know it depends on the
institution, but there has to be some sort of support for this other
than requirements that CLIA and CAP set forth.  Also what other than a
phase two what can also happen if a facility is caught doing this.??

Jesus Ellin
Yuma Regional Medical Center

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