[Histonet] salary for lab assistants

Mon Jun 26 12:28:28 CDT 2006

Well,
    I have to agree that this stinks.  Either gross tissue examination is
high complexity testing or it is not.  This is just creating confusion.  How
are you to know when you inspect a lab whether the person doing gross is
always just transferring the specimen and never bisecting that larger polyp
or cervical bx?  Or does this mean as long as the entire specimen is
submitted, then it OK not to have the qualifications?  They have, once
again, managed to confuse just about everyone and in the process make the
inspection process that much more arbitrary.  Charles, do you have the
source for government billing regulations?

Tammy Barnhart, BS, HTL(ASCP)
Anatomic Pathology Supervisor
St. Alexius Medical Center
Bismarck, ND

-----Original Message-----
From: Charles.Embrey [mailto:Charles.Embrey <@t> carle.com]
Sent: Monday, June 26, 2006 12:17 PM
To: Barnhart, Tammy
Cc: Histonet <@t> pathology.swmed.edu
Subject: RE: [Histonet] salary for lab assistants

Sorry to say that your assumption is wrong.  I have already e-mail CAP and
here is my e-mail and their response.  They make it very clear that they are
deviating from CLIA.  Personally I think the whole thing stinks and CAP is
wrong for what they have done here.

Dear Mr. Embry:

I am responding to your inquiry regarding the dissection of patient specimen
material by someone other than a pathologist.  The intent is that the
requirements of ANP.11610 apply to personnel who evaluate and dissect
specimens, and select which samples of tissue are to be submitted for
histologic processing.  The question is not intended to apply to persons who
merely transfer a small specimen from a bottle to a cassette.  This latter
process does not require the judgment of the former.   

There may be "gray" areas in this distinction, and the laboratory director
is responsible for dealing with those circumstances. 

I am also copying your e-mail to Stephen J. Sarewitz, MD, CAP checklist
commissioner, and Francis E. Sharkey, MD, CAP education commissioner for
informational purposes and possible future checklist revision.

Thank you for your inquiry of the Laboratory Accreditation Program.

-----Original Message-----
From: Charles.Embrey [mailto:Charles.Embrey <@t> carle.com]
Sent: Tuesday, May 02, 2006 12:42 PM
To: CommEmail
Subject: Question concerning non-pathologists grossing

ANP.11600 refers to "specimens examined grossly" but the next question,
ANP.11610 has changed the phrase "examined grossly" to "are dissected".  Is
CAP creating a "loophole" for labs to use Non-high complexity testing
personnel to do biopsies and small specimens?  The federal register CLIA
interpretive guidelines appendix C subpart M effective April 24, 2003 states
in section 493.1461(e) "In the case if gross examinations, the technical
supervisor may delegate to individuals qualified under 493.1498 the
responsibility for the physical examination/description, including color,
weight, measurement, and other characteristics of the tissue; or other
mechanical procedures for which a specific written protocol has been
developed."  

Is CAP going to accept non-high complexity testing personnel to gross?  Why
the two different wordings?

Charles Embrey PA(ASCP)

Manager Histology

Carle Clinic IL

(217) 383-3666

-----Original Message-----
From: Barnhart, Tammy [mailto:Tbarnhart <@t> primecare.org] 
Sent: Monday, June 26, 2006 11:44 AM
To: Charles.Embrey; Janice Mahoney; histonet <@t> lists.utsouthwestern.edu
Subject: RE: [Histonet] salary for lab assistants

After reviewing the CAP checklist as it relates to grossing of specimens
(see below), I don't think I would assume that the CAP is not referring to
what CLIA considers "High Complexity Testing". CLIA is very clear about
educational and training requirements needed to perform high complexity
testing.  Granted the CAP has caused a lot of confusion by using the term
"dissected by individuals other than pathologist" instead of the term
"tissue examination" as CLIA has used, but that may be viewed as splitting
hairs.  I have assumed that the CLIA and CAP requirements are the same and
like Janice, have cited labs I have inspected for not having qualified
personnel performing this function. Charles, do you have a source for the
government requirements for tissue examination and billing?  I would really
like to have that documentation for my files.

I have asked the CAP to respond to this question via e-mail and will share
their response with the list as soon as it is received.

Tammy Barnhart, BS, HTL(ASCP) 
Anatomic Pathology Supervisor 
St. Alexius Medical Center 
Bismarck, ND 

**NEW**         04/28/2005 

ANP.11610             Phase II  N/A   YES   NO 

If specimens are dissected by individuals other than a pathologist or
pathology resident, do such individuals qualify as high complexity testing
personnel under CLIA-88 regulations?

NOTE:  The laboratory director may delegate the dissection of specimens to
non-pathologist individuals; these individuals must be qualified as high
complexity testing personnel under CLIA-88 regulations.  The minimum
training/experience required of such personnel is:

1.      An earned associate degree in a laboratory science or medical
laboratory technology, obtained from an accredited institution, OR

2.      Education/training equivalent to the above that includes at least 60
semester hours or equivalent from an accredited institution.  This education
must include 24 semester hours of medical laboratory technology courses, OR
24 semester hours of science courses that includes 6 semester hours of
chemistry, 6 semester hours of biology, and 12 semester hours of chemistry,
biology or medical laboratory technology in any combination.  In addition,
the individual must have laboratory training including either completion of
a clinical laboratory training program approved or accredited by the ABHES,
the CAHEA, or other organization approved by HHS (note that this training
may be included in the 60 semester hours listed above), OR at least 3 months
documented laboratory training in each specialty in which the individual
performs high complexity testing.

In addition, the CLIA-88 regulations include exceptions for grandfathered
individuals; these regulations (42CFR493.1489 and 1491) may be found at
http://www.phppo.cdc.gov/clia/regs/subpart_m.aspx#493.1487
<http://www.phppo.cdc.gov/clia/regs/subpart_m.aspx#493.1487> 

This checklist question applies only to laboratories subject to CLIA-88. 

COMMENTARY: 

N/A 

REFERENCE: Department of Health and Human Services, Centers for Medicare and
Medicaid Services. Clinical laboratory improvement amendments of 1988; final
rule. Fed Register. 2003(Oct 1):1070-1071 [42CFR493.1489], 1071-1072
[42CFR493.1491]. 

ANP.11620             Phase II  N/A   YES   NO 

Are the types of specimens examined and the extent of the examination
performed by a non pathologist clearly defined in a documented policy or
protocol?

COMMENTARY: 

N/A 

REFERENCES: 1) Department of Health and Human Services, Centers for Medicare
and Medicaid Services. Clinical laboratory improvement amendments of 1988;
final rule. Fed Register. 1992(Feb 28):7183 [42CFR493.1489(b)(6)];  2)
Cibull ML. Q&A. Northfield, IL: College of American Pathologists CAP Today.
1997;11(7):112;  3) Grzybicki DM, et al. National practice characteristics
and utilization of pathologists' assistants. Arch Pathol Lab Med.
2001;125:905-912. 

-----Original Message----- 
From: histonet-bounces <@t> lists.utsouthwestern.edu 
[ mailto:histonet-bounces <@t> lists.utsouthwestern.edu
<mailto:histonet-bounces <@t> lists.utsouthwestern.edu> ]On Behalf Of 
Charles.Embrey 
Sent: Monday, June 26, 2006 9:33 AM 
To: Janice Mahoney; Pathrm35 <@t> adelphia.net; pamm <@t> hlclab.com; 
histonet <@t> lists.utsouthwestern.edu; rjbuesa <@t> yahoo.com 
Subject: RE: [Histonet] salary for lab assistants 

First off, CAP doesn't exactly follow CLIA.  CLIA is more stringent and what
you describe is definitely considered grossing and "high complexity
testing".  CAP, on the other hand, is drawing a distinction between grossing
(anything that must be cut in) and non-grossing (taking measurements and
putting biopsies in a cassette with no cutting involved).  Technically you
can meet CAP standards while being in violation of CLIA regulations.  If the
lab does any billing with the government, (Medicare, Medicaid, Tricare) then
you had better be meeting CLIA '88.  Personally I thing CAP is so wrong for
clouding the water on this one.  

Charles Embrey, PA(ASCP)  

-----Original Message----- 
From: histonet-bounces <@t> lists.utsouthwestern.edu [
mailto:histonet-bounces <@t> lists.utsouthwestern.edu
<mailto:histonet-bounces <@t> lists.utsouthwestern.edu> ] On Behalf Of Janice
Mahoney

Sent: Monday, June 26, 2006 8:24 AM 
To: Pathrm35 <@t> adelphia.net; pamm <@t> hlclab.com;
histonet <@t> lists.utsouthwestern.edu; rjbuesa <@t> yahoo.com 
Subject: RE: [Histonet] salary for lab assistants 

I completely agree.  Weighing and measuring is grossing and the person who
does so must qualify under CLIA (CAP follows CLIA).  Many institutions are
still allowing this grossing to be performed HT's and assistants who do not
qualify.  I have been performing CAP inspections for many years and have
cited labs for this.  I did my homework and have documentation from CLIA to
substantiate the fact that "measuring, counting and weighing" is indeed
grossing.

Jan M. 
Omaha 

>>> "Ron Martin" <Pathrm35 <@t> adelphia.net> 06/25/2006 11:21 AM >>> 
Should this lab assistant be "cassetting" at all? This sounds like a 
grossing tech to me and should fall under CLIA regs for high complex testing

with the appropriate education/training. If this person isn't qualified 
should he/she be performing these duties at all? 
Ron Martin 

-----Original Message----- 
From: histonet-bounces <@t> lists.utsouthwestern.edu 
[ mailto:histonet-bounces <@t> lists.utsouthwestern.edu
<mailto:histonet-bounces <@t> lists.utsouthwestern.edu> ] On Behalf Of Rene J
Buesa 
Sent: Sunday, June 25, 2006 9:38 AM 
To: Pam Mara; histonet <@t> lists.utsouthwestern.edu 
Subject: Re: [Histonet] salary for lab assistants 

Pam: 
  For your description your assistant works as a histotech although she may 
or may not have "academic qualifications". 
  You have to consider also that initially histotechs were trained "on the 
job" and later on were "grandfathered" at licensure time (perhaps this is 
one of the reasons why historically histotechs are in lower echelon of 
clinical lab salary scale, but that is another subject to talk about!). 
  I do not think that you should ask about lab aides paymen rates when your 
aide is performing tasks above those of that job position. 
  As a lab supervisor/manager it should be part of your mission that of 
assuring that the employees you supervise are treated fairly. 
  Having said all that I think that you should get for her a salary that 
reflects her tasks, not those usually corresponding for a job level. 
  It is my opinion that she shoudl be paid, at least, at the histotech entry

level. 
  Hope this will help you! 
  René J. 

Pam Mara <pamm <@t> hlclab.com> wrote: 
  I have a question. We have a lab assistant here who does the "cassetting" 
of 
tissue specimens. She isn't a PA and she doesn't really gross in any large 
specimens. We mainly have GI specimens and biopsies, which she 
weighs/measures and puts into cassettes. She also helps with staining, 
coverslipping, etc. 
I was just wondering what is a reasonable salary for someone who performs 
these tasks? Does anyone else work with a lab assistant that performs 
similar tasks? 

Thanks for the info, 
Pam Mara 

-----Original Message----- 
From: histonet-bounces <@t> lists.utsouthwestern.edu 
[ mailto:histonet-bounces <@t> lists.utsouthwestern.edu
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Sent: Saturday, June 24, 2006 9:52 AM 
To: histonet <@t> lists.utsouthwestern.edu 
Subject: Histonet Digest, Vol 31, Issue 36 

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