[?? Probable Spam] [Histonet] New CAP grossing guidelines

Joe Nocito jnocito <@t> satx.rr.com
Wed Mar 31 16:08:11 CDT 2010

just had a lively discussion at work. My take is that the only thing CAP 
changed was that they combined the "processing" and "grossing" pieces 
together again, which I don't know why they split them in the first place. 
But you don't have the entire CAP note and many people miss this.  The last 
item states OR three months of documented laboratory training in the high 
complexity area. Again, my take is that an unregistered histotech can have 
at least three months of documented training in grossing complex specimens, 
have the record signed off by the medical director and be ok. How far off am 

----- Original Message ----- 
From: "Mahoney,Janice A" <Janice.Mahoney <@t> alegent.org>
To: "Histonet" <histonet <@t> lists.utsouthwestern.edu>
Sent: Wednesday, March 31, 2010 2:44 PM
Subject: [?? Probable Spam] [Histonet] New CAP grossing guidelines

Is anyone concerned about the new (old) grossing personnel guidelines from 
CAP.  Many labs use people to "process " tissue.  No more!

ANP.11610 Phase II

If individuals other than a pathologist or pathology resident assist in 
gross examinations, do such individuals qualify as high complexity testing 
personnel under CLIA 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 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, 
NAACLA, 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.

The CLIA regulations on high complexity testing personnel may be found at HC 
Testing Personnel<http://wwwn.cdc.gov/clia/regs/subpart_m.aspx>.

In addition, the CLIA regulations include exceptions for grandfathered 
individuals; these regulations (42CFR493.1489 and 1491) may be found at the 
above Web address and at Grandfathered 

It is the responsibility of the laboratory director to determine whether an 
individual's education, training and experience satisfies the requirements 
of this checklist question.
Jan Mahoney
Omaha, NE

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