Timothy.Morken at ucsf.edu
Wed Nov 23 18:12:06 CST 2016
Jennifer, short answer:
It is not that histology is not a "high complexity test." The issue is, who is defined as "testing personnel." All histology tests are high complexity. But in anatomic pathology the pathologist is the only designated "testing personnel" according to CLIA regs because they are the only personnel interpreting and reporting results.
No one else in histology interprets or reports results, so all other work in histology is considered "processing."
The confusion between AP and Clin Lab is that Med Techs do report out results and so are "testing personnel" under CLIA.
CAP is trying to apply regs to AP that were written for Clin Lab. They not fit well....
Pathology Site Manager, Parnassus
Supervisor, Electron Microscopy/Neuromuscular Special Studies
Department of Pathology
UC San Francisco Medical Center
From: Jennifer Valentine-Williams [mailto:jennifer.valentine-williams at neogenomics.com]
Sent: Wednesday, November 23, 2016 2:02 PM
To: Morken, Timothy; Jesus Ellin
Subject: RE: [Histonet] Personel
I would like to branch off from this topic... Should a lab aid be allowed to load/unload slides/reagents from an automated IHC machine?
Should they be permitted to print the labels that tell the machine which tests to run?
I say no, but others say otherwise, so I'm interested in what everyone else here thinks.
All lab tests have pre and post analytical components and I believe they all contribute to the High-complexity status of the "test". It surely cannot be that the interpretation is the only portion that is considered the "High-complexity test". I am open to hearing why this may be the case though.
Jennifer Valentine-Williams, HT (ASCP)
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