[Histonet] frozen section/histo duties

Morken, Timothy Timothy.Morken at ucsf.edu
Wed Aug 26 10:24:52 CDT 2020


" The way I read it, the only things in pathology that are actually high complexity testing that aren't performed exclusively by pathologists are .... and QCing special stain/ISH/IHC slides (ANP.21395).  "

CLIA regulations specifically state that quality control is not a test so it is not covered by the complexity rules. 

Tim Morken
Supervisor, Electron Microscopy/Neuromuscular Special Studies
Department of Pathology
UC San Francisco Medical Center


-----Original Message-----
From: Dilts,Andrew via Histonet <histonet at lists.utsouthwestern.edu> 
Sent: Wednesday, August 26, 2020 5:20 AM
To: 'Nancy Schmitt' <Nancy_Schmitt at pa-ucl.com>; histonet at lists.utsouthwestern.edu
Subject: Re: [Histonet] frozen section/histo duties


It's a little tricky and usually brings in CLIA's definition of high complexity testing personnel and then the nuanced definition of testing.  As strange as it seems, most of what we do in histology is not actually testing until a pathologist reads it out and reviews it.

The way I read it, the only things in pathology that are actually high complexity testing that aren't performed exclusively by pathologists are grossing (ANP.11610) and QCing special stain/ISH/IHC slides (ANP.21395).  This can put some labs in a position where, even though a grandfathered histotech may be very capable at QCing stains and fully certified, he or she may not be able to do the QC for regulatory purposes.  Furthermore, the requirements to sit for the exam could be met without being CLIA high complexity testing compliant, so we are still pumping out new histotechs in this loophole.  I doubt it was intended that way, but there it is.

Other high complexity tasks include report review (ANP.29590), digital image analysis (ANP.23038), and circulating tumor cell analysis (ANP.29630) but those aren't an issue for our lab because we either don't do them or because our pathologists obviously do report review.

More directly to your point, I don't see anything in the requirements about histotechs doing or not doing frozens.  I also don't see anything about requiring histotechs to be certified at all for any reason other than your laboratory's preference.  In fact, you can have non-certified staff that have the high complexity testing education who are able to perform routine histology tasks that certified (particularly grandfathered) histotechs aren't allowed to do.

Hopefully someone with more knowledge will chime in because I'm sure I have a lot to learn about the ins and outs of this.




Andrew Dilts  HTL(ASCP)
Histo Supervisor, Laboratory Services
Phone: (417) 269-5021
Andrew.Dilts at coxhealth.com
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.coxhealth.com&d=DwIGaQ&c=iORugZls2LlYyCAZRB3XLg&r=7cy9qXFa73jDX2Iixpjkq1XlWAfHgLLHm33agI_sCKA&m=LXTqkewz9k7aOX8GHkE9kjIWImSbkPcE-HZ9PGP6VX8&s=CwylMDTvTcTJPlPEssSfefVCw86sgGdHl08WdVY4DnI&e= 



-----Original Message-----
From: Nancy Schmitt <Nancy_Schmitt at pa-ucl.com>
Sent: Monday, August 24, 2020 3:12 PM
To: histonet at lists.utsouthwestern.edu
Subject: [Histonet] frozen section/histo duties

Hello and Happy Monday-
Would you please share what your processes are for:

  1.  HT's cutting frozen under direct supervision of pathologist - do you do this?
     *   Now HT has changed and requires Associates degree - but previous would be grandfathered in  - correct?
  2.  Non- certified staff working in histology with supervision - anything they DON"T do?
CAP is our guideline and I am reading - want to make sure I am not overthinking this but not missing anything.........
Thoughts appreciated,
Nancy Schmitt HT, MLT(ASCP)
Pathology Support Services Manager





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