I only hope that Tim's posting sets this issue to rest. The histotech doing IHC, FISH, or grossing and some other complex tasks has to have special training and studies because all those are high complexity tests. Even those histotechs reading FISH results (counting the reactive nuclei for latter signing by the pathologist) have to receive special training. I will just point out again that some administrators try to "underrate" these tests in order to train "their monkeys" and pay less even when the ratio billing/cost is extremely high. Management greed drives sometimes these issues. René J.
From: "Morken, Timothy" <[email protected]> To: "[email protected]" <[email protected]> Sent: Wednesday, February 6, 2013 5:47 PM Subject: RE: [Histonet] High complexity test The CLIA definition of High Complexity testing is not absolute, rather High Complexity Testing is determined by a scored algorithm of the entire "Test System" (preanalytical through Post Analytical). As such, it clearly takes into account the laboratory or other personnel performing all the specimen collection, grossing, processing, cutting in the pre-analytical phase, and the "Testing Personnel" (CLIA Definition) performing the analytical phase (preparing slides, reagents, applying reagents, quality control, etc) and post analytical phase(interpretation) . The Pathologist's role is only part of that and is scored accordingly. CLIA clearly considers the IHC Test System as High Complexity and requires a technologist for the IHC portion with at least and Associates degree (or equivalent, including course and experience in appropriate science and testing) for Testing Personnel. So, I don't think it is correct to dismiss any personnel standards as irrelevant simply because a pathologist will do the interpretation. Note that if ANY High Complexity tests are performed in the lab then the lab must have a CLIA certification for High Complexity Testing. References: CLIA website with the personnel regulations: http://wwwn.cdc.gov/clia/regs/subpart_m.aspx CAP Q&A about personnel standards for IHC, ISH and IF http://www.cap.org/apps/docs/education/lapaudio/pdf/031710_qa.pdf Relevant IHC question reproduced below: Q 17. My question refers more specifically to immunofluorescence, in situ hybridization and immunohistochemistry. Are the techs that perform these tests considered high complexity testing personnel? If the techs are reporting any kind of preliminary result, they must be qualified to do high complexity testing. If all they are doing is applying the stain, then that is considered processing. A: Personnel performing immunofluorescence, immunohistochemistry and in-situ hybridization techniques require qualifications applicable to high complexity testing. Personnel performing histology processing using routine standardized staining procedures (not classified as molecular) do not fall under CLIA as testing personnel and do not have qualification requirements define CLIA website detailing test categorization: http://wwwn.cdc.gov/clia/regs/subpart_a.aspx#493.17 Excerpt here about High vs Moderate complexity (low complexity are basically home use tests) Sec. 493.17 Test categorization. (a) Categorization by criteria. Notices will be published in the Federal Register which list each specific test system, assay, and examination categorized by complexity. Using the seven criteria specified in this paragraph for categorizing tests of moderate or high complexity, each specific laboratory test system, assay, and examination will be graded for level of complexity by assigning scores of 1, 2, or 3 within each criteria. The score of "1" indicates the lowest level of complexity, and the score of "3" indicates the highest level. These scores will be totaled. Test systems, assays or examinations receiving scores of 12 or less will be categorized as moderate complexity, while those receiving scores above 12 will be categorized as high complexity. Note: A score of "2" will be assigned to a criteria heading when the characteristics for a particular test are intermediate between the descriptions listed for scores of "1" and "3." (1) Knowledge. (i) Score 1. (A) Minimal scientific and technical knowledge is required to perform the test; and (B) Knowledge required to perform the test may be obtained through on-the-job instruction. (ii) Score 3. Specialized scientific and technical knowledge is essential to perform preanalytic, analytic or postanalytic phases of the testing. (2) Training and experience. (i) Score 1. (A) Minimal training is required for preanalytic, analytic and postanalytic phases of the testing process; and (B) Limited experience is required to perform the test. (ii) Score 3. (A) Specialized training is essential to perform the preanalytic, analytic or postanalytic testing process; or (B) Substantial experience may be necessary for analytic test performance. (3) Reagents and materials preparation. (i) Score 1. (A) Reagents and materials are generally stable and reliable; and (B) Reagents and materials are prepackaged, or premeasured, or Require no special handling, precautions or storage conditions. (ii) Score 3. (A) Reagents and materials may be labile and may require special handling to assure reliability; or (B) Reagents and materials preparation may include manual steps such as gravimetric or volumetric measurements. (4) Characteristics of operational steps. (i) Score 1. Operational steps are either automatically executed (such as pipetting, temperature monitoring, or timing of steps), or are easily controlled. (ii) Score 3. Operational steps in the testing process require close monitoring or control, and may require special specimen preparation, precise temperature control or timing of procedural steps, accurate pipetting, or extensive calculations. (5) Calibration, quality control, and proficiency testing materials. (i) Score 1. (A) Calibration materials are stable and readily available; (B) Quality control materials are stable and readily available; and (C) External proficiency testing materials, when available, are stable. (ii) Score 3. (A) Calibration materials, if available, may be labile; (B) Quality control materials may be labile, or not available; or (C) External proficiency testing materials, if available, may be labile. (6) Test system troubleshooting and equipment maintenance. (i) Score 1. (A) Test system troubleshooting is automatic or self- correcting, or clearly described or requires minimal judgment; and (B) Equipment maintenance is provided by the manufacturer, is seldom needed, or can easily be performed. (ii) Score 3. (A) Troubleshooting is not automatic and requires decision-making and direct intervention to resolve most problems; or (B) Maintenance requires special knowledge, skills, and abilities. (7) Interpretation and judgment. (i) Score 1. (A) Minimal interpretation and judgment are required to perform preanalytic, analytic and postanalytic processes; and (B) Resolution of problems requires limited independent interpretation and judgment; and (ii) Score 3. (A) Extensive independent interpretation and judgment are required to perform the preanalytic, analytic or postanalytic processes; and (B) Resolution of problems requires extensive interpretation and judgment. Tim Morken Supervisor, Electron Microscopy/Neuromuscular Special Studies Department of Pathology UC San Francisco Medical Center -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Mark Tarango Sent: Wednesday, February 06, 2013 2:07 PM To: Jesus Ellin Cc: [email protected] Subject: Re: [Histonet] High complexity test Just to clarify, this is not my interpretation. This is what CAP will tell you when you give them a call. Mark On Wed, Feb 6, 2013 at 1:07 PM, Jesus Ellin <[email protected]> wrote: > I would say this is high complexoty testing and the tech performing > this has to have knowledge of the process and troubleshooting in case > there is issues with the results. I do not agree with the > interpretation some people give,, but this is based on individual > institutions > > Sent from my iPad > > On Feb 6, 2013, at 2:05 PM, "Rene J Buesa" <[email protected]> wrote: > > > This issue has been discussed at length recently (please go to > > HistoNet > files). > > The "complexity" does not deals with the "actual test" but with the > ability of the technician to go above and beyond the "robotic tasks" > but also able to think and apply knowledge when something goes wrong. > > Sometimes dismissal of complexity is rooted on the desire in > > management > to pay less for tasks that require a higher licensure grade. > > René J. > > > > From: Sara Baldwin/mhhcc.org <[email protected]> > > To: [email protected] > > Sent: Wednesday, February 6, 2013 2:54 PM > > Subject: [Histonet] High complexity test > > > > Hi histonetters > > Is ventana Ultra IHC only doing antibodies no FISH or CISH is this > considered High complexity testing? We are doing ER/PR and some others. > > > > Thanks > > Histology/Cytology Supervisor > > S. Kathy Baldwin, SCT (ASCP) > > Memorial Hospital and Health Care Center [email protected] Ph > > 812-996-0210, 0216, Fax 812-996-0232, Pager 812-481-0897, Cell > > 812-887-3357 _______________________________________________ > > Histonet mailing list > > [email protected] > > http://lists.utsouthwestern.edu/mailman/listinfo/histonet > > _______________________________________________ > > Histonet mailing list > > [email protected] > > http://lists.utsouthwestern.edu/mailman/listinfo/histonet > > ______________________________________________________________________ > This message is confidential, intended only for the named > recipient(s) and may contain information that is privileged or exempt > from disclosure under applicable law. If you are not the intended > recipient(s), you are notified that the dissemination, distribution, > or copying of this message is strictly prohibited. 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