What I believe happens is that the referring lab must do an audit/inspection of 
the technical-only lab to be sure they are CLIA compliant. For instance, check 
validation procedures for stains, equipment, quality control. It's true CLIA 
itself does not inspect the Tech-only lab, but the referring lab becomes the 
"technical supervisor" and must have documentation to show they have inspected 
it and it is compliant. That is how it works for vendors using other labs to do 
work for them under FDA regulations.


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



-----Original Message-----
From: Andy B via Histonet [mailto:histonet@lists.utsouthwestern.edu] 
Sent: Monday, October 05, 2015 12:05 PM
To: histonet@lists.utsouthwestern.edu
Subject: [Histonet] TC labs

Does CLIA inspect labs that only perform Technical Components on tissue?

I know that CAP does so as part of its due diligence, however years ago a CLIA 
inspector told me that CLIA doesnt inspect TC-only operations because there is 
no report (PC) being rendered. How does this jive with grossing and the new 
High Complexity Testing (HCT) paradigm?

In other words, what is to prevent a pathologist (or non-pathologist) from 
owning and operating a TC lab service that is remote from the PC service 
location? How does CMS verify that TC labs are correctly and compliantly 
performing grossing (HCT) and other TC lab evolutions if they do not inspect 
such operations?

I know of labs that are TC only and bill CMS for the Technical Components.
Has anyone else ever wondered about this? How is CMS assuring that TC labs are 
compliantly staffed and managed if CMS only inspects labs that issue reports?

Does anyone wonder how CMS can get away with hammering some labs and ignoring 
others?
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