James,
We base all of our high complexity testing on the semester hours as listed in 
"c."  If an individual has completed an associate degree in a laboratory 
science, they should meet the educational requirements as stated previously.  I 
would recommend obtaining a transcript from the applicants.  Our institution 
then will keep that in their personnel file.  As part of our policy for non-PA 
grossing, I have a form that I complete stating I reviewed the employee's 
educational requirements.  I have copied and pasted my document below.  If you 
are interested in receiving the entire procedure and attachments, please let me 
know and I can email them to you directly.

Employee Name:__________________________

A review of this employee’s educational records was completed on 
___________(date).

This employee has been   □approved     □not approved   to perform high 
complexity testing based on CLIA requirements as listed in the Federal Register 
493.1489 and 1491.

493.1489 states the following education requirements:

Each individual performing high complexity testing must--
    (b) Meet one of the following requirements:
                (1) Be a doctor of medicine, doctor of osteopathy, or doctor of
        podiatric medicine licensed to practice medicine, osteopathy, or
        podiatry in the State in which the laboratory is located or have earned 
a doctoral, master's or bachelor's degree in a chemical, physical, biological 
or clinical laboratory science, or medical technology from an accredited 
institution; OR
        (2)(i) Have earned an associate degree in a laboratory science, or 
medical laboratory technology from an accredited institution or?
           (ii) Have education and training equivalent to that specified in 
paragraph (b)(2)(i) of this section that includes--
                (A) At least 60 semester hours, or equivalent, from an 
accredited institution that, at a minimum, include either-
                        (1) 24 semester hours of medical laboratory technology 
courses; or
                        (2) 24 semester hours of science courses that include--
                                (i) Six semester hours of chemistry;
                                (ii) Six semester hours of biology; and
                                (iii) Twelve semester hours of chemistry, 
biology, or medical laboratory technology in any combination
    

Full text on Federal Register qualifications can be viewed at: 
http://wwwn.cdc.gov/clia/regs/toc.aspx 




Review completed by: ______________________ (printed name)
                           
    ______________________ (signature)

-----Original Message-----
From: Vickroy, James via Histonet [mailto:histonet@lists.utsouthwestern.edu] 
Sent: Wednesday, April 13, 2016 8:14 AM
To: histonet@lists.utsouthwestern.edu
Subject: [Histonet] Grossing tech qualifications


a.       We are experiencing trouble finding another tech that will meet CLIA 
high complexity testing standards as well as has histotechnician training.   
Also the qualifications for who can gross is a little vague so I wanted to see 
if anyone has any information that would help me.  A summary of the grossing 
qualifications are listed below.   In the past we have hired applicants with 
bachelor's degrees in biology and then trained them in histotechnology.   We 
also went through the 90 day inhouse training for grossing.   My questions have 
to do with a clarification regarding those with an associate's degree.     I 
have an applicant that has an associate's degree in science with an emphasis on 
microbiology.     My question has to do with the language  "An earned associate 
degree in a laboratory science or medical laboratory technology" .   How can I 
determine what that exactly means?   Would a person with an associate's degree 
in science with an emphasis in microbiology qualify?  I'm 
 not sure she has the sixty hours total.

Qualifications of a technician for performing gross descriptions and 
preparation for tissue processing under the direct or indirect supervision of a 
pathologist include:

b.       An earned associate degree in a laboratory science or medical 
laboratory technology,
Obtained from an accredited institution, OR

c.       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, the CAHEA, 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.

I would appreciate any understanding that others might have.

Jim



Jim Vickroy
Histology Manager
Springfield Clinic, Main Campus, East Building
1025 South 6th Street
Springfield, Illinois  62703
Office:  217-528-7541, Ext. 15121
Email:  jvick...@springfieldclinic.com<mailto:jvick...@springfieldclinic.com>



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