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.di...@coxhealth.com
www.coxhealth.com
-----Original Message-----
From: Nancy Schmitt <nancy_schm...@pa-ucl.com>
Sent: Monday, August 24, 2020 3:12 PM
To: histonet@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
CoxHealth – ranked one of Missouri's Best Hospitals by U.S. News & World Report
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