Good morning,
Under CLIA, Histology processes (processing, embedding, cutting, staining) are 
considered pre-analytic (not testing) and are not classified under either 
complexity level. Currently, the only activities that are considered high 
complexity are grossing, ISH, and reporting results.

Jennifer Wooten, BA, BS, HTL (ASCP)CM
Technical Quality Assurance Auditor

-----Original Message-----
From: James P Montgomery <james.p.montgom...@kp.org>
Sent: Friday, October 20, 2023 2:04 PM
To: histonet@lists.utsouthwestern.edu
Subject: [Histonet] Moderate vs High Complexity for routine histology

Hello,

Is routine histology considered moderate or high complexity by CAP?  It looks 
like CLIA doesn't even assign a complexity rating as far as I can tell.  I know 
grossing is considered high complexity but what about routine processing, 
embedding, cutting, and special/IHC/ISH staining?  I've had a CAP inspector say 
histotechs are moderate, but a QA manager felt they were high complexity.

Thanks

James



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