RE: [Histonet] Training for gross

From:Rene J Buesa

Because tissue processing, in 98% of all our laboratories in general and in all the histopathology labs is done by tissue processors, automatically. Only some labs doing electron microscopy still process samples manually and if a machine can process tissue, it cannot be considered as a "high complexity" task.
René J.

--- On Tue, 8/26/08,  wrote:

Subject: RE: [Histonet] Training for gross
To: "Caldwell, Lia" 
Cc:,, "Sharon.Davis-Devine" 
Date: Tuesday, August 26, 2008, 2:20 PM

Question....   under CAP guideline ANP. 11600 "Processing" (vs
"grossing/gross examination) considered  a form of high complexity

The reason I ask is because under CAP guideline ANP.11610  the statement is
- "If individuals other than
 a pathologist, etc., assist in 'GROSS EXAMINATIONS", do such
qualify as HIGH COMPLEXITY testing
 personnel under CLIA-88 regulations?"  There is absolutely NO mention of
qualifications for individuals performing
 tissue "PROCESSING".

Lisa A. Martin, PA (ASCP)
Gundersen Lutheran Medical Center

             "Caldwell, Lia"                                         
             Sent by:                  "Sharon.Davis-Devine"         
             lists.utsouthwest                                          cc=20
                                       RE: [Histonet] Training for gross  =20
             08/22/2008 04:54                                             =20
             PM                                                           =20

This came up during a recent CAP inspection of a lab we inspected in
Maricopa so I have taken the liberty of copying the information from the
CAP guidelines regarding this issue for you.  The first question defines
high complexity testing and the second question addresses requirements for
individuals performing these tasks.
Hope this helps, have a great weekend!

According to CAP guidelines


"Are all macroscopic tissue examinations performed by a pathologist or
pathology resident, or under supervision of a qualified pathologist?

Note:  Two levels of complexity of macroscopic tissue examination are
defined, as follows:

1.  Processing is defined as a tissue examination limited to description,
inking and cutting of the specimen (if applicable), and submission of the
entire specimen to histology.  Tissue processing can be performed accroding
to standardized protocols.  Processing is generally limited to small
specimens (skin ellipses, small biopsies, curettings, etc.) and does not
require knowledge of anatomy.

2.  Grossing (or gross examination) is defined as a tissue examination
requiring a greater exercise of judgement and a knowledge of anatomy.
Dissection of the specimen and selection of tissue samples for submission
to histology are generally required.  The specimen description is not
necessarily stadardized.


"If individuals other than a pathologist or pathology resident assist in
gross examinations, do such individuals qualify as high complexity testing
personnel under CLIA-88 regulations?

NOTE:  The laboratory director may delegate the dissection of specimens to
non-pathologist individuals;  these individuals must be qualified as high
complexity testing personnel under CLIA-88 regulations.  The minimum
training/experience required of such personnel is:

1.  An earned associate degree in a laboratory science or medical
laboratory technology, obtained from an accredited institution, OR
2.  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.

In addition, the CLIA-88 regulations include exceptions for grandfathered
individuals; these regulations (42CFR493.1489 and 1491) may be found at

It is the responsibility of the laboratory director to determine whether an
individual's education, training and experience satisfies the requirements
of this checklist question.

This checklist question applies only to laboratories subject to CLIA-88

Lia M. Caldwell HT (ASCP)
Histology Supervisor
Oro Valley Pathology Dept.
phone: (520) 901-3914
"be yourself - everyone else is already taken." -unknown


From: on behalf of
Sent: Fri 8/22/2008 10:23 AM
Subject: [Histonet] Training for gross

For all of you Histonetters out there I have a question about training
individuals to gross in small specimens.  Can a person with a degree and
being a Cytotechnologist, Medical Technologist or a Histotechnologist
gross in small biopsy samples?  And if they can, what kind of training
is required and for how long?  We are losing one of our PA's and are
contemplating replacing that person with a person with a degree. Thanks
for the info.

Sharon Davis-Devine, CT (ASCP)

Cytology Supervisor

Carle Clinic

602 West University

Urbana, Illinois 61801

Phone:  217-383-3572


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