What is considered high complexity testing


I had an interesting inquiry.  This technician is being inspected by
CLIA.  They listed ISH for HPV as one of the tests done in histology.
They were told that ISH was a "High Compexity Test" and that histotechs
are not qualified to be doing this.  They said that a test like this
should be performed by a MedTech type, unless they could demonstrate
that they had been "High Complexity Tests" before 1995.  The question
is:  Is IHC considered HCT?  Can someone clear up this issue for me, I
was not sure how to advise this person?  Is this another issue like
"grossing" where it can be done by histotechs as long as they are
trained and supervised by a pathologists type, since we do not interpret
the results we just do the methods and then give the slides to a
pathologists to use in making the report.?

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