Bottom line - you must be high complexity for CLIA and you must have distinct procedures for CAP. Mine said "Biopsy Grossing", so at inspection I had to change it to processing. Which for us means the tissue processor.
So it's all a mess, in my most humble 2 cents worth again! j:>)
Saint Joseph's Hospital
5665 Peachtree Dunwoody Rd NE
Atlanta, GA 30342
404-851-7376 - Phone
404-851-7831 - Fax
[mailto:firstname.lastname@example.org]On Behalf Of
Sent: Tuesday, November 06, 2007 1:59 PM
Subject: [Histonet] non pathologist grossing versus processing
So this is a subject that has been beat like a dead horse for a long time on histonet. The subject is, a histotech describing, measuring (color, description, measurments, etc) of G.I. and other non-complicated specimens (some skins included...inking).
So, as a PA(ASCP) myself I spend much of my paid time with realy simple specimens like G.I. biopsies and skins. Basically, these are specimens that are boring and take up a lot of time cause there are so many of them....not to say it makes me not like my job....I still LOVE it. But, if I could delegate those to a histotech then I would have the time to devote more to higher complexity specimens like radical nephrectomies, mastectomies, pneumonectomies, etc.. We have some near by labs that our pathologists contract out to, of which also have gross, but those pathologists have been doing that gross. So, it would be great, in my mind to be able to deligate the low complexity specimens to technicians in both places and have myself grossing all the complex specimens so the pathologists don't have to hire another pathologist or PA and I would be expending what I get paid in a more effecient manner.
In the CLIA regs it states that anyone doing gross exam on specimens needs to be a high complexity tester under CLIA 493.1489. It also mentions that there is a distinction between processing specimens (specimen preparation, what technicians do) and grossing specimens (describing color, weight, measurements, submitting sections). I notice on histonet that everybody always says that you have to be a 493.1489 tester to be able to do any type of gross. But, what if processing a specimen could include the description, measurement, inking, color, etc...of specimens that required no knowledge of anatomy and the entire specimen was submitted? According to the CAP inspection checklist, there is this exact destinction between two levels of macroscopic tissue complexity and are clearly defined. The two levels are defined as "1)Processing," and "2)Grossing."
"Are all macroscopic tissue examinations performed by a pathologist or pathology resident, or under the 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 according 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 judgment 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 standardized."
Throughout this checklist it never requires one who processes tissues to be qualified as a high complexity tester, or 493.1489 individual. You must, however, include a lot of documentation about the nature of supervision (direct or indirect, by a pathologist) and the specific types of specimens that they are limited to, and exactly how they are to process them.
My question is, why don't we here more about this? Why can't I find it in the CLIA regs, but I can in the CAP checklist? And, is anybody out there even aware of this disctinction? Well, it made my day...and hopefully it will be a help to others out there!
Vince Van Cleave, BS, PA(ASCP), HTL, HT
Laboratory Manager and Pathologist Assistant
Clinical Pathology Associates
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