RE: [Histonet] CAP question on grossing

From:"Luck, Greg D."

Charles (,

Where "specifically" is it stated in any regulations (e.g. CLIA '88, CAP,
Federal Register or other source) that "tissue grossing" is defined as high
complexity testing?  Thanks, Greg

Greg Luck, BS, HT(ASCP)
Anatomic Pathology Supervisor
Deaconess Medical Center
800 W. 5th Ave
Spokane, WA 99204
Phone 509.473.7077
Fax 509.473.7133

-----Original Message-----
From: Charles.Embrey [] 
Sent: Wednesday, October 26, 2005 7:49 AM
To: Jesus Ellin
Subject: RE: [Histonet] CAP question on grossing

CAP and CLIA have never made a separation in "transference" from grossing.
Ever CLIA statement I have ever read on the subject states that grossing any
tissue is high complexity testing.  "Transference" is not even recognized in
the CAP checklist.  I routinely assist on CAP inspections and I would love
to see a lab try to sell me on "transference".  Of course it is only a Phase
II write up but if the problem is not documented as corrected the lab can
lose its accreditation. Liability and appropriate pay are other
considerations I personally have mentioned in other e-mails but have been
flamed for.  My personal feeling is that if someone wants to undervalue
their talent and work that is up to them.  As long as labs can get techs to
do part of the pathologists job for about a tenth of the pathologist's
salary, those people will be prayed upon.

Charles Embrey, PA(ASCP)   

-----Original Message-----
From: Jesus Ellin []
Sent: Tuesday, October 25, 2005 7:36 PM
To: Charles.Embrey
Subject: RE: [Histonet] CAP question on grossing

What about transference, our pathologist's are saying that small bx's or
anything that does not require cutting or manipulation falls under this
category. They are saying any registered or registry eligable can do this
portion of the gross.  What needs to happen is have stated black in white
what techs can or can not do.  This not only puts a lot of liability on the
tech, it also is having tech do a PA or pathologist job at a techs wage,
which is not right at all.  Were can someone find out what the scale is for
grossing tech's?  I know it depends on the institution, but there has to be
some sort of support for this other than requirements that CLIA and CAP set
forth.  Also what other than a phase two what can also happen if a facility
is caught doing this.??

Jesus Ellin
Yuma Regional Medical Center

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