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Q&A column

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Editor: Frederick L. Kiechle, MD, PhD

Submit your pathology-related question for reply by appropriate medical consultants. CAP TODAY will make every effort to answer all relevant questions. However, those questions that are not of general interest may not receive a reply. For your question to be considered, you must include your name and address; this information will be omitted if your question is published in CAP TODAY.

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Q. Can a person who has a bachelor of science degree in health care administration sign off on competency assessments?
A.January 2024—Having a bachelor of science degree in health care administration is not adequate by itself to qualify someone to assess competency for high- or moderate-complexity testing because it does not provide information on that person’s science-related education, training, or experience.

The laboratory must obtain records, such as a diploma or transcript, of the person’s highest level of education in a clinical laboratory-related science (for example, in a biological, chemical, physical, or clinical laboratory science or in medical technology) from an accredited institution and training and/or experience in the area of testing.

The laboratory must then ensure the person meets the minimum qualifications to assess competency based on the complexity of the testing performed, as required in the CAP’s laboratory general checklist requirement GEN.55510 and the related CLIA regulations. For high-complexity testing, the person would need to meet the qualifications of a technical supervisor, as outlined in CAP checklist requirement GEN.53400, or general supervisor, as per GEN.53600. For moderate-complexity testing, the person must meet the qualifications of a technical consultant, as per GEN.53625.

If more stringent state or local regulations are in place for supervisory qualifications, including requirements for state personnel licensure (for example, in California), those must also be followed.

Centers for Medicare and Medicaid Services. What Do I Need to Do to Assess Personnel Competency? November 2012. https://www.cms.gov/regulations-and-guidance/legislation/clia/downloads/clia_compbrochure_508.pdf

College of American Pathologists. GEN.53400 Section Director (Technical Supervisor) Qualifications/Responsibilities. In: Laboratory general checklist. Aug. 24, 2023.

College of American Pathologists. GEN.53600 General Supervisor Qualifications/Responsibilities. In: Laboratory general checklist. Aug. 24, 2023.

College of American Pathologists. GEN.53625 Technical Consultant Qualifications/Responsibilities. In: Laboratory general checklist. Aug. 24, 2023.

College of American Pathologists. GEN.55510 Competency Assessment—Assessor Qualifications. In: Laboratory general checklist. Aug. 24, 2023.

Erin Wilgus, MS, MLS(ASCP)CM
Technical Specialist
Laboratory Accreditation Services
College of American Pathologists
Northfield, Ill.

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