JShepard, I have been approached on this subject multiple times.
There might be a loop hole. If the Nursing staff call it a "blood draw", it doesn't fall under the QSA regs for BB.
If the nursing staff call it a "therapeutic phlebotomy", it does.
What's the difference between a blood draw and a therapeutic phlebotomy?
Nothing, except what regulations fall under it.
The result is the same.
I have been telling my nursing staff to call it "blood draw".
Hope this helps
Stephanie