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Technical Consultant / CAP requirements


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As a MLS (ASCP), I am very frustrated.  I currently am a Section Head of Blood Bank since 2012.  I have just been told that I am not able to be a technical consultant of my department.   Which, means even though I am the person that knows the ins and outs of the blood bank department I am not able to perform direct observations of the employees that work in my department because I don’t have my bachelor in one of the four major sciences.  This is not making since to me, I was able to sit for the MLS certification but I not competent enough to observe my employees.  Has anyone else run into this?

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@idsirnate1 

Your institution needs to have another look at CLIA/CAP requirements.

Here's a link to the CLIA competency brochure that explains it in an approachable format:

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-07.pdf

To perform competency, you need to be a technical supervisor, which for immunohematology requires a doctor. The technical supervisor can delegate competency to a general supervisor. In high complexity testing environments (all blood bank is high complexity) to be a general supervisor you only need an associates degree and two years experience of high complexity testing. Truth be told you don't even need an associates but can meet qualification with a long list of other comparable training/education.

CAP follows CLIA guidelines for general supervisor qualifications (it doesn't spell them all out, but it couldn't because there are a dozen pages of grandfather clauses or alternate pathways) and competency assessment performance. Feel free to message me and I'll ramble on at greater length, if it will help you.

Edited by goodchild
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This is coming from CLIA.  At our facility we are not classified as supervisors but as Leads. 

Moderate Complexity – Technical Consultant

MD, DO with current medical license in state of lab’s location AND certified in anatomic and/or clinical pathology by ABP or AOBP or equivalent qualifications

MD, DO, or DPM with current medical license in state of lab’s location AND 1 year laboratory training/experience in the designated specialty/subspecialty or responsibility

PhD in chemical, physical, biological or clinical laboratory science or medical technology AND 1 year laboratory training/experience in the designated specialty/subspecialty of responsibility

Masters in chemical, physical, biological or clinical laboratory science or medical technology AND 1 year laboratory training/experience in the designated specialty/subspecialty of responsibility

 

 

I received by MLT certification ASCP in 94, then went back to school 2006 receiving a Bachelor degree in information technology (computer programming) with required science classes received my certification as a MLS (ASCP).  This is very frustrating I feel I have done all this hard work for nothing.  They are asking me how long would it take to get my bachelor in one of the four major sciences.  I don't know of any college to that would take science classes from 1994.  If anyone knows of a way to get around this please let me know.

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If you are certified as a MLS, and have a BS or a BA, tell the powers that be you already have a bachelor's in one of the "four major sciences".

Note that you are actually working as a general supervisor for BB (as pointed out in a post above).  You don't need to be a "technical supervisor".  That would be your pathologist.

Scott

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36 minutes ago, idsirnate1 said:

This is coming from CLIA.  At our facility we are not classified as supervisors but as Leads. 

Moderate Complexity – Technical Consultant

MD, DO with current medical license in state of lab’s location AND certified in anatomic and/or clinical pathology by ABP or AOBP or equivalent qualifications

MD, DO, or DPM with current medical license in state of lab’s location AND 1 year laboratory training/experience in the designated specialty/subspecialty or responsibility

PhD in chemical, physical, biological or clinical laboratory science or medical technology AND 1 year laboratory training/experience in the designated specialty/subspecialty of responsibility

Masters in chemical, physical, biological or clinical laboratory science or medical technology AND 1 year laboratory training/experience in the designated specialty/subspecialty of responsibility

 

 

I received by MLT certification ASCP in 94, then went back to school 2006 receiving a Bachelor degree in information technology (computer programming) with required science classes received my certification as a MLS (ASCP).  This is very frustrating I feel I have done all this hard work for nothing.  They are asking me how long would it take to get my bachelor in one of the four major sciences.  I don't know of any college to that would take science classes from 1994.  If anyone knows of a way to get around this please let me know.

They're still applying an incorrect interpretation of CLIA as it pertains to Transfusion Services (immunohematology).

  • All blood bank activities are high complexity.
  • High complexity testing doesn't have a 'technical consultant' designation. They have technical supervisors and (without re-reading) only MD, DO, and maybe doctor of podiatry(?) qualify.
  • Technologists who Lead/Supervise/Manage/Senior Tech (however your organization calls it doesn't change the CLIA interpretation of personnel) have to be qualified as general supervisors.
  • General supervisors may perform competency assessments.
  • If you qualify as testing personnel and have two years of experience in high complexity testing (which it sounds like you do), you are qualified to be a general supervisor.
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