This is a CMS regulation, not FDA. What happens if you get a CLIA citation? Is one citation enough to hold up your CLIA approval status? I think we need to INSIST on some logic and reasonable judgment on this. It says that the ABO compatible status must be assured. If you demonstrate that your computer system is designed to disallowed ABO incompatible units to be selected, and you show that you confirm the ABO of all donor units received, and you reconfirm the ABO of all patients, then I would argue (hard) that this is demonstrating ABO compatibility. There are many ways to do so and ISXM is but one. Also, if you have validation data on the GEL implementation where you have tested AB (including A2B) units with group A and B recipients, and demonstrated incompatibility, you have additional data to prove that your Gel method detects ABO incompatibility. One thing is for certain. If we all kill ourselves to implement something that does not add to patient safety but does add to health care costs, things will just get more rediculous. I vote for civil disobedience on this one.