CMS qualifications for Competency Assessors
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Hello Fellow POCCs.
MLH is 4 hospital system with 2.2 POCCs to manage 4000 operators. 1358 observations need to be completed on an annual basis as part of competency.
In the current process, we had nurses, who had a BSN and 2 years' experience with the test method, functioning as competency assessors (technical consultant), so that nurses could complete the direct observation on each other.
BSN Nurses were also doing training and competency for new hires.
CMS December 2023 changes have now stated that a BSN is no longer the equivalent to a BS in biology making them now ineligible to be competency assessors.
Thus, we are searching for manageable ways to complete the competency process other than having 2 POCCs have to do competency observations.
Please share with me any discussions and particularly solutions your system is considering addressing this (outside of using the POCCs) to perform all competency passements for non-waived testing.
Appreciatively,
Melissa Willcox
MT ASCP
POCC
Main Line Health
willcoxm@mlhs.org
MLH is 4 hospital system with 2.2 POCCs to manage 4000 operators. 1358 observations need to be completed on an annual basis as part of competency.
In the current process, we had nurses, who had a BSN and 2 years' experience with the test method, functioning as competency assessors (technical consultant), so that nurses could complete the direct observation on each other.
BSN Nurses were also doing training and competency for new hires.
CMS December 2023 changes have now stated that a BSN is no longer the equivalent to a BS in biology making them now ineligible to be competency assessors.
Thus, we are searching for manageable ways to complete the competency process other than having 2 POCCs have to do competency observations.
Please share with me any discussions and particularly solutions your system is considering addressing this (outside of using the POCCs) to perform all competency passements for non-waived testing.
Appreciatively,
Melissa Willcox
MT ASCP
POCC
Main Line Health
willcoxm@mlhs.org
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Hello,
I am the POCC at Einstein Philadelphia. With regard to assessing competency, the nurse educators do the direct observation for the Accuchek Inform II, the Cliniteks are used in the ED and the nurse educator for that department takes care of that population. Most departments have a nurse educator who performs the assessments for ACT, Blood Gases, POC PT/INR, HgbA1c, urinalysis by dipstick and urine pregnancy testing etc. some areas have superusers who are trained by the manufacturer. I perform the initial training for the ED residents for occult blood testing, microscopic examinations and ocular pH testing for chemical contamination. I also train the OB/GYN residents for the premature rupture of membranes using the Amnio test and the ROM Plus. I am the only person in the POC department and there is no way that I could ever accomplish this on my own.
Bonnie Coccagna MS, MT(ASCP)
Jefferson Einstein Healthcare Network
Point of Care Coordinator
215-456-6811
________________________________
Before going further, I wanted to confirm which rule is being discussed. Is this in reference to the following?
Final Rule- Clinical Laboratory Improvement Amendments of 1988 (CLIA) Fees, Histocompatibility, Personnel, and Alternative Sanctions for Certificate of Waiver Laboratories (CMS-3326-F)
Here is the link to CMS-3326-F below:
Federal Register :: Clinical Laboratory Improvement Amendments of 1988 (CLIA) Fees; Histocompatibility, Personnel, and Alternative Sanctions for Certificate of Waiver Laboratories
EDIT: If you follow the link to the rule and look under the section § 493.1411 Standard; Technical consultant qualifications. the language reads as follows:
(4)(i)(A) Have earned a bachelor's degree in a chemical, biological, clinical or medical laboratory science, or medical technology from an accredited institution; or
This leads me to think that a nursing degree is acceptable as a "clinical" degree under this guideline for Technical Consultant.
Here is his reply:
Mary,
Mary
1. The 12/28/2024 Final ruling https://www.federalregister.gov/d/2023-28170 seems to state the TC changes go into effect at the end of 2024
3. Associate degrees as TC.
There is a gray area if you blood gas menu contains chemistry analytes such as glucose, lactate, Na+ etc.
Certainly an RT can sign off on pH, pCO2 and O2 and the rest of the ABG parameters, but what about the chemistry ones?
CAP is currently revising their standards based on these revised CMS regs so hopefully there will be more clarifications as we get closer to the
December effective date.
The issue is here:
In response to the overwhelming opposition, CMS determined not to finalize its proposal to qualify BSNs for high complexity testing. Individuals with a nursing degree may still qualify as moderate complexity Testing Personnel, which covers most point-of-care testing, but cannot serve as Lab Directors or Technical Consultants in those settings.
If I understand this correctly, BSNs can perform moderately complex testing, but not perform high complexity testing AND they can not be technical consultants which is what you need to be able to be a CA for non-waived testing.
I definitely need to look further into this.