Competency assessment
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We are CAP inspected and POC is under the main lab CLIA #. I have 3 moderately complex testing platforms within POC. I have clinical nurse educators and respiratory educators that help with competency. We require them to have a 4 year science degree + 2 years experience to do this since that is the requirement for moderately complex testing.
My question is, I have an MLT in the lab who helps with POC. Since we are under the umbrella of the main lab CLIA which is a highly complex lab and she has the qualifications to assess competency for highly complex testing, can she do competency observation for iSTAT, which is moderately complex?
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Hello,
My understanding is that the requirement to assess a moderately-complex test is a Bachelor's of Science degree with 1 year of experience of performing that test.
We do not allow MLT's to assess moderately-complex tests.
Tricia Boyer
We have run into the same road block. The reasoning that CAP gave is that those running high complexity tests must have a lab background or have a Bachelor's. So there is less risk if someone without a Bachelor's doing the check-off will make a mistake in assessing skills.
For moderately complex testing, this test is done by lab and non-lab personal. So there is more risk for an assessment to not be as thorough. (i.e. think ADN vs. BSN)
Danyel - That is a good question. I would think they would qualify since they can assess high complexity tests but who knows …...
You absolutely cannot use an MLT to assess mod complex testing. Only a bachelors degree and 2 years of experience. This is the requirement per CMS/CLIA. We were cited in our lab (NOT POCT) because they were using MLTs to assess mod complex testing.
It is even a little more complex than just having a Bachelor’s degree to assess moderately complex testing. The CAP does not recognize a four year BS in nursing
as an acceptable degree to meet the role of technical consultant and be able to assess competency. The role of Technical Consultant requires a BS in a chemical, physical or biological science. The CAP further defines those three degrees as having completed
24 credit hours in chemistry, biology and medical technology or MLS.
CAP requires that the assessor must have a minimum of 6 credit hours in chemistry, 6 credit hours in biology and the remaining 12 credits can be in any combination
of biology, chemistry or medical laboratory science in order to meet the qualification. This eliminates most with BSN’s from being POC competency assessors for moderately complex testing. The BSN does qualify for those labs that are CLIA only, but not for
CAP as CLIA does recognize the BSN.
We found some nurses in our institution who have enough credit hours but we have to determine that by reviewing their transcripts and not just a BSN diploma.
I agree with Kathleen, that an MLT is not qualified to assess competency for moderate complexity or high complexity, UNLESS that MLT also has a Bachelor Degree in a Life Science. There are MLT's that also have a BS in Biology for example, that person would qualify as long as they have 2 years of experience.
About nurses - I disagree that most BSN's do not meet this qualification. I have reviewed hundreds upon hundreds of nursing transcripts on trainers with a BSN and most of them do in fact qualify just fine. In addition to general bio and chem, anatomy and physiology, they typically also have pharmacology, pathophysiology, etc - those also count. It was rare to see a BSN that did not meet the 24 credit hours of Bio/Chem from what I have seen.
I also thought a BSN degree would not qualify for Technical Consultant. Another POCC sent me the following CMS documentation:
https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-16-18.pdf
It clearly states: "Bachelor's and Associate's degrees in nursing meet the requirement for earning a degree in a biological science for, respectively, high complexity testing personnel and moderate complexity testing personnel."
With 2 years of experience, they can meet Technical Consultant. But on the other hand, someone with a BS degree in Geology can also qualify (Geology is a Physical science degree)! It's all about the type of degree, not what is on the transcript. I was told it doesn't matter if they have 48 hours of science credits, if they don't have a biological, chemical, physical science or MLS degree, they don't qualify.
An MLT can assess highly complex testing if they meet the qualifications of a "general supervisor" - an associates degree in MLT and 2 years lab or blood gas experience in highly complex testing. We have MLTs assessing competency for highly complex testing within the main lab. I believe the thinking is that for highly complex testing you have more supervisory roles in place to oversee this so someone with a less degree qualifies.
It's very confusing(and frustrating!) then that the same person does not qualify to assess competency of a lower complexity of testing within the same laboratory.
I do agree that I believe a BSN qualifies as a 4 year science degree based on the CMS statement that Christiane references above. If CMS is going to call a BSN equivalent to a 4 year science degree for testing personnel, then to me it's equivalent for competency assessment with the required experience.
Thanks for the feedback everyone.
I forgot to mention there is a Q&A section that goes along with the letter. One of the questions asked is if a BSN meets Technical Consultant. The answer was "Yes, if they have the two years of required experience". Per CAP, it does not matter if the experience was with Moderate Complex testing or waived, the pre-analytical, analytical, and post-analytical should be the same processes for waived and non-waived. They also stated in my email it can be from a previous employer, as long as you have their complete documentation of training or experience.
Also, if the degree states "Bachelors of Science", you better have their transcript stating what their field of study was and they have the 12 credits in biology/chemistry.
I had a strong candidate apply in my department with more than 25 years of lab experience, with 10 years in POC, BS degree with 30 credits in biology and chemistry. They met the requirements for ASCP to allow them to challenge the MT boards, so they are a certified MT. But because their degree isn't a biological, chemical, physical science or MLS degree, they don't meet Technical Consultant. I had to pass on hiring them, because I needed someone who met Technical Consultant.
Yeah, I know CMS doesn't accept a certification. Sorry for venting, but this doesn't seem fair.
to all,
I just spoke with CAP. A BSN qualifies as a technical supervisor for POCT. The pathologist needs to give that authority to them as a technical supervisor. Here for the ISTAT we use 2 years of experience with the item that they will be observing comps upon.
In the lab, the qualifications may be different. A CAP system inspector explained the differences to me but I do not remember them.
If you have questions....your life would be easier if you just call CAP.
Deanna Bogner
Does the 2 year experience need to be a continuous one? If an employee had 2 years experience, left for a while and came back, do we have to start over again and wait for 2 years for that employee to be able to assess moderately complex testing?
Hi Chris,
Can I just ask if the candidate had all those credits in biology and chemistry (30) why they did not qualify as TC? What kind of degree did they have?
JoAnn
The CAP Laboratory Personnel Evaluation Roster FAQS on page 7 states: "A bachelor's or associated degree in nursing meets the requirement for earing a degree in a biological science for respectively, high complexity and moderate complexity testing personnel.".
Debra....I spoke with Stacy at CAP about an hour ago. I would clarify that with her
does anyone know if a respiratory therapist would qualify as a TC?