Personnel requirements for moderate complexity testing

Our question to CAP was about technical consultant requirements but thought I would add it here for reference.

Good afternoon! I wanted to confirm that a bachelor's degree in nursing would qualify as a bachelor's degree "a chemical, biological, clinical or medical laboratory science" to qualify as a technical consultant for moderately complex testing. Thank you.
 

Prior to the implementation of the CLIA Final Rules, a bachelor's degree in nursing was considered equivalent to a bachelor's degree in a biological science (per the CMS's Surveys & Certification Memo 16-18-CLIA). With the implementation of the CLIA Final Rules, the CMS's interpretation has changed; however, there is a provision that allows those individuals qualified and serving in the technical consultant role as of December 28, 2024, to continue in their role as long as they do so continuously from that date forward. Individuals with bachelor's of nursing degrees starting as technical consultants after that date must have their transcripts evaluated to determine the educational equivalency of the degree to one of the accepted qualifications.  Criteria for course evaluation and educational equivalency are found in the CAP Personnel Guidance document. 
 
 Sincerely,
 
 Shelley M
 Laboratory Accreditation
 Case# 02482843
 
 

I'm also struggling with the same question and cannot get a straight answer, or at least one that makes sense. For mod complex TESTING personnel, the new rule calls out nursing to qualify to AS, BS, MS degree. EMTs/other can qualify with something as simple as a HS diploma (and thorough training, etc). And all of these qualify WITHOUT any extra years of experience. 

But what about 2 or 4 year radiology techs, respiratory therapists, perfusionists? 

Hi to all,
How is everyone handling moderate complexity with the new Technical Consultant regulations that nursing degrees do not count ? 
We are losing grandfathered TC's every month and no new nursing educators can qualify now. I have about 1,500 staff who do moderate complexity testing. My administration wants my staff of 4 POC techs to take over the comps and trainings. It just feels like this will be a nightmare having classes that no one shows up to and covering all three shifts. Any solutions out there?

Thanks,
JoAnn

I had specifically asked about Perfusionist and radiology techs and this is the response I received from CAP:


Thank you for your question on personnel requirements.  I included the newest version of the CAP Personnel Guidance Document which is very helpful.  Not every school/university is the same, so we do not have a list of majors aside from the straight Biology/Chemistry/Medical Lab Science.  On the screen shot below, CMS does specifically call out blood gas testing for respiratory therapy and cardiovascular technology.
 
 Let me know if you have any further questions.
 Linda
 


I did follow up to see if there was an equivalent training definition for moderate complexity testing like is stated for high complexity testing and this was my response from CAP:
Since the moderately complexity testing personnel minimum qualifications is high school graduate with appropriate training, the educational equivalency was not needed.
 
 Thank you
 Linda
 

For the staff doing mod. complex without nursing degrees we are updating our job descriptions to require high school diplomas or equivalent to make sure we meet the new regulations. 

My issue is enabling new nursing staff to be Technical Consultants to participate in competencies , annual and 6 months and training new staff.
This is such a blow to my department. 

I'm running into this issue with one of my Urgent Cares as they start non-waived testing soon and I'm the only POCC for 1 Hospital and 8 Urgent Cares with 1200 operators.  Hoping to get some help, I called CAP about education requirements for someone who trains non-waived testing.  They told me that the laboratory director may determine who is qualified to perform training in the laboratory.  There are CAP/CLIA requirements for qualifications to assess competency, but not for training.