Respiratory Therapy

I have managed it both ways. I prefer the RT areas to be under the lab CLIA. 

Under the lab side: Cheaper from the CLIA certificate cost, an involved Laboratory Medical Director (pulmonologists might be a bit dismissive of the items the lab has to have), and usually one inspection agency. (RT was inspected by TJC while the main lab was CAP when I managed them separately) 

Sometimes the "lab" doesn't want those "RT problems" under their CLIA. No matter which CLIA they are under, and there are citations or other issues, eventually it will the problem of the laboratory. 

I have also had both ways, and I concur with Deanna that under the lab is better. 
One issue could be Respiratory having the appropriate staff to be technical consultant. In addition, since the test is mod complex, a pulmonologist might not qualify as lab director. I had that issue in one of my positions, where we were cited for the Respiratory medical director not having the 20 hours of training required by CLIA, and had to have the laboratory medical director step in temporarily until that was obtained. There is added risk of inspection deficiencies, especially if the Respiratory department doesn't work well with the lab, or understand CLIA/CAP/TJC regulations. 

Yes, We have multiple locations. All are under the Main campus CLIA. Like Kathleen we have had education issues with RT Directors/Managers/Supervisors.  POC has to take care of RT and Pulmonary Fuct. Lab.  Fortunately, we have a good relationship with RT. 

I have been on both sides of that equation - with RT separate and RT under lab/POC.  By far prefer the latter.  Because, what ends up happening with the former is you end up getting all the lab-based/regulatory questions anyway, when they are due for inspection.  And with no time to right the wrongs/non-compliance.  

We are CAP and have RT under our CLIA.  One potential "con" is the role of Technical Consultant, who can assess competency.  If there are no RTs that have a bachelor's degree, someone from the Lab would have to assume that role. 

Thank you all for your responses. For now, we are going to keep POC and RT separate and just assist with any regulatory questions that may arise. I've been at this location for 5 years and we haven't had any issues with inspections, so hopefully this trend continues. Thanks again.