BOC Newsletter - Special Edition Alert

Friday, July 22, 2016

ASCP BOC Leading Challenge to CMS Nursing Equivalency Action

Nursing Is Not a Biological Science, ASCP BOC argues

The ASCP Board of Certification (BOC) has been in ongoing discussions with Centers for Medicare and Medicaid Services (CMS) staff regarding its recent decision to declare nursing degrees the equivalent of biological sciences degrees.

In an April 1 internal memo to CMS State CLIA Survey Agency Directors, CMS announced that individuals with a bachelor’s degree in nursing may perform high complexity testing and that individuals with an associate degree in nursing may perform moderate complexity testing. The CMS memo provides no rationale or justification for its decision. During these discussions (including a recent meeting between CMS, the ASCP BOC, and ASCLS), the BOC has expressed concern about the impact of the decision on test quality and patient care. The meeting occurred in response to a letter sent to CMS by the BOC on behalf of the Board of Governors (BOG), whose member institutions include:

  • ASCP (American Society for Clinical Pathology)
  • American Association for Clinical Chemistry (AACC)
  • American Association of Pathologists’ Assistants (AAPA)
  • Association of Genetic Technologists (AGT)
  • American Society for Clinical Laboratory Science (ASCLS)
  • American Society of Cytopathology (ASC)
  • American Society of Hematology (ASH)
  • American Society for Microbiology (ASM)
  • AABB
  • Clinical Laboratory Management Association (CLMA)
  • National Society for Histotechnology (NSH)

The ASCP BOC brought the issue to the attention of the BOG member institutions in a June 3 email alerting them of the issue and informing them of the BOC’s plans to contact CMS about its decision. Shortly thereafter, some BOG member institutions sent in their own letters supplementing the BOG’s initiative.

In its letter to CMS, the BOC argued, “The nursing degree is not intended to be, nor should it be viewed as the equivalent of a degree in biological sciences or any other natural science degree required of laboratory testing professionals to perform moderate and high complexity diagnostic testing services.”

The BOG letter provided examples from several major universities to illustrate that, both in scope and depth, “the natural science coursework required for a biological sciences degree vastly outweighs the natural science coursework required as part of a nursing degree.” 

In addition, the BOC raised concern that the Agency’s decision may have unintended spillover effects with regard to laboratory leadership. The BOC noted that the Agency’s decision “appears to have opened a pathway for the nursing degree to qualify individuals to serve in senior technical leadership positions within moderate and high complexity clinical laboratories," including as a laboratory director or technical supervisor in a moderate complexity laboratory or a general supervisor or technical supervisor in a high complexity laboratory.

The BOC letter raised objections, writing that the Agency’s decision “significantly lowers the qualifications necessary to perform high and moderate complexity testing and could have significant repercussions for test quality and patient safety.”  The ASCP BOC plans to continue its dialogue with CMS to urge it to rescind its decision.  We will keep our certificants and BOG member institutions informed of the progress on these discussions.