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Help Stop CMS’s Proposal Classifying Nursing as a Biological Science

Feb 27, 2018

Flawed Proposal Would Allow Individuals with a Degree in Nursing to Supervise Labs and Perform High Complexity Testing!

Your help is needed to STOP a highly flawed proposal from the Centers for Medicare and Medicaid Services (CMS) to allow individuals with a bachelor’s degree in nursing to supervise clinical laboratories and to perform all CLIA complexity levels of laboratory testing

The proposal, published in a CMS Request for Information on Jan. 9, 2018, seeks comments and information regarding formalizing the current CMS interpretation that undermines the Clinical Laboratory Improvement Amendments of 1988 (CLIA) personnel standards. This policy would allow individuals with a bachelor’s degree in nursing to perform high complexity testing and to serve as technical consultants (supervisors), which would require them to assess the competency of skilled laboratory professionals. 

The proposal reflects the Agency’s controversial interpretation, outlined in an April 1, 2016 memorandum, that nursing is a biological science. The 2016 policy allows individuals with a nursing degree to perform and supervise high complexity testing and may even allow these degree holders to direct clinical laboratory testing. It is unclear whether CMS would disallow a nursing degree from being used to meet other supervisory roles apparently allowed under current Agency policy. 

A typical baccalaureate degree in the biological sciences generally requires three to four times MORE biology courses than does a degree in nursing. The laboratory medicine community has great respect for the nursing profession and the important healthcare services they provide to patients. Still, a nursing degree is not equivalent to a biological sciences degree. In response to the 2016 policy, the laboratory community has advocated repeatedly for changes to the policy. CMS has received several letters and a petition signed by 35,000 concerned individuals challenging the Agency’s interpretation and even met with representatives of the laboratory community in September 2016. For more information on these efforts, click here.

In order to change the Agency’s position on allowing a nursing degree to satisfy CLIA’s high complexity degree requirements, we urge all concerned individuals, i.e., laboratory professionals, pathologists, patients and the general public, to tell CMS to “Put Patients First. Individuals that don’t have the appropriate scientific knowledge should not be allowed to perform high complexity testing or supervise laboratory testing. Please let CMS know what you think here!

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Please share this important Action Alert with your friends, colleagues, and other interested persons.  Also, when you tell CMS about your concerns with its flawed personnel proposal, we suggest you list your academic degrees and professional credentials in your message.  Thank you for standing up for patient quality!


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