GEN.53625 Technical Consultant Qualifications

My interpretation is that based on the transcript (classes taken for the BSN degree), a BSN may or may not qualify.

Our POC program is TJC accredited but BSN and Respiratory Therapists (with Bachelor Degree in RT) both qualify. 
I have never found this in writing, however, our TJC inspector had stated such. The number of science credits influences qualification. 

Our interpretation is that a BSN qualifies under a "Biological Science".

To my previous understanding according to CLIA regulations, BSN did not qualify as Technical consultant.  It has been up for discussion.  According to our last TJC survey and response from an email our LD sent to them, a BSN does qualify as TC and you must have at least 2 years experience in lab testing or whatever the moderate complex test being assessed for competency.

My understanding is that in the state of California, a BSN does not qualify as one of the bachelor of science degrees required for a Technical Consultant.  That being said, with COVID changing the way things are being done, you may have success with an inspector by arguing that you have had to modify your process in order to minimize exposure to too many people.

SC16-18.Personnel Qualifications for CLIA_REVISED 05.03.16.pdf

See attached CMS Guideline published May 3rd 2016 Page 4 bottom of the page, BSN meets the requirements of a Bachelor's in a biological Science.

I am unaware if this has been revised. 

Personnel Policies for Individuals Directing or Performing Non-waived Tests | CMS

Here is the link to the document on the CMS website.

All of those CMS guidelines to me refer to qualifying as a testing personnel and not a Technical consultant??

S&C-16-18-CLIA Personnel Policies for Individuals Directing or Performing Non-waived Tests (cms.gov)
CMS.gov, FAQ's  Question 12 and 13
Q12. Is a bachelor’s degree in nursing considered a degree in biological science for the purpose of meeting the TC qualification at 42 CFR §493.1411(b)(4)(i) for moderate complexity testing? A12. Yes, an individual holding a bachelor’s degree in nursing, possessing a current license issued by the state in which the laboratory is located (if such licensing is required), and having at least 2 years of laboratory training or experience, or both in non-waived testing, in the designated specialty or subspecialty areas of service for which the technical consultant is responsible, can meet the qualification for moderate complexity TC. 
Q13. Can a bachelor’s degree in nursing meet the requirement 42 CFR §493.1405(b)(5)(i) for LD (moderate complexity)? A13. In order to qualify under §493.1405(b)(5)(i) as a LD for moderate complexity testing , the individual must possess a current license issued by the state in which the laboratory is located (if such licensing is required); must have earned a bachelor’s degree in a chemical, physical, or biological science or medical technology from an accredited institution; must have at least 2 years of laboratory training or experience, or both in non-waived testing; and must have at least 2 years of supervisory laboratory experience in non-waived testing.

Anita,
   This arose in our lab a while back as well. I have an email from a CAP Inspection Services Manager that states "CMS and CAP have recognized a BSRN degree, with 2 years experience, as meeting the qualifications for the CLIA role of Technical Consultant."  If you would like me to forward it to you let me know. 

Hi Ashlee,
Could I please have a copy of the letter from CAP?
Thanks so much!