Training Vs. Competency for Moderately Complex Testing

Good morning Anastasia,
I'll take a stab at answering (but as usual will say 'beware if your State has additional requirements because mine does not so I'm not sure about those). 

A 'trainer' (who is not also conducting competency assessment) is not required to meet same requirements/CLIA role qualifications as the assessor/evaluator of competency must meet.

The trainer must not only be knowledgeable about the test procedure to be used, but must follow exactly the (required) written process/policy for training and assessing, which is current, signed off by the CLIA Lab Director (for the testing site). 

I'm sorry but unsure what you mean with the 2nd question.
Are you asking about the trainer (who does not qualify as a Tech Consultant because they do not have a BS) being able to be an evaluator/assessor after they pass their own personal comp assessment at 6 months (as a testing personnel)? (Unless your State trumps CLIA regs on Tech Consultant role qualifications), I'd say 'no', the 'non-qualified as a Tech Consultant' could gather evidence/data on testing personnel to submit to the qualified Tech Consultant towards the testing personnel meeting their personal assessments. But the CLIA Lab Director cannot designate the Tech Consultant role to a non-qualified person regardless of lab experience if they do not meet the educational requirement.  

Hope I didn't confuse!
Peggy

Competency needs to be evaluated initially as well as 6 and 12 months.  :)

Agree nonwaived competency needs to be established  - initially - in order to determine if the employee/tester is competent to independently perform the test as required.
Whereas competency assessment (evaluation) requirement is for semiannual (most call it '6 months' but that depends on Accreditation agency) after initial training and employee begins testing.

Here is a citation: 
CAP GEN.55505 The competency of personnel performing nonwaived testing is assessed at the required frequency at the laboratory (CAP/CLIA#) where testing is performed. NOTE: Competency assessment evaluates an individual's ongoing ability to apply knowledge and skills to achieve intended results. Competency must be assessed at the following frequency: At least semiannually (first assessment within seven months from initiation of testing and second assessment no later than 12 months from the start of testing during the first year an individual tests patient specimens (new employees).

Hope this helps.
Warm wishes, Peggy @Univ of Tx Medical Branch, Houston/Galveston

Hi Anastasia,
I believe the semiannual and annual competency assessments are considered "competency assessments".  The initial "evaluation" after training is NOT considered competency assessment because the employee hasn't done any testing; there are no records to "assess".  I believe Jean Ball clarified this during one of her presentations.  Note that the CAP used the words "be evaluated".  By that definition, your trainers do NOT need to meet the TC qualification.   

This is my interpretation of the CAP checklists.  Hope it is correct.  

Don, that is my interpretation as well.  Initial TRAINING is not a competency assessment and can be performed by anyone trained and knowledgeable with the procedure.  That's how sales reps can be trainers if they are not MLS's.  Any competency assessments (for non-waived testing) after that whether semi annually or annually must be completed with a technical consultant or higher.  

I agree with Don and Reine above. Not only have I heard Jean Ball explain this during a presentation, but during out last CAP inspection a CAP representative came and explained it the same way. Initial training is performed at time of hire and they can not be competent yet since they have not been performing the test. Then semiannually and annually you assess their competency since they have now been performing the test. The CAP representative even suggested I change my forms to have a specific initial training form and a separate competency form so the 2 items are not confused.