Verifying education documentation

Hi Danyel! I usually send to my state CLIA inspector because those can be SO tricky! Do you have a contact at your state CLIA office?

What will they be doing?

I think as long as they are only performing waived and moderately complex tests, they are good as long as they have documented high school graduation (or equivalent).  This person cannot sign off on competency however, because he/she doesn't meet the criteria for technical consultant.

I have a general email that I communicate through for CLIA cert questions, etc. I could try that. Sometimes I check with my COLA inspector. They will be using the iSTAT for blood gases and chemistries. I think the motive behind the requirement is that if you have "enough" of a certain type of biological, chemical or physical science classes, then you are determined to have basic lab knowledge of sample collection, handling, etc and not need that as part of your training. This is silly of course as we know that RNs, rad techs, etc do not necessarily have this sort of background either but their degrees are acceptable. We train everyone in every aspect any way - this requirement drives me crazy sometimes!

I feel like nearly anyone could perform moderate complexity testing using option 4 in the link below and adequate training.  I only get hung up on the education requirements for competencies/technical consultant requirements.   
https://www.law.cornell.edu/cfr/text/42/493.1423

Moderately complex tests can be run by someone with a minimum of high school education. 
Explain the reasoning why  the test must be done the way you showed them.  Don't just show them let them know the theory.  I hate to say, but there are some techs that can do the test better than some of the nurses with a BS degree. If they pay attention they can be a great asset to the department. 
The  key is proper training and monitoring their performance  closely  to ensure they are doing the tests correctly.  If they are getting more errors ( overfilled, underfilled, wasting cartridges, etc.  a retraining is necessary. 
It does not hurt to  observe them especially the first 3 months of them doing the test.