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Clinical Chemistry Forum |
Department of Clinical Laboratories, Memorial Sloan Kettering Cancer Center, New York, NY 10021.
| Abstract |
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| Introduction |
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| History of CLIA |
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Under CLIA, laboratory practices are divided into the following
categories: microbiology; diagnostic immunology; chemistry; hematology,
including coagulation; pathology (histopathology, oral pathology, and
neuropathology); cytology, cytogenetics; histocompatibility; and
immunohematology (transfusion service). There is no genetics category
(Table 1
). Tests are categorized as waived, provider-performed
microscopy, and those of either moderate or high complexity. Waived
tests are simple laboratory procedures that are cleared by FDA for home
use, use methodologies that are so simple and accurate as to render the
likelihood of erroneous results negligible, or post no reasonable risk
of harm to the patient if the test is performed incorrectly.
Laboratories performing only waived tests must receive a CLIA
certificate and follow the manufacturer's instructions for the test,
but are not required to implement other CLIA regulations.
Provider-performed microscopy also requires only laboratory
registration. These tests require use of a microscope and must be
performed by a physician, dentist, or midlevel practitioner authorized
by the state. These tests must be performed during the patient's visit
on a specimen obtained at that time. The classification of
moderate-complex tests was based on an additive numeric score with a
grade of 1 (least complex) to 3 (most complex) given to each of seven
criteria. Scores below 13 were classified as moderate and those above
as complex. The criteria used to classify tests were as follows:
knowledge required to perform the test, training and expertise,
complexity and experience required, characteristics of operational
steps, availability of calibrators, quality control and proficiency
testing material, troubleshooting and maintenance required, and the
degree of interpretation and judgment. Originally, there were almost
12 000 analytes categorized (Federal Register
1993;58(141):39879). Since then, 3000 more have been added to the list
(Federal Register 1996;61(131):35737).
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The CLIA requirements to ensure quality testing include proficiency testing (PT), patient test management, quality control (QC), and quality assurance (QA). QA includes test ordering; availability of tests; patient preparation; collection and delivery of specimens; analytical performance, including turnaround time; data handling; interpretation of results; and clinical action by the user. QC requires preparation of procedure manuals, method calibration and validation, daily controls for each assay (at least two levels), adherence to manufacturer's instructions, and written documentation of all QC activity. Patient test management involves rules to assure optimum integrity and identification of patient specimens throughout the testing process and result reporting. These rules identify requirements for specimen submission and handling, test requisitions, test records and reports, and the submission of specimens to other laboratories (2).
There are now ~158 000 laboratories registered under CLIA. Of these laboratories, 57% are physician office laboratories, 50% perform only waived tests, 20% perform provider-performed microscopy, and 11% (or almost 18 000 laboratories) are accredited to perform moderately and/or highly complex tests.
| CLIA Advisory Committee |
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CLIAC or subcommittees at the request of HHS, will review and make recommendations concerning: criteria for categorizing tests and review of analytes categorized as moderately complex and highly complex; determination of waived tests; personnel standards; patient test management, QC, QA standards; PT standards; applicability to the standards of new technology; and other issues relevant to CLIA if requested by HHS.
HHS will be responsible for providing necessary data and information to the members of CLIAC. Subcommittees and workgroups report to CLIAC who will either accept, reject or modify their recommendations".
CLIAC was formed in February 1992, under a charter issued by the Secretary of HHS. The charter states that CLIA will provide scientific and technical advice and guidance to the Secretary and the Assistant Secretary for Health regarding the need for, and the nature of, revisions to the standards under which clinical laboratories are regulated, the impact on medical and laboratory practice of proposed revisions to the standards, and the modification of the standards to accommodate technological advances.
The committee consists of 20 members, including the Chair. Members are
selected by the Secretary from authorities knowledgeable in the fields
of microbiology, immunology, chemistry, hematology, and pathology, and
representatives of medical technology, public health, clinical
practice, and consumers. In addition, CLIAC includes three ex officio
members, or designees: the Director, CDC; the Commissioner, FDA; the
Administrator, HCFA; and such additional officers of the US government
that the Secretary deems are necessary for the Committee to effectively
carry out its functions. CLIAC will also include a nonvoting liaison
representative, who is a member of the Health Industry Manufacturers
Association, and such other nonvoting liaison representatives that the
Secretary deems are necessary for the Committee to effectively carry
out its functions. The members of CLIAC, as of July 1, 1998, are listed
in Appendix 1
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Because of the diversity of its membership, it must be emphasized that CLIAC is at times divided in the guidance and advice it offers to the Secretary. Even when all CLIAC members agree on a specific recommendation, the Secretary might not follow their advice because of other overriding concerns. Thus, although some of the actions recommended by CLIAC may eventually produce changes in the law, the reader should not infer that all of the advisory committee's recommendations will be automatically accepted and acted on by the Secretary.
| Genetic Testing |
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The proposed role of CLIA in genetic testing was an outcome of several studies. The Human Genome Project was initiated in 1990 under the guidance of NIH and the Department of Energy (DOE). (4) It is estimated that by 2005 most if not all of the estimated 100 000 human genes will be identified and catalogued. Already there are clinical tests proposed for use in the screening and management of patients with genetic disease. During this period of exploding technology, there has been great concern not only about the legal, ethical, and social aspects of genetic testing, but also the quality of laboratory testing and the availability and access of these procedures during the rapid commercialization of the tests. (5)(6)(7) In 1997, a joint NIH-DOE Task Force on genetic testing was established. In anticipation of recommendations from this Task Force a genetics work group of CLIAC was formed. The NIH-DOE Task force recommendation was as follows: "The Task Force urges the newly created Genetics Subcommittee of CLIAC to consider the creation of a specialty of genetics which would encompass all predictive tests that satisfy criteria for stringent scrutiny. If only a subspecialty for DNA/RNA-based tests is feasible, the subcommittee must then address how to assure the quality of laboratories performing non DNA/RNA predictive genetic tests. The agencies primarily responsible for administering CLIA; HCFA and CDC should take the lead in implementing these recommendations" (7). In October 1997, the CDC, in response to a directive by Dr. David Satcher, who was then Director of the CDC, published a strategic plan for integrating advances in human genetics into public health action. The report entitled, "Translating Advances in Human Genetics in Public Health Action: A Strategic Plan", reiterated the NIH-DOE recommendations and mandated CLIA to establish "standards, regulations and guidelines to ensure the accuracy, validity and precision of laboratory procedures and to ensure that other QA issues are addressed as well" (8).
CLIAC and its genetics working group were requested by HHS to review genetic testing. They concluded that CLIA should include a dedicated genetic testing section. This conclusion was based on the fact that although the testing technology is similar to that used in other laboratory areas, the sensitivity of genetic testing results and the social, economic, and legal aspects of such tests requires a separate section in CLIA. It was felt that the high degree of precision and accuracy required for genetic testing required stringent regulations. Genetic testing was considered from the point of view of preanalytical, analytical, and postanalytical concerns. Current CLIA regulations were reviewed to determine which rules were applicable and where new rules to cover genetic testing adequately or additions or amendments to those now in place were needed. The following are the draft proposals of CLIAC. These will require governmental review and approval and public comment before they are incorporated into CLIA.
| Definitions |
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Molecular Genetic and Cytogenetic Test.
The
analysis of human DNA, RNA, and chromosomes to detect heritable or
acquired disease-related genotypes, mutations, phenotypes, or karyotype
for clinical purposes. Such purposes include predicting risk of
disease, identifying carriers, and establishing prenatal or clinical
diagnosis or prognosis.
Biochemical Genetic Test.
The analysis of materials
derived from the human body, including human proteins and certain
metabolites predominantly used to detect inborn errors of metabolism,
heritable genotypes, or mutations for clinical purposes. Such purposes
include predicting risk of disease, identifying carriers, and
establishing prenatal or clinical diagnosis or prognosis. [Tests that
are used primarily for other purposes, but may contribute to diagnosis
of a genetic disease (e.g., blood smears and certain serum
chemistries), would not be covered by this definition.]
| confidentiality and informed consent |
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| personnel standards |
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Clinical consultant (genetic testing; new section).
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clinical consultant must meet one of the following criteria:
The responsibility of the laboratory director and the clinical consultant are to ensure that reports of test results include pertinent information required for clinical interpretation that is meaningful to a nongeneticist healthcare provider.
In addition, they must assist the individual who orders the test to understand what clinical information the test will yield and to recommend follow-up tests when appropriate.
Technical supervisor (genetic testing; new section).
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technical supervisor must meet one of the following criteria:
In addition to the general laboratory responsibilities for a technical supervisor now outlined in CLIA, the technical supervisor (genetics testing) must ensure that reports include pertinent information required for specific patient genetic testing.
The committee felt strongly that the primary responsibility for the day-to-day operation of a genetics laboratory would be in the hands of the technical supervisor. It was recommended that the title "Technical Supervisor" be changed to "Technical Director", not only for genetic testing, but for all laboratory specialties. This was proposed with an understanding that the title is appropriate for the level of responsibility required, that the General Supervisor may report to this position, and that the title Technical Director is more reflective of the "real world".
General supervisor (genetic testing; new section).
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general supervisor must meet one of the following criteria:
Testing personnel.
No change from current CLIA
regulations [Code of Federal Regulations, Section 1489, Part 493,
Title 42 (10-1-97 edition)].
| quality control |
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| contamination |
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| proficiency testing |
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| validation of tests |
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| special reporting requirements |
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| retention of records |
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| reuse of tested specimens |
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| Conclusion |
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to accommodate technological advances. It must be kept in mind that the Secretary may not follow the advice of CLIAC because of other overriding concerns. Thus, although some of the actions recommended by CLIAC may eventually produce changes in the law, it should not be construed that all of the advisory committee's recommendations will be automatically accepted and acted upon by the Secretary.
| Footnotes |
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1 Nonstandard abbreviations: FDA, Food and Drug Administration; HCFA, Health Care Financing Administration; HHS, Health and Human Services; CLIAC, Clinical Laboratory Improvement Advisory Committee; PT, proficiency testing; QC, quality control; QA, quality assurance; and DOE, Department of Energy. ![]()
| References |
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The following articles in journals at HighWire Press have cited this article:
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J. R. ten Bosch and W. W. Grody Keeping Up With the Next Generation: Massively Parallel Sequencing in Clinical Diagnostics J. Mol. Diagn., November 1, 2008; 10(6): 484 - 492. [Abstract] [Full Text] [PDF] |
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C. Orlando, P. Verderio, R. Maatman, J. Danneberg, S. Ramsden, M. Neumaier, D. Taruscio, V. Falbo, R. Jansen, C. Casini-Raggi, et al. EQUAL-qual: A European Program for External Quality Assessment of Genomic DNA Extraction and PCR Amplification Clin. Chem., July 1, 2007; 53(7): 1349 - 1357. [Abstract] [Full Text] [PDF] |
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V. M. Van Deerlin, L. H. Gill, J. M. Farmer, J. Q. Trojanowski, and V. M-Y. Lee Familial Frontotemporal Dementia: From Gene Discovery to Clinical Molecular Diagnostics Clin. Chem., October 1, 2003; 49(10): 1717 - 1725. [Abstract] [Full Text] [PDF] |
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C. C. Raggi, P. Pinzani, A. Paradiso, M. Pazzagli, and C. Orlando External Quality Assurance Program for PCR Amplification of Genomic DNA: An Italian Experience Clin. Chem., May 1, 2003; 49(5): 782 - 791. [Abstract] [Full Text] [PDF] |
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D. S. Young and D. G.B. Leonard Issues in Genetic Testing Clin. Chem., June 1, 1999; 45(6): 915 - 926. [Full Text] [PDF] |
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D. S. Young Issues in Genetic Testing Clin. Chem., May 1, 1999; 45(5): 725 - 725. [Full Text] [PDF] |
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N. A. Holtzman Promoting Safe and Effective Genetic Tests in the United States: Work of the Task Force on Genetic Testing Clin. Chem., May 1, 1999; 45(5): 732 - 738. [Abstract] [Full Text] [PDF] |
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