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CLIA Hits Questionable Tests
Stephen Barrett, M.D.
The Centers for Medicare & Medicaid
Services (CMS) has announced that four "nontraditional"
laboratory tests are not permissible unless the laboratory providing
them is approved for "high-complexity testing" as defined
under the Clinical
Laboratory Improvement Act (CLIA) Program.
Congress passed the Clinical Laboratory Improvement Amendments
(CLIA) in 1988 to establish quality standards for all laboratory
testing to ensure the accuracy, reliability, and timeliness of
patient test results regardless of where the test was performed.
A laboratory is defined as any facility which performs laboratory
testing on specimens derived from humans for the purpose of providing
information for the diagnosis, prevention, treatment of disease,
or impairment of, or assessment of health.
The final CLIA regulations published
on February 28, 1992 are based on the complexity of the test
method; thus, the more complicated the test, the more stringent
the requirements. Three categories of tests have been established:
waived complexity, moderate complexity (including provider-performed
microscopy) and high complexity. CLIA specifies quality standards
for proficiency testing, patient test management, quality control,
personnel qualifications and quality assurance for laboratories
performing moderate and/or high complexity tests. Waived laboratories
must enroll in CLIA, pay the applicable fee and follow manufacturers'
instructions. Because problems in cytology laboratories were
the impetus for CLIA, there are also specific cytology requirements.
The Centers for Medicare & Medicaid
Services (CMS) is charged with the implementation of CLIA, including
laboratory registration, fee collection, surveys, surveyor guidelines
and training, enforcement, approvals of proficiency testing providers,
accrediting organizations, and exempt states. The Centers for
Disease Control and Prevention (CDC) is responsible for the CLIA
studies, convening the Clinical Laboratory Improvement Amendments
Committee (CLIAC) and providing scientific and technical support/consultation
to CMS. The FDA is responsible for test categorization. To enroll
in the CLIA program, laboratories must first register by completing
an application, pay fees, be surveyed (if applicable), and become
certified.
To curb the use of certain tests that
lack a scientific basis or are unsubstantiated, the CLIA Program
has established a rule that any laboratory doing such tests must
be CLIA-certified for high-complexity testing. Unapproved providers
can be sanctioned under either federal or state laws that regulate
laboratory use. Live blood cell analysis, biological terrain
assessment, dental sensitivity testing, and cytotoxic testing
are covered by this requirement. The listing of live cell analysis
was triggered by a complaint I made in 1996 against three chiropractors
in Allentown, Pennsylvania who were using it as a gimmick to
attract patients and sell enzyme pills. This CLIA alert summarizes
the current policy toward these tests.
CLIA: SPECIAL ALERT
LIVE BLOOD CELL ANALYSIS (LBA) UNDER CLIA
[Alternative - Non-Traditional Laboratory Testing]
Live Blood Cell Analysis (LBA)
is a test which is used for the purpose of providing information
for the diagnosis, prevention, or treatment of any disease or
impairment of, or assessment of the health of human beings. The
Health Care Financing Administration (now the Centers for Medicare
& Medicaid Services) Office of General Counsel (OGC) determined
in August, 1997, that LBA was subject to all CLIA requirements.
Therefore, any facility performing this procedure must be certified
by CLIA and must obtain the correct certificate. Failure to comply
with any of the CLIA requirements will result in enforcement
actions and/or sanctions being taken.
In January, 1996, the Centers for Disease Control (CDC), determined
that the LBA test procedure automatically defaulted to high complexity
because it had not been categorized by CDC. Therefore, any facility
performing this test must meet all CLIA requirements for high
complexity testing: Patient Test Management; Proficiency Testing;
Quality Control; Personnel, and Quality Assurance. Therefore
any facility performing LBA must hold a valid registration certificate,
Certificate of Compliance, or Certificate of Accreditation. LBA
is not a Provider-Performed Microscopic Procedure (PPMP) test.
LBA is also a non-covered Medicare service. CLIA Regulations
(CDC Website)
LBA is performed by placing a drop of blood from the patient's
fingertip on a microscope slide under a glass coverslip to keep
it from drying. [NOTE: In some cases, a powder has been developed
that when sprinkled on the blood will form a type of "coverslip"].
The slide is then viewed at high magnification with a dark-field
microscope that forwards the image to a television monitor. The
results are then used for prescribing nutritional supplements.
LBA is also known as Hemaview, Free Radical Blood Screening,
etc.
Other examples of Alternative Testing (Non-Traditional Laboratory
Testing) that are subject to CLIA:
Biological Terrain Assessment (BTA):
BTA is a computerized analysis of blood, urine, and saliva specimens
used to recommend nutritional programs, vitamin and mineral supplements,
homeopathic products, and/or herbs. Analysis is determined through
pH determinations. A portion of the test is legitimate: pH. .
. .
Dental sensitivity testing: This
test determines whether one is sensitive to materials in fillings.
If sensitive, all fillings can be removed and replaced. All reviewing
agencies could not determine whether the method was valid.
Cytotoxic Testing (Food Allergy Testing):
Cytotoxic testing involves taking about 10 ccs of blood from
a patient. The white blood cells (WBCs/leukocytes) are mixed
with plasma and sterile water and placed on microscopic slides,
after each slide has been coated with the dried extract of a
particular food. The reaction of the cells to the extracts is
then examined under a microscope. If the cells collapse, disintegrate,
or change shape, the patient is supposedly allergic to that particular
food. This evidence of food allergy is then used to explain a
variety of symptoms. To correct this condition, the clinic offers
a personalized diet program which includes vitamin and mineral
supplements. Also called Brian's Test or Leukocyte Antigen Testing.
To obtain further information on LBA and other alternative
laboratory testing, please contact your State Survey Agency or
CMS Regional Office.
Last modified on Wednesday, April 24, 2002
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Except for freestanding commercial laboratories,
blood banks, hospitals, and large medical offices, very few facilities
have high-complexity approval. Only
a few states restrict the use of unestablished laboratory tests.
Nevertheless, if you encounter any practitioner
who does live blood cell analysis, biological terrain assessment,
dental sensitivity testing, or cytotoxic testing and is not obviously
running a laboratory, please ask your state laboratory department
to investigate.
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This article was posted
on March 9, 2004.
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