Why Licensure

“You are seeking to become licensed to encroach on my scope of practice.”

• Pathologists’ Assistants are not pathologists and cannot diagnose and sign out cases as we are not qualified to do so according to any regulatory agencies such as CLIA, CAP, and the Joint Commission.
• Pathologists’ Assistants perform technical work and cannot bill for professional level charges as we are not pathologists performing the professional tasks of diagnosis and sign out.
• Our Scope of Practice, according to the American Association of Pathologists’ Assistants and regulatory bodies, allows us to perform the gross examination and postmortem examinations with the exception of final diagnosis and sign out.

“You expect too much money, licensure will make it worse; I could just hire another pathologist.”

• When reviewing ASCP’s salary survey and looking at other laboratory average salaries such as MLT and MLS/CLS, salary was highest in states that do have laboratory personnel licensing.  The states that require laboratory licensing did not make the top 18, which shows that licensing does not necessarily dictate salary, much less salary increases.  The highest paid personnel in the MLT and MLS/CLS categories were those working in large academic institutions with greater than 500 beds, which seems to indicate that facility size has more to do with laboratory personnel salary than anything else.
• Pathologists’ Assistants will always be less expensive than another pathologist, as we are not physicians.
• As the pathologists’ workforce faces increasing shortages, pathologists are required to spend more time at the microscope and less time in the gross room.  This means that if the facility/group is utilizing Pathologists’ Assistant(s), there could be large gaps where the pathologist does not step into the gross room while the Pathologists’ Assistant is grossing daily.  The Pathologists’ Assistants being at the gross bench daily keeps their skills sharp, up to date and efficient.  Some pathologists do not perform gross examination for months to years between grossing experience, and this can potentially diminish their efficiency in the gross room.

“We are already in a workforce shortage; this will make it worse.”

• Currently, there are 16 NACCLS-accredited Pathologists’ Assistant programs in the U.S. and Canada with annual classes of up to 230 PA students per year, and another two programs are in serious applicant status.
• New programs are being developed rapidly, and the number of programs has doubled in the last decade.
• Based on data from the AAPA Career Center in between October 2022 and December 2023, there were over 265 job postings and >70% of the positions were not reposted.  This suggests that the majority of job postings are filled after one advertisement.
• There is indeed a workforce shortage of pathologists, and PAs are becoming more commonly utilized for gross examination and forensic pathology to allow pathologists to spend more time diagnosing and signing out reports and less time in the gross room.
• There are many factors for a PA to accept a position including geographic location, pay appropriate for level of complexity/services, benefits, work/life balance, etc., which have a significant impact on how long it takes to fill a position.
• Desirable positions with competitive pay have been filled without posting a formal advertisement.  Candidates are found and subsequently hired by word of mouth or on social media.
• The timing of a posting can also have an effect on recruitment efforts.  If an employer misses the window for new graduates coming out of programs seeking employment, it can be more difficult to hire as the newly graduated Pathologists’ Assistants have already signed on to positions and are sometimes locked in for a minimum period of time due to recruitment bonuses.
• The reputation, real or perceived, of an employer can also play a significant role in the hiring process.  The Pathologists’ Assistant profession is a small enough community that when an employer has a negative impact, word of mouth can spread quickly dampening the reputation of the employer.  If an employer has a high turnover, it could be beneficial to perform exit interviews to ascertain the primary reasons for losing staff such as: overwhelming workloads, location, safety issues, managerial challenges, etc.  If performed in a neutral way allowing exiting employees to be honest, employers can gain insight into how to improve and build their reputation back up to become a more desirable employer/position.

“I have had program-trained PAs who were sub-par; if I train my own personnel, I know what I’m getting.”

• Pathologists’ Assistants began with two pathways for training: one was formal education/training and the other included on the job training (OJT).  In 1976, there was an OJT examination which allowed candidates to become AAPA “fellow members”.  Later, AAPA partnered with the American Society for Clinical Pathology to create independent national certification exams.  In 2008, the OJT pathway for certification was closed and the only pathway remaining was to successfully complete an accredited PA program and pass the ASCP certification examination.
• Based on AAPA salary surveys, program-trained PAs have significantly increased, and OJT PA populations are decreasing.  In 2007, 26% of the survey respondents indicated they were OJT, but by 2021 that population was down to 11%.  Conversely, program-trained PAs went from 74% in 2007 to 89% in 2021.  Additionally, the program-trained PAs’ educational backgrounds have changed to include 87% M.S. degrees in 2021 as opposed to only 61% in 2007.  All of these statistics indicate that newly graduated PAs should have an overall increase in standard and complete training/educational backgrounds.
• There are individuals out there who refer to themselves as a “pathologists’ assistant” but have no credentials/certification as the professional title is not currently protected and can therefore be misused with little to no consequence.  These individuals can give a falsely negative view of the Pathologists’ Assistants profession.
• If an employer is hiring NAACLS-accredited, program-trained Pathologists’ Assistants, the graduating Pathologists’ Assistants all receive standardized training per accreditation standards.
• Newly graduated Pathologists’ Assistants may not be familiar with every single specimen as their training site may not have certain types of specimens available; however, new graduates and experienced Pathologists’ Assistants are able to adapt to site-specific submission requirements or pathologist-specific preferences.

“I don’t want to take another exam.”

No additional exam would be required.  Pathologists’ Assistants would need to continue to meet certification and ASCP BOC CMP requirements that they are already completing for recertification every three years.

“It’s not necessary, added bureaucracy.”

• VA example: the national laboratory director stated that Veterans’ affairs hospitals do not need to have a Pathologists’ Assistant category, as grossing is listed under the histotechnologist (HTL) category.  Per the HTL standard requirements, Pathologists’ Assistants would be excluded from the job postings as we are not certified as an HTL.  A director who is unaware of our profession would have specifically excluded Pathologists’ Assistants from performing gross examinations in their labs.
  
• Without licensure requirements, anyone who meets the CLIA requirements of associate degree can perform high complexity testing (aka gross examination) on all tissue types.
  
• Nothing is preventing someone from hiring an unqualified person with an associate degree from performing Pathologists’ Assistant level work. This has direct effects on:
  
  • Job security – grossing technicians filling open positions for “PAs”.
    
  • Salary averages – lower qualifications = lower pay, which yields an average lower salary for the Pathologists’ Assistant field resulting in lower wages overall.
    
  • Confusion on who we are/what our purpose is as professionals.
    
  • Due to confusion on who we are, we have little or no visibility to lab administrators, hospitals staff, and surgeons as we are grouped together with histology or clinical lab personnel.
    
  • Due to lack of required educational backgrounds or license requirements, we are often excluded from laboratory administrative positions by lab directors/human resources.
    
• Quality of care – patients whose tissues are handled by lesser qualified personnel have a higher likelihood of missed significant or unexpected findings (https://pubmed.ncbi.nlm.nih.gov/11764069/).

“It’s too expensive.”

Licensing fees are likely a lower cost than one might think, averaging less than $65 per renewal/year.

“I am an ASCP-certified Pathologists’ Assistant trained via the OJT route; how will this impact me?”

• Language on Pathologists’ Assistant educational pathways must be included in legislation to allow for:
  • ASCP-certified Pathologists’ Assistant trained via the OJT route
  • BS program-trained ASCP-certified Pathologists’ Assistants
  • MS program-trained Pathologists’ Assistants
  • ASCP BOC Certification maintenance requirements

“I am a travel Pathologists’ Assistant; how will this impact me?”

• A PA who is interested in doing travel work would have to be credentialed in the state they are applying to work in.  For example, if you wanted to take a travel PA position in the state of New York, the travel PA would have to apply for a New York State license as a PA.  As more states start licensing, there may be a possibility for states to start allowing for reciprocity between two states, but currently licenses are sparsely required.
• Obtaining a license is only different in that the applicant has to apply for the license based on their previously obtained credentials such as graduation from an accredited program and ASCP certification results/certification verification.  It is an extra application, but there is no additional exam or requirements other than providing the same credentials you would provide to an employer anyways.  These credentials are reviewed by a state board who understands the profession-specific requirements as opposed to a human resources staff member who has little knowledge of the profession or laboratory backgrounds.  This increases the likelihood of getting truly qualified candidates as opposed to applicants an HR representative might wrongfully accept or reject due to their unfamiliarity with the field.
• In states that require licensure, there is an added protection from fraudulent applicants as submitting false information violates licensing regulations and there are state penalties for the applicant.  These regulations protect employers who are hiring a Pathologists’ Assistant ensuring they are getting appropriately credentialed and qualified applicants.

“We need our biopsy/grossing technicians; how will this impact them?”

• Licensing of Pathologists’ Assistants should define what a Pathologists’ Assistant is and what they are capable of by including all gross examination and autopsy tasks that are within our Scope of Practice.
• Other personnel such as biopsy/grossing technicians can be distinctly defined with a separate and appropriate license or a “limited” license, which restricts their scope of work to a specified set of tissue types or CPT codes.  This “limited” license would include separate educational standards from those of a Pathologists’ Assistant.

In Florida, PAs are prohibited from cutting frozen sections and from becoming administrative laboratory directors.

• Scope of practice from 64B3-10.005 Scope of Practice Relative to Specialty of Licensure.
  “10) The purpose of the specialty of histology is to process cellular and tissue components through methods of fixation, dehydration, embedding, microtomy, frozen sectioning, staining, and other related procedures and techniques employed in the preparation of smears, slides, and tissues.  This specialty also encompasses methods for antigen detection and other molecular hybridization testing methods where the purpose is analysis and/or quantification of cellular and tissue components for interpretation by a qualified physician.  Technicians licensed in histology are limited to the performance of specimen processing, embedding, cutting, routine and special histologic staining, frozen sectioning, and mounting of preparations under the general supervision of a director, supervisor, or technologist.”
• In summary, Florida law states that a histotechnician/histotechnologist can perform frozen sections.
• If Florida added a Pathologists’ Assistant license, our scope of practice in their law could also include performing frozen sections, which would allow for overlap, but then include all other PA-specific tasks.
  • This would prevent Pathologists’ Assistants from being prohibited from performing frozen sections, but not take this task away from histology staff.

In Florida, the VA system was seeking a Physician Assistant and advertising that they will train them to gross specimens.

• When an AAPA member reached out to them to question the job posting, the director of the lab confirmed it was easier to advertise for someone completely unrelated and train them than it was to start from scratch and create a new position.

In Texas, health systems are removing Pathologists’ Assistants Allied Health Professional credentials because they are not licensed.

• This diminishes our profession and makes us less visible to health systems.
• Hides us from the eyes of other professionals as we are literally non-existent on paper/websites.
• Makes it more difficult to expand the field and be re-integrated into a field once we have been removed; we will have to work hard to recover.

Imposters

• Individuals have been able to use the title “pathologists’ assistant”, as the title is not licensed, which means anyone who wants to call themselves a Pathologists’ Assistant can and nothing is stopping them from doing so.  When an untoward event happens, the Pathologists’ Assistant profession receives negative press when the occurrence was associated with an imposter and not a certified Pathologists’ Assistant.

What about Pathologists’ Assistants who work in labs that are being bought out by large companies such as LabCorp who are losing privileges as they are grouped with “anyone who grosses” as opposed to being physician extenders.  Job titles are “Pathology assistant” vs. “pathology assistant – certified”, and both accrue PTO at the same rate as a lab assistant/entry level staff member.  Why not use the correct title?  Why not have a different title for grossing technicians?

• If a state were to implement licensing of PAs, anyone performing the tasks outlined in the legal scope of practice for a Pathologists’ Assistant would have to meet the qualification standards and be credentialed as a PA.  The license would protect the official title of “Pathologists’ Assistants”.  As an example, in the state of New York, anyone working in the medical laboratory has to be licensed.  Grossing falls under one of two licenses: histotechnician/technologist or Pathologists’ Assistant based on the level of complexity being handled.