CLIA Rule Change – Impact on Derm-Trained Dermpaths & Mohs Surgeons Finishing in 2025+

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Dermanently

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I recently came across the CLIA rule change that took effect on December 28, 2024, which removes the American Board of Dermatology (ABD) as an equivalent qualification to pathology training for serving as a lab director (LD) of a high-complexity lab (e.g., dermatopathology, immunodermatology, Mohs).

From what I understand, under the new rule, individuals who are not board-certified by the American Board of Pathology (ABPath) or American Osteopathic Board of Pathology (AOBPath) must now have:

• At least two years of experience supervising high-complexity testing
• At least 20 CE credit hours relevant to lab directorship

Previously, derm-trained dermpaths and Mohs surgeons could qualify to direct a lab with ABD certification alone, but it looks like that is no longer the case.

For those of us finishing dermpath and Mohs fellowships in 2025 and beyond (derm-trained, not path-trained when it comes to dermpath), what are the practical implications of this change?

• Will this significantly delay the ability of derm-trained dermpaths to run their own in-house labs, since they now need two years of supervisory experience?
• Are there potential workarounds, like getting designated as a technical supervisor first, or do we need to rely on path-trained colleagues to serve as lab directors initially?
• How will this impact Mohs surgeons setting up their own histology labs after fellowship? Will they now need to hire a separate lab director?

Curious to hear thoughts from those who have looked into this or are already navigating it.

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No one knows. In the case of Mohs, if you have been a lab director for the last two years prior to this going into effect you will be grandfathered in. If you don’t fall into this category the path forward has not been determined. They are going to be discussing this at the mohs meeting next month.
 
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