Dermatologists can no longer direct their own dermpath labs. YAY!!!

[KeratinPearls]

Wanted to spice up this forum a little more. Headed over to the Derm forum and read this….saw a similar post on Reddit until it was taken down by a dermatologist who asked if it was possible to start his/her lab without hiring a pathologist. The post was eventually taken down after some backlash.

This is a small win for pathologists.



“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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[SunBakedTrash]

It’s crazy but unsurprising to see dermatology completely eroded away by greed. The PE takeover and actions like this serve to show how quickly things can implode. They may not feel the full effect yet, but they will.

 

[Alteran]

The Stark laws were so poorly written for AP that you could have driven a 747 through them. It’s nice to see that decades later issues we’ve as pathologists have been concerned about are finally starting to be addressed, albeit slowly and piecemeal. It of course doesn’t help those whose entire careers spanned the decades of abuse, but it at least helps the future generations of pathologists.

This ultimately though I don’t think will have a major impact on us as we might like to think. Dermpath was the last “profitable” pod lab gimmick. GI and GU pod lab models were completely hollowed out by the 88305 technical apocalypse over a decade ago. Derm only worked because they could double dip in the professional (reading the slides) and also getting the technical. Now that they can’t do the technical, how can they even do the professional component? And even though this looks like a golden opportunity for pathologists to become medical directors of these labs (and hopefully not for cheap), what’s probably going to happen is a total divestment of Derm pod labs and all the work going to the Quests, LabCorps, and other bottom dollar labs where pathologists are already treated as cheap labor by our own kind.

 

[KeratinPearls]

POD labs are a joke and driven by greed, extra cash and exploitation of pathologists. I had to work in one for one of my previous jobs. I talked to a urologist once in three years. The diagnosis of malignancy was called in just like if the pathology was done in a pathology lab (not a pod lab). Has no effect on patient care. Only puts money into urologists pockets. The group was eventually bought out by Solaris (private equity). Not sure if we lost that account since I left that job.

 

[KeratinPearls]

The Stark laws were so poorly written for AP that you could have driven a 747 through them. It’s nice to see that decades later issues we’ve as pathologists have been concerned about are finally starting to be addressed, albeit slowly and piecemeal. It of course doesn’t help those whose entire careers spanned the decades of abuse, but it at least helps the future generations of pathologists.

This ultimately though I don’t think will have a major impact on us as we might like to think. Dermpath was the last “profitable” pod lab gimmick. GI and GU pod lab models were completely hollowed out by the 88305 technical apocalypse over a decade ago. Derm only worked because they could double dip in the professional (reading the slides) and also getting the technical. Now that they can’t do the technical, how can they even do the professional component? And even though this looks like a golden opportunity for pathologists to become medical directors of these labs (and hopefully not for cheap), what’s probably going to happen is a total divestment of Derm pod labs and all the work going to the Quests, LabCorps, and other bottom dollar labs where pathologists are already treated as cheap labor by our own kind.

They can still do the technical. They just need to hire a pathologist to supervise the lab I believe.

 

[Alteran]

They can still do the technical. They just need to hire a pathologist to supervise the lab I believe.

Correct and hopefully pathologists will realize they can get paid well into the 6 figures for that responsibility, especially for super busy Derm labs that acquire enough skin in one day to make a Buffalo bill outfit. Also, in my reading of the new rule:

• One year directing or supervising nonwaived testing

How does that work? If they’re not the director, how do they get to supervise or direct unless delegated functions count? It may sound good on paper but be functionally impractical for a non-Pathology boarded MD to achieve perhaps.

Edit: I’m happy to be corrected on this point, but I don’t think Histology alone is considered high-complexity testing by CLIA.

 

[HeyDalaron]

Do you think that pathologists that pursue dermatopathology are less likely to accept suboptimal payment structures than other pathologists?

 

[coroner]

Can't high complexity lab directors still be pHD's? Or does the above apply specifically for AP labs and medical directors must be pathologists?

High Complexity Testing Requirements​

Requirements for supervising and running a high-complexity testing labs were updated by CMS in December 2024. Below is a summary of the key updates.

1. Doctoral Degrees (PhD/DCLS):If a candidate has earned a doctoral degree in fields like chemistry, biology, clinical laboratory science, medical laboratory science (MLS), or medical technology (MT), the individual qualifies as long as they meet the following criteria:
   • Board certification from an HHS-approved body.
   • At least one year of experience supervising or directing non-waived lab testing.
   • 20 continuing education (CE) credits related to laboratory director duties.
   • Finally, those without a relevant doctoral degree must also have completed 16 semester hours of doctoral-level coursework in biology, chemistry, medical technology, or related fields.
2. MDs/DOs: For medical doctors (MDs) and doctors of osteopathy (DOs), requirements were streamlined. Individuals may be board-certified in pathology (ABP) or by the American Osteopathic Board of Pathology (AOBP), with recognized equivalency qualifications now removed as a qualification. If they don’t have that certification but have experience directing or supervising high-complexity testing for two years, plus 20 CE credits, they can still qualify.

 

[Alteran]

Absolutely. But I think histology doesn’t fall under high-complexity (or any type of complexity under CLIA) as it is considered test preparation, not an actual test. So by that logic, just being affiliated with a histology only lab to meet the experience requirement won’t work. And it is completely impractical to have a non-pathologist be affiliated as a director or designee for a traditional laboratory that does high-complexity testing.

I do honestly think all POD lab models are now effectively kaput.

Do you think that pathologists that pursue dermatopathology are less likely to accept suboptimal payment structures than other pathologists?

ABSOLUTELY. Just try to hire a Dermpath and you’ll see for yourself.

 

[KeratinPearls]

Do you think that pathologists that pursue dermatopathology are less likely to accept suboptimal payment structures than other pathologists?

Ask yourself this question.

“Do you think people that go into derm or dermpath truly love skin or do they love the money?” If Derm and Dermpath made 250k a year like starting path in academia would it still be competitive to get into? The answer is no but the true skin geeks would still go into it for the pure love of skin.

That’s the answer to your question if dermpaths would take suboptimal pay.

 

[Dral]

Ask yourself this question.

“Do you think people that go into derm or dermpath truly love skin or do they love the money?” If Derm and Dermpath made 250k a year like starting path in academia would it still be competitive to get into? The answer is no but the true skin geeks would still go into it for the pure love of skin.

That’s the answer to your question if dermpaths would take suboptimal pay.

True. Just over the not so long I've been in practice, I've seen apps for dermpath change over the years. I don't have data to back it up, but in my experience, it follows the numbers (jobs and money). Mohs apps always seem to be up due to the money and the fact that there is no longer a back door in.