College of American Pathologists
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  Licensure—status in the states and scope of


CAP Today




August 2010

Rodolfo Laucirica, MD

Cytotechnologists are clinical laboratory professionals who play invaluable roles in laboratory medicine. Their scope of practice includes serving as consultants to pathologists when they evaluate cervicovaginal and nongynecologic cytological samples, assisting in superficial and deep fine-needle aspiration biopsies, educating cytotechnology students and pathology residents and fellows, implementing and evaluating quality assurance procedures, and validating new testing methods and instruments. More recently, as novel technologies have translated into clinical practice, they have become involved with ancillary tests such as immunocytochemistry, in situ hybridization, and amplified nucleic acid detection. After training in a CAHEEP-approved program and receiving either a bachelor’s degree or master’s degree, cytotechnologists are tested by and receive certification from the American Society for Clinical Pathology. However, over the past several years there have been discussions about and state governmental action toward state licensure requirements for cytotechnologists.

Currently, state licensure or certification requirements for cytotechnologists exist in California, Florida, Hawaii, Louisiana, Nevada, New York, Rhode Island, Tennessee, West Virginia, and Puerto Rico. In the past several years six states have considered licensure legislation for laboratory personnel: Illinois, Massachusetts, Minnesota, Missouri, Iowa, and Texas.

To address the issue of state licensure for cytotechnologists, the American Society of Cytopathology conducted a survey in 2005 to determine the relevance of this issue to its members.1 Of the 317 respondents, 49 percent were opposed to state licensure, 34 percent were in favor, and 16 percent were undecided. Those who supported state licensure believed it would raise the level of professionalism for cytotechnologists and provide a means to prevent improperly trained or incompetent cytotechnologists from working in a particular state. Those who opposed state licensure cited licensure costs, inability of licensure to ensure patient safety, and restriction of scope of practice as some of the reasons.

A white paper commissioned by the ASC and posted on its Web site, “Facing the Future of Cytopathology: Discerning the Future Needs of Our Profession,”2 addressed state licensure. This study cites the 2005 ASC survey and raises the problem of licensure and the lack of language regarding the scope of practice for cytotechnologists. For example, cytotechnologists cannot perform molecular tests in California3 and are not involved in ancillary technologies such as human papillomavirus testing in Florida and Tennessee. The laws in these states have barred cytotechnologists from performing these tests because no language was inserted to allow them to do so. Other articles dealing with state licensure of cytotechnologists4,5 also raised the problem of defining the scope of practice for cytotechnologists.

In December 2008, the CAP published model criteria for state licensure of clinical laboratory personnel as a means to clarify the scope of practice for clinical laboratory personnel and their relationship with the laboratory director. Working with the ASC, the CAP inserted a statement into the model criteria directed at the role of cytotechnologists in the clinical laboratory: “Nothing contained in this (licensure) act shall be construed as a limitation on the scope of work performed by cytotechnologists who are qualified under CLIA.”6

The CAP supports the role of cytotechnologists in the clinical laboratory and regards the need for state licensure for cytotechnologists as unnecessary. Continued dialogue between the CAP, ASC, and other societies, such as the ASCP and the American Society for Cytotechnology, may better define the scope of practice for cytotechnologists. Finally, cytotechnologists need to be vigilant and vociferous advocates for their specialty. By working with state pathology societies and contacting state legislators, cytotechnologists can have a voice in the legislative process and thereby help to define their role in health care now and in the future.


  1. ASC Cytotechnologist scope of practice. November 2006. Available at
  2. Facing the future of cytopathology: Dis-cerning the future needs of our profession. January 2010. Available at
  3. CA lab personnel law—time for a change? Stakeholders’ meeting. Laboratory Field Services, California Department of Public Health. Aug. 24, 2009.
  4. Crothers BA. Licensing your livelihood: state-mandated cytotechnologist licensure. ASC Bulletin. 2005;52:49–50, 52.
  5. Moriarty AT, DuBray-Benstein B. The upsides and downsides of state licensure for cytotechnologists. CAP TODAY. January 2005, pp. 58, 60.
  6. CAP model criteria for state licensure of clinical laboratory personnel. August 2009. Available

Dr. Laucirica, a member of the CAP Cytopathology Committee, is associate professor and director of the cytopathology fellowship program at Baylor College of Medicine and director of anatomic pathology and cytopathology at Ben Taub Hospital, Houston. He is president of the Texas Society of Pathologists.