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- CMS action on remote sign-out raises questions. Here are the answers
The Centers for Medicare and Medicaid Services (CMS) is ending its enforcement discretion for remote review of digital images of cytology slides on March 23, 2026.
- Previously, CMS discontinued its enforcement discretion for review of glass slides in 2023.
- Per CLIA statute, it is required that "all cytological screening be done on the premises of a laboratory that is certified," meaning the updated guidance corresponds with the law.
Questions and answers
What is "remote review"?
Electronic review of digital images by qualified personnel under CLIA from a location that is NOT considered part of the main laboratory (eg, pathologist's home or an offsite location).
If I am currently remotely reviewing digital cytology slides, what do I need to do to prepare for this change?
CMS will require that laboratories that want to continue reviewing digital images of cytology slides at a remote location after March 23, 2026, obtain a CLIA certificate for that location, separate from the main laboratory.
How long do I have before I must be in compliance with this guidance?
Per the CMS, labs have six months from the issue date of the memorandum to comply. Laboratories must have an additional CLIA certificate for each location outside of the main laboratory by March 23, 2026, if they want to continue remote review of digital cytology images.
We currently remotely review digital surgical pathology slides; will we be out of compliance if we continue?
No, the updated guidance only applies to remote review of cytology digital slides.
Go deeper: Read the CAP’s Remote Sign-Out FAQs.