Position Statement And Legislative Guidelines On State Licensure For Cytotechnologists

ASC Position Statement And Legislative Guidelines On State Licensure For Cytotechnologists


The American Society of Cytopathology (ASC) is a distinguished professional society of physicians, cytotechnologists and scientists who are dedicated to the cytologic method of disease detection and prevention.  The ASC’s diverse membership of more than 3500 individuals includes representatives from the US and other countries who share a vision of education, research and continuous improvement to enhance the standards and quality of patient care as applicable to cytopathology.

The ASC neither advocates for nor against licensure for cytotechnologists or other laboratory professionals. If licensure is considered by individual states, the ASC emphasizes the following:

  • Cytotechnologists should have a voice in the legislative process.   
  • State licensure should not include any limits on the scope of practice for qualified cytotechnologists, and should be consistent with the scope of practice as defined under Clinical Laboratory Improvement Act (CLIA).
  • Reciprocity for state licensure is desirable and encouraged. If an individual has already obtained a license in another state, we recommend that the state consider an expedited process of licensure that accepts the documentation and confirmation of licenses/certificates from the other state.
  • ASCP Board of Certification in cytotechnology should be accepted as the equivalent of a state examination documenting proficiency in practice.
  • State legislatures are encouraged to follow the guidelines below in developing their laws and regulations concerning licensure. 


In recognition of the importance of active involvement in state affairs concerning our profession, the ASC encourages its members to urge state legislatures to consider the following guidelines as model language to describe the qualifications and practice of cytotechnologists.  These guidelines were first developed in 2006 by an ad hoc task force comprised of the Legislative and Regulatory Proceedings Committee, in conjunction with the former Cytotechnologist Advisory Committee, and were reviewed and revised/updated in 2011 by the Economic and Government Affairs Committee.

Definition of “Cytotechnologist/ Cytologist”

“Cytotechnologist/Cytologist”: A clinical laboratory professional specializing in the analysis of cellular material from patient specimens for the purpose of diagnosing and monitoring disease, evaluating risk of disease, and guiding or monitoring therapy. These specialists assist with the collection and preparation of specimens, and detection and interpretation of normal and abnormal cells, as well as infectious agents using a variety of techniques that include but are not limited to microscopic cytomorphology, special stains, immunocytochemistry and molecular techniques. In addition, these individuals may be responsible for all activities related to the pre-analytic, analytic, and post-analytic phases of testing including, but not limited to test selection and development, equipment selection, operation and maintenance, result reporting, quality control and assurance and statistical analysis of performance. The Cytotechnologist may also have a supervisory or educational role.

Recommended Minimal Requirements for Qualification as a Cytotechnologist

This language is adopted, verbatim, from the Clinical Laboratory Improvement Amendments of 1988, Final Rules, Federal Register, Vol 57(40): 28 February 1992.

  1. Individuals that meet one of the following qualifications may be licensed as a cytotechnologist / cytologist:
    • Have graduated from a school of cytotechnology accredited by Commission on Accreditation of Allied Health Programs (CAAHEP); prior to 1996, have graduated from a school of cytotechnology accredited by the Committee on Allied Health Education and Accreditation (CAHEA); or
    • Be certified in cytotechnology by a certifying agency approved by Health and Human Services (HHS); or
    • Before September 1, 1992-
      • Have successfully completed 2 years in an accredited institution with at least 12 semester hours in science, 8 hours of which are in biology, and
        • Have had 12 months of training in a school of cytotechnology accredited by an accrediting agency approved by HHS, or
        • Have received 6 months of formal training in a school of cytotechnology accredited b y an accrediting agency approved by HHS and 6 months of full-time experience in cytotechnology in a laboratory acceptable to the pathologist who directed the formal 6 months of training, or
      • Have achieved a satisfactory grade to qualify as a cytotechnologist in a proficiency examination approved by HHS and designated to qualify persons as cytotechnologists, or
    • Before September 1, 1992, have full-time experience of at least 2 years or equivalent within the preceding 5 years examining slide preparations under the supervision of a pathologist and before January 1, 1960, must have
      • Graduated from high school; and
      • Completed 6 months of training in cytotechnology in a laboratory directed by a pathologist or other physician providing cytology services; and
      • Completed 2 years of full-time supervised experience in cytotechnology; or
    • On or before September 1, 1993, have full-time experience of at least 2 years or equivalent examining cytology preparations within the preceding 5 years in the United States under the supervision of a pathologist; and
      • On or before September 1, 1994, have met the requirements in either paragraph 1a or 1b of this section
  2. Individuals that meet one of the following qualifications may be licensed as a Cytology Supervisor:
    • Be qualified as a cytotechnologist under the conditions in paragraph 1 above, and
    • Have at least 3 years of full- time experience (2,080 hours per year) as a cytotechnologist in the preceding 10 years.


Proposed Scope of Practice for Cytotechnologists

  1. Technical:
    • Assist in the collection of patient specimens and specimen evaluations
    • Select the most appropriate preparation and staining techniques for the specimen and for diseases in the differential diagnosis.
    • Prepare and evaluate stains and other testing reagents according to standard operating procedures.
    • Prepare patient specimens according to standard operating procedures for ancillary testing, including but not limited to in situ hybridization, immunocytochemistry, and amplified nucleic acid detection, and other molecular tests.
    • Exercise independent technical judgment subject to the supervision, control, responsibility, and direction by the laboratory director.
  2. Interpretation:
    • Evaluate, mark and interpret representative areas of benign and abnormal processes observed microscopically in patient specimens, manually or with automated instruments.
    • Evaluate, and correlate ancillary studies such as cellblocks, molecular tests and immunocytochemistry.
  3. Reporting
    • Use the laboratory information system or other method to report patient results according to established guidelines.
  4. Quality Assurance
    • Establish basic quality control and quality assurance procedures on equipment, stains, ancillary tests and reagents; evaluate the results of quality control and implement corrective action as needed.
    • Validate new testing methods and equipment and perform comparison studies between new and existing procedures to determine the performance specifications compared to manufacturers’ claims.
    • Operate, calibrate, and conduct periodic performance checks and maintenance on laboratory equipment and instrumentation related to all cellular based testing.
    • Troubleshoot instrument malfunctions.
  5. Management
    • Write laboratory standard operating procedures.
    • Perform orientation and supervision for students, laboratory assistants, cytology processing technicians and new or less skilled laboratory personnel.
    • Establish and monitor laboratory safety programs in compliance with regulations.

Proposed Scope of Practice for Cytology Supervisors

All components of Scope of practice for cytotechnologist in addition to:

  1. Personnel Management and Supervision:
    • Provide supervision of cytotechnologists, cytopreparatory technicians and support staff assigned to the department.
    • Train the above-mentioned employees and assess periodically for competency.
    •  Investigate and test new methodologies and instrumentation that is applicable for primary interpretation and ancillary testing.
    • Perform all aspects of personnel management including, but not limited to establishment of daily working and training schedules, approval and monitoring of time off, preparation of employee evaluations, employee counseling, writing job descriptions, hiring and firing activities, interviewing candidates, and resolving personnel conflicts.
  2. Compliance
    • Develop and maintain policy and procedure manuals, as well as performance improvement plans.
    • Ensure adherence to federal, state, and local regulations, the published practice guidelines, and the laboratory compliance program.
    • Provide inventory control and management.
    • Ensure compliance with fire, safety and disaster guidelines.
    • Serve as diagnostic consultant for diagnostic dilemmas.
    • Oversee activities for inspections by accrediting agencies.
  3. Technical: Exercise independent technical judgment subject to the supervision, control, responsibility, and direction by the laboratory director.
  4. Budget:  Prepare budgets to meet financial objectives, including purchase of supplies and new equipment and staffing according to organizational benchmarks.
  5. Client Service: Provide advice and information to clinicians regarding utilization, test ordering, specimen collection and processing, use of special studies, and released test results, recognizing that only pathologists exercise independent medical judgment in the diagnosis and treatment decisions related to clinical laboratory tests.
  6. Research and Development:  Implemention, assist with and evaluate research and development projects as directed by pathologists.

Proposed Continuing Educational Requirements for Cytotechnologists and Cytology Supervisors

These guidelines are adopted from the recommendations of the American Society for Clinical Pathology (ASCP) Board of Certification available at: http://www.ascp.org/bor/cmp/

  • Total continuing education (CE) points required every 3 years: 36 (12 hours annually, where 1 point = 1 credit hour)
  • Special CE requirements each 3-year period:
    • 1 point in laboratory safety
    • 2 points in area of certification (e.g. cytology)
    • Remaining points in area of specialty, management, education or other related laboratory areas of interest


Original Document Reviewed and Approved by Executive Board November 7, 2006
Revised Document Reviewed and Approved by ASC Executive Board December 2, 2011