The University Professional and Technical Employees – Communication Workers of America Local 9119 represents 15,000 Professional and Technical titles at the 10 campuses and 5 medical centers at UC. We respectfully oppose AB 2281 by Assembly Member Jacqui Irwin. AB 2281 would allow medical laboratory technicians (MLTs) to perform a series of tests of moderate complexity such as blood smear reviews, microscopic urinalysis, ABO/rh testing and antibody screening. We believe these tests belong in the Clinical Lab Scientists’ (CLS) scope of practice.

CLS’s have to complete rigorous coursework to obtain a bachelor’s degree in science before applying to obtain a CLS trainee license, which is required to apply to a CLS training program. This one-year internship at an approved training program contains a didactic portion as well as hands-on training in all of the departments of the laboratory. Not only do CLS’s have background knowledge from various college courses but during these internships, CLS’s and, at times, pathologists, give CLS trainees lectures relating the completed courses to the various tests that CLS’s will perform as license-holders, and how each test result is related to the health of the patient. Upon completion of all coursework and the one-year internship, CLS’s are eligible to sit for a licensure exam administered by the American Society for Clinical Pathology.

Educational requirements to become a Medical Laboratory Technician (MLT) are significantly less rigorous. MLTs are only required to obtain an associate’s degree and 6 months of training; half of what is required for CLS’s. The training program includes 2 semesters of didactic and only one semester of clinical rotations.

In a clinical laboratory, tests are categorized as waived, moderate, and high complexity.  Our CLS membership maintain that there is a fine line between when a test moves from moderate complexity to high complexity, especially in the departments of Hematology (the study of the blood) and Blood Bank. Increasing the scope of practice for MLTs to include more complex tests like a blood smear, ABO/Rh, and antibody testing would be inappropriate because the current levels of education, skill, and training that are mandated for MLTs do not adequately prepare them to perform these tests.  Incorrect readings of these tests could have dire results for patients.

We acknowledge that potential staffing shortages in labs are a real concern across the State. That is why our organizations strongly support the idea of creating more CLS training programs, such as what is being started at UCSF.  We believe that lowering the educational bar for moderate complexity testing is not the solution. California has always been held to a higher standard of patient care, and for good reason. AB 2281 is a misguided attempt to solve a potential problem of Clinical Laboratory Scientist shortages by expanding scope of practice where it should not be expanded.

Lab tests such as blood smear reviews, microscopic urinalysis, blood typing and anti-body screening require a certain amount of discretionary judgment. We believe that these tests are best performed by licensed professionals who are properly educated, trained, and experienced. In our view, it’s the CLS that best serves the patient here.

This bill jeopardizes patient care for the benefit of employers looking to use cheaper labor costs, at the patients’ risk. On behalf of CLS’s at all of UPTE’s represented labs and clinics, and for the above reasons, we ask that you oppose AB 2281.

Tell Members of the California State Senate: Vote NO on AB 2281

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