State Operations Manual (Pub. 100-07), Ch. 6 § 6116.5
Credentialing of Foreign Trained Laboratory Personnel
6116.5 - Credentialing of Foreign Trained Laboratory Personnel
(Rev. 230; Issued: 07-11-25; Effective: 07-11-25; Implementation: 07-11-25)
Personnel employed in laboratories subject to CLIA that perform tests of moderate and/or
high complexity must meet specific education, training, and experience requirements.
Individuals who attended foreign schools must have an evaluation of their credentials
determining equivalency of foreign to United States education.
Nationally recognized evaluation organizations and their affiliates should perform the
academic credential evaluation on a course-by-course basis. Nationally recognized
evaluation organizations include but are not limited to the National Association
Credential Evaluation Services, Inc. (NACES) (http://www.naces.org) and the
Association of International Credential Evaluators, Inc. (AICE) (http://www.aice-
eval.org). Other organizations may be available and may be able to be confirmed through
research on the Internet (See Appendix C).
The laboratory should maintain a copy of the course-by-course foreign-trained
equivalency evaluation/determination in the laboratory records.
Laboratories may also choose to use a primary source verification company for verifying
foreign trained personnel, so long as the PSV relies on the same type of course-by-
course evaluation to confirm and document the foreign degree’s equivalency to the
personnel qualifications.
• Foreign trained personnel that have a PhD equivalent must hold current
HHS-approved board certification or meet the regulation at 42 CFR
§493.1405(b)(3) or 42 CFR §493.1443(b)(3).
• Foreign trained physicians (M.D., D.O., DDS) who are licensed to practice
medicine in the State in which the laboratory is located do not need to produce
educational equivalencies. A valid State medical license is sufficient proof of
academic achievement.
• With the exception of licensed physicians, other moderate and high
complexity testing personnel who attended a foreign school still need to
have foreign equivalencies done.
• Each person examining cytology slide preparations must meet the
qualifications of 42 CFR §493.1449(b) or (e) or 42 CFR §493.1483(a) and
(b)(1) or (b)(2) or (b)(3).