Click HERE to download the final letter to California Department of Human Services.
The proposed rules that will govern embryology practice in California are being offered for public comments.
ACE (referred as “College” thereafter) generally supports this initiative as a move which will over time facilitate creating minimum standards in embryology practice.
The College is in the process of submitting its comments to address several areas of the proposed rules including the following:
1. Proposed rules will require 30 semester hrs of post baccalaureate education in biology or embryology.
2. Proposed rules will require that an applicant for directorship position should complete several years of training in the approved ART facility to be eligible for the license.
It is not clear whether those who already passed the examination for ELD or HCLD will be disqualified to continue practice in their current capacity because they came short on credit hours or did not train in the approved ART facility.
ACE will recommend grandfathering routes for those individuals to enable them to qualify for the California oral examination and become licensed.
In this regard, ACE plans to recommend: 1) An exemption for ART practitioners who have accumulated several years of experience in the US based IVF laboratory by the time the rules become final, 2) Clarify the criteria for the approved program selection.
The full text of comments by the College will be distributed to ACE newsletter subscribers once its is submitted to the California Department of Health.
You may submit your comments directly to California Department of Health or if you like those to be included in a letter sent by the College then email by September 15th, 2010 to: contact@embcol.org.
The deadline established by California Department of Health is September 27th, 2010.
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