Department Circular No. 2021 – 0511

 29 October 2021

CLARIFICATIONS ON THE ROLES AND FUNCTIONS OF REGISTERED RESPIRATORY THERAPISTS, REGISTERED MEDICAL TECHNOLOGISTS AND HEAD OF CLINICAL LABORATORY

Administrative Order No. 2021 – 0037, titled, “New Rules and Regulations Governing the Regulation of Clinical Laboratories in the Philippines,” was issued on June 11, 2021, published on July 7, 2021, and took effect on July 22, 2021. Section V.F. of the General Guidelines states that “Unit/Section of health facilities performing diagnostic CL (Clinical Laboratory) tests such as, but not limited to, arterial blood gas and/or Radioimmunoassay for thyroid function tests and Prostate Specific Antigen shall be under the DOH–licensed CL.”

Arterial Blood Gas (ABG), being vital in the critical management of patients, is usually performed as Point of Care Testing (POCT). Processing of the specimen is usually done either in the Pulmonary Laboratory or in the main Clinical Laboratory. Respiratory Therapists, based on their law, Republic Act No. 10024, titled, “An Act Regulating the Practice of Respiratory Therapy, creating a Professional Regulatory Board of Respiratory Therapy, Appropriating Funds Therefor and for Other Purposes,” issued on March 9, 2010, contended that it is their domain and should not be under the Clinical Laboratory.

However, Section 1 of Republic Act (R.A.) 4688 titled, “An Act Regulating the Operation and Maintenance of Clinical Laboratories and Requiring Registration of the Same with the Department of Health, Providing Penalty for the Violation Thereof, and for Other Purposes,” specifically states that, “Any person, firm or corporation, operating and maintaining a clinical laboratory in which body fluids, tissues, secretions, excretions and radioactivity from being or animals are analyzed for the determination of the presence of pathologic organisms, processes and/or conditions in the person or animals from which they are obtained, shall register and secure a license annually at the office of the Secretary of Health.”

The following guidelines are being issued to clarify the roles of the relevant personnel, namely the Respiratory Therapist Registered in the Philippines (RTRP), Registered Medical Technologist (RMT), Head of Clinical Laboratory (HOCL):

1. Extraction of blood for ABG analysis shall either be done by professionally trained personnel such as Medical Doctor (MD), Respiratory Therapist Registered in the Philippines (RTRP) and Registered Medical Technologist (RMT). 

2. Processing of specimen for ABG analysis can either be done at the Respiratory/Pulmonary Unit by the RTRP, as Point–of–care testing (POCT), or at the CL by the RMT.

3. ABG result shall be interpreted by the patient’s attending Physicians and referred to the Pulmonologist, as the nee arises.

4. The Head of the CL shall exercise oversight functions on the section of the Respiratory/Pulmonary Unit that analyzes/processes the ABG, which include but not limited to, quality control of equipment/instrument and supplies.

5. All results whether processed at the Respiratory/Pulmonary Unit as POCT or at the main CL, shall be signed by the Head of the Clinical Laboratory or the designated Associate Clinical Pathologists, in the absence of HOCL.

6. Releasing of official results shall be done by the unit/section which processed the tests (Clinical Laboratory or Respiratory/Pulmonary Unit).

For strict compliance and dissemination.

 

ATTY. CHARADE B MERCADO – GRANDE

Undersecretary of Health

Health Regulation Team

 

(There should also be a distinction between the Radioimmunoassay done in the Clinical Laboratory to the Radioimmunoassay done in Nuclear Medicine. Both are performed by RMT but signed by Endocrinologist in the Nuclear Medicine and by a Pathologist in a CL)