What Is CLIA Waived Testing and Who Can Perform It?

CLIA waived refers to a category of laboratory tests classified as simple enough that they carry a low risk of producing an incorrect result. The designation comes from the Clinical Laboratory Improvement Amendments of 1988 (CLIA), a federal law that regulates virtually all laboratory testing performed on human specimens in the United States. When a test is “CLIA waived,” it means the facility performing it faces the least regulatory burden of any lab testing category, needing only a basic certificate and compliance with the test manufacturer’s instructions.

How a Test Gets Waived Status

The FDA decides whether a test qualifies as waived by evaluating it against a scorecard with seven criteria: the knowledge needed to run it, the training and experience required, how reagents and materials are prepared, how complex the operational steps are, what calibration and quality control look like, how much troubleshooting and maintenance the equipment needs, and how much interpretation is involved in reading the results. Each criterion gets a score of 1, 2, or 3, with 1 representing the lowest complexity.

A test earns waived status through one of three paths. It may be specifically listed in the CLIA regulations as waived. It may be cleared by the FDA for home use, which automatically qualifies it. Or the manufacturer can apply directly to the FDA for a waiver, submitting scientific data showing the test meets the simplicity and accuracy criteria. In practice, waived tests tend to be self-contained kits where reagents come premeasured, steps are automatic or easy to control, and results require minimal judgment to interpret.

Common CLIA Waived Tests

The list of waived tests has grown substantially since 1988 and now includes hundreds of test systems. Some of the most widely used examples include:

  • Blood glucose monitoring using devices cleared for home use
  • Urine pregnancy tests read by visual color comparison
  • Rapid strep tests (streptococcus group A antigen detection by direct optical observation)
  • Urine dipstick testing for glucose, protein, pH, ketones, blood, and other markers
  • Fecal occult blood tests to screen for hidden blood in stool
  • Ovulation tests detecting luteinizing hormone by visual color comparison
  • Spun microhematocrit (a basic blood count measure)
  • Rapid drug screening tests using dipsticks, cups, or cartridges read by direct observation
  • Whole blood ketone tests
  • Erythrocyte sedimentation rate (non-automated)

HIV antibody rapid tests and prothrombin time monitors (used to manage blood-thinning medication) also have waived versions, which shows that “simple to perform” doesn’t necessarily mean “low stakes.” Erroneous results on these tests can directly affect medication dosing or carry serious personal consequences.

What You Need to Perform Waived Tests

Any facility that performs waived testing on human specimens, whether it’s a physician’s office, pharmacy, nursing home, or community health clinic, must obtain a Certificate of Waiver (CoW) from the Centers for Medicare and Medicaid Services (CMS). The application uses CMS Form 116, and the biennial certificate fee is $248 as of 2024.

The regulatory requirements that come with a Certificate of Waiver are intentionally light. The facility must follow the manufacturer’s instructions for each test, enroll in the CLIA program, and pay its certificate fees on time. That’s the core legal obligation. There are no mandated proficiency testing programs, no required personnel qualifications, and no routine inspections every two years like those required of moderate or high-complexity labs.

That said, CMS can still inspect a waived lab under certain circumstances: if someone files a complaint, if there’s evidence the facility is performing tests beyond the scope of its certificate, if there’s a risk of patient harm from inaccurate results, or if CMS needs to gather information about waived testing practices generally.

How Waived Differs From Moderate and High Complexity

CLIA sorts all lab tests into three tiers: waived, moderate complexity, and high complexity. The difference isn’t just about how hard the test is to run. It determines the entire regulatory framework a lab operates under.

Moderate and high-complexity labs must meet detailed standards for personnel qualifications, quality control, proficiency testing, and patient test management. They’re subject to routine surveys every two years. Staff performing those tests must meet specific education and training thresholds, and labs must formally assess each employee’s competency on an ongoing basis.

Waived labs skip nearly all of that. CLIA does not require competency assessments for staff performing waived tests, does not mandate specific educational credentials, and does not impose routine survey schedules. The tradeoff is that waived labs can only perform the tests on their certificate. Running a moderate-complexity test under a Certificate of Waiver is a compliance violation that can trigger an inspection.

Quality Practices That Still Matter

Because the regulatory bar is low, it can be tempting to treat waived testing as foolproof. It isn’t. The CDC has published detailed guidance on good laboratory practices for waived testing sites, and the recommendations go well beyond what CLIA legally requires.

Running control tests and documenting the results gives you evidence that the test system, meaning the reagents, instruments, and operator, performed as expected. Control results should be reviewed periodically to catch gradual shifts in performance that might not be obvious on any single day. All testing records, including problems and how they were corrected, should be kept in chronological order so they’re easy to retrieve.

For tests with qualitative results (positive or negative rather than a number), the CDC recommends recording outcomes using words like “positive,” “negative,” “reactive,” or “nonreactive” rather than plus and minus symbols. The reason is practical: a handwritten minus sign is easily altered to look like a plus sign, and that kind of clerical error can change a patient’s care.

Training matters, too. While CLIA doesn’t mandate formal competency assessments for waived testing personnel, it does require that all staff be properly trained and follow the manufacturer’s instructions. Labs holding a Certificate of Waiver are still responsible for making sure every person running a test has been oriented and knows exactly how to perform it correctly.

Why the Distinction Matters for Patients

If you’ve ever had a rapid strep test at an urgent care clinic, checked your blood sugar with a home monitor, or taken a home pregnancy test, you’ve used a CLIA waived test. The waived category exists to make simple, reliable testing widely available without burying small offices and clinics in regulatory overhead that was designed for hospital laboratories running thousands of complex assays.

The system works when facilities take the “simple” classification seriously and follow manufacturers’ instructions to the letter. Where problems arise is when staff skip steps, use expired reagents, store test kits improperly, or never run quality control checks. The test itself may be low-complexity, but the result still drives real clinical decisions, from adjusting a blood thinner dose to diagnosing an infection to confirming a pregnancy.