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Published on: April 21, 2022
Waived semen analyzers in clinical practice: analytical standards, regulatory categorization, and the limits of
David H McCulloh1,2,3, Jeff Boldt4, Charles H Muller5
1Department of Obstetrics and Gynecology, Grossman School of Medicine, New York University, New York, United States. dhmcculloh@gmail.com.
Background:
The award of Clinical Laboratory Improvement Amendment (CLIA)-waived status to automated semen analyzers, including the LensHooke (Bonraybio) and SQA-iOw (Medical Electronic Systems), has prompted substantive debate regarding analytic adequacy, regulatory classification, and appropriate clinical use.
Objective:
To synthesize academic and industry perspectives on the analytical standards, regulatory categorization, and clinical deployment of waived automated semen analyzers, and to provide practical guidance on laboratory validation.
Evidence Review:
We reviewed peer-reviewed publications evaluating the SQA-V and SQA-iOw, the United States (US) Food and Drug Administration's (FDA's) 510(k) and CLIA waiver documentation, the US Centers for Medicaid and Medicare Services (CMS) CPT transmittals, the College of American Pathologists (CAP) Reproductive Lab Medicine Checklist requirements, and World Health Organization (WHO) Laboratory Manual guidance on computer-assisted semen analysis.
Conclusions:
Waived semen analyzers offer genuine advantages in workflow efficiency and intra-instrument reproducibility and are appropriate for preliminary assessment of major male factor causes of infertility. Documented limitations in morphology accuracy near the 4% Tygerberg threshold, motility detection at low values, and handling of complex samples make them insufficient as stand-alone replacements for qualified manual analysis in high-stakes contexts including azoospermia determination and pharmacologic research as well as studies on infertility pathophysiology and diagnosis, and fertility prognosis. The scope of the CLIA waivers is settled; the applicable CPT billing codes remain unresolved and require professional society engagement with the American Medical Association's (AMA's) CPT Editorial Panel. Laboratory validation is a professional obligation regardless of CLIA complexity level and is also required internationally by ISO 15189.
