Clinical Laboratory Technology

Cytotechnologist & Certified Histological Technician License Requirements

General Requirements

The practice of cytotechnology and the use of the title "cytotechnologist" or "certified histological technician" require licensure, unless otherwise exempt under the law.

To be licensed as a cytotechnologist or certified histological technician in New York State you must:

• be of good moral character;
• be at least 18 years of age;
• meet education requirements (if required);
• meet examination requirements (if required); and
• meet experience requirements (for licensure by grandparenting only).

You must file an application for licensure and the other forms indicated, along with the appropriate fee, to the Office of the Professions at the address specified on each form. It is your responsibility to follow up with anyone you have asked to send us material.

The specific requirements for licensure are contained in Title 8, Article 165 of New York's Education Law and Sections 52.39 and 52.41 and Subparts 79-14 and 79-16 of the Regulations of the Commissioner of Education.

You should also read the general licensing information applicable for all professions.

Fees

The licensure and first registration fee for a cytotechnologist is $371.

The licensure and first registration fee for a certified histological technician is $263.

The limited permit fee for a cytotechnologist and certified histological technician is $50.

Fees are subject to change. The fee due is the one in law when your application is received (unless fees are increased retroactively). You will be billed for the difference if fees have been increased.

• Do not send cash.
• Make your personal check or money order payable to the New York State Education Department. Your cancelled check is your receipt.
• Mail your application and fee to:

  NYS Education Department
  Office of the Professions
  PO Box 22063
  Albany, NY 12201

Partial Refunds

Individuals who withdraw their licensure application may be entitled to a partial refund.

• For the procedure to withdraw your application, contact the Clinical Laboratory Technology Unit by e-mailing opunit6@mail.nysed.gov or by calling 518-474-3817 ext. 592 or by faxing 518-402-2323.
• The State Education Department is not responsible for any fees paid to an outside testing or credentials verification agency.

If you withdraw your application, obtain a refund, and then decide to seek New York State licensure at a later date, you will be considered a new applicant, and you will be required to pay the licensure and registration fees and meet the licensure requirements in place at the time you reapply.

Definitions of Common Terms

Accredited (or accredited by an acceptable accrediting agency) means accredited by an organization accepted by the Department as a reliable authority for the purpose of accrediting cytotechnology or certified histological technician programs on a national or regional basis, as having reasonable accreditation standards, and as an organization that applies its criteria for granting accreditation of programs in a fair, consistent and nondiscriminatory manner.

Blood bank means a facility for the collection, processing, storage and/or distribution of human blood, blood components or blood derivatives.

Certified histological technician means a clinical laboratory practitioner who pursuant to established and approved protocols of the department of health performs slide based histological assays, tests, and procedures and any other such tests conducted by a clinical histology laboratory, including maintaining equipment and records and performing quality assurance activities relating to procedure performance on histological testing of human tissue and which requires limited exercise of independent judgment and is performed under the supervision of a laboratory supervisor, designate by the director of a clinical laboratory or under the supervision of the director of the clinical laboratory.

Clinical laboratory technology means the performance of microbiological, virological, serological, chemical, immunohematological, hematological, biophysical, cytogenetical, cytological or histological procedures and examinations and any other test or procedure conducted by a laboratory as defined by title five of article five of the public health law, on material derived from the human body which provides information for the diagnosis, prevention or treatment of a disease or assessment of a human medical condition.

Cytotechnologist means a clinical laboratory practitioner who, pursuant to established and approved protocols of the Department of Health, performs cytological procedures and examination and any other such tests including maintaining equipment and records and performing quality assurance activities related to examination performance, and which require the exercise of independent judgment and responsibility, as determined by the Department.

Director of a Clinical Laboratory means a person who is responsible for administration of the technical and scientific operation of a clinical laboratory or blood bank, including supervision of procedures and reporting of findings of tests.

Pathways to Licensure

Pathways to licensure as a cytotechnologist or certified histological technician include:

• The special provisions (grandparenting): Applicants may meet special provisions including experience and/or education to be licensed without examination.
• The transition pathway: This will apply to those who have recently graduated or who are currently in educational programs. This pathway will expire on September 1, 2013.
• The standard pathway: This will generally apply to those who will attend a program registered as licensure qualifying or the substantial equivalent as determined by the department.

Cytotechnologist | Certified Histological Technician

Cytotechnologist

There are three Pathways to apply for a New York State cytotechnologist license - Grandparenting, Transition and Standard - encompassing seven methods by which applicants may apply. You must select the Method you will use and verify that you meet the requirements. You must indicate the method number at the top of your Application for Licensure (Form 1).

(Note: This pathway is only available until January 1, 2009.)

Grandparenting provisions provide a pathway to licensure for individuals who meet special provisions prior to specified dates without having to meet education requirements or pass an examination or both for licensure that are required under the transition pathway and the standard pathway. This pathway to licensure will generally apply to those with experience practicing in their fields for at least two years.

To be eligible for licensure under grandparenting, you must file an Application for Licensure (Form 1) and pay the $371 fee for licensure and first registration prior to January 1, 2009, be at least 18 years of age, be of good moral character, and meet the other specified requirements by the dates indicated.

If you file Form 1 of your application and the appropriate fee by January 1, 2009 and certify in good faith that you have, or will have, met the requirements for licensure under the grandparenting method you choose by the specified date, but no later than July 1, 2009, you will be able to practice as a cytotechnologist from the date you file the application with the Department until the Department acts on your application.

After filing your Form 1 and fee, you must provide documentation of having met all other requirements for licensure on the appropriate forms.

Use this method if you:

• have successfully performed the duties of a cytotechnologist for two years (at least 2,880 clock hours) during the period from December 31, 2002 through December 31, 2007 ; and
• will, by July 1, 2009, meet a transition pathway education requirement or a standard pathway education requirement for licensure as a licensed cytotechnologist (see "Transition Pathway Education Requirements" and "Standard Pathway Education Requirements").

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $371 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 4A

Use this method if you have successfully performed the duties of a cytotechnologist for five years (at least 7,200 clock hours) prior to December 31, 2007.

You must submit, or have submitted on your behalf, the following items and forms to document you meet these requirements.

• Form 1 and $371 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 4A

Use this method if you hold a Certificate of Qualification to practice as a cytotechnologist that was issued by the New York City Department of Health prior to 1995.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $371 fee for licensure and first registration
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Copy of Certificate of Qualification from the New York City Department of Health

(Note: This pathway is only available until September 1, 2013.)

If you do not meet any of the grandparenting pathway requirements, you may be eligible for licensure under one of the two transition methods described below. This pathway to licensure will generally apply to those who have recently graduated or who are currently in educational programs.

If you meet the appropriate transition pathway education requirements prior to September 1, 2013, you will have met the education requirement for licensure. If you meet all other requirements for licensure, except the examination for licensure, you will be eligible for a limited permit authorizing you to practice for one year to enable you to take the examination for licensure. Limited permits are effective for one year and may be renewed for one additional year for good cause as determined by the Department.

Transition Pathway Education Requirements

Use this method if you received a baccalaureate or higher degree in cytotechnology or a related title that:

1. prepares graduates for employment as a cytotechnologist; AND
2. contains didactic and clinical education that integrates pre-analytical, analytical, and post-analytical components of laboratory services, including the principles and practices of quality assurance/quality improvement, and that is designed and conducted to prepare graduates to practice cytotechnology using independent judgment and responsibility; AND
3. meets one of the following requirements:
   • is registered by the Department for general educational purposes but need not be specifically registered for licensure purposes, including the approximately 70 programs that are registered with the Department that have prepared graduates for employment in this profession, OR
   • is accredited by an accrediting agency acceptable to the Department, such as the National Accrediting Agency for Clinical Laboratory Sciences (NAACLS), or the Commission on Accreditation of Allied Health Education Programs (CAAHEP), or other acceptable organizations that accredit educational programs. Please Note: This does not include private membership organizations which may, or may not, offer examinations and list individuals for areas of general or specialty practice, OR
   • is recognized by the appropriate civil authorities of the jurisdiction in which the program is offered as a program that prepares the applicant for professional practice as a cytotechnologist.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $371 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 5 and $50 limited permit Fee (if you intend to practice in New York State under the general supervision of a Clinical Laboratory Director after you meet the education requirement and before you pass the licensing examination)

Use this method if you:

1. Received a baccalaureate or higher degree with a major in biology, chemistry, or the physical sciences registered by the Department or determined by the Department to be the substantial equivalent of such a program; AND
2. Completed a program that:
   1. prepares graduates for employment as a cytotechnologist;
   2. contains didactic and clinical education that integrates pre-analytical, analytical, and post-analytical components of laboratory services, including the principles and practices of quality assurance/quality improvement, and that is designed and conducted to prepare graduates to practice cytotechnology using independent judgment and responsibility; and
   3. meets one of the following requirements:
      • is registered by the Department for general educational purposes but need not be specifically registered for licensure purposes, including the approximately 70 programs that are registered with the Department that have prepared graduates for employment in this profession, OR
      • is accredited by an accrediting agency acceptable to the Department, such as the National Accrediting Agency for Clinical Laboratory Sciences (NAACLS), or the Commission on Accreditation of Allied Health Education Programs (CAAHEP), or other acceptable organizations that accredit educational programs. Please Note: This does not include private membership organizations which may, or may not, offer examinations and list individuals for areas of general or specialty practice, OR
      • is recognized by the appropriate civil authorities of the jurisdiction in which the program is offered as a program that prepares the applicant for professional practice as a cytotechnologist.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $371 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 5 and $50 limited permit Fee (if you intend to practice in New York State under the general supervision of a Clinical Laboratory Director after you meet the education requirement and before you pass the licensing examination)

Individuals who do not qualify for licensure through grandparenting or the transition pathways should apply for licensure through the standard pathway. This pathway to licensure will generally apply to those who will attend a program registered as licensure qualifying and then apply for licensure.

Standard Pathway Education Requirements

Use this method if you will receive a baccalaureate or higher degree from:

• a cytotechnology program registered by the Department as licensure qualifying; OR
• a program in cytotechnology or a related title that is determined by the Department to be the substantial equivalent of a registered program in cytotechnology that is accredited by an acceptable accrediting agency or recognized by the appropriate civil authorities of the jurisdiction in which the program is offered as a program that prepares individuals for professional practice as a cytotechnologist, and is designed and conducted by the degree-granting institution to prepare graduates to practice as cytotechnologists using independent judgment and responsibility.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $371 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 5 and $50 limited permit fee (if you intend to practice in New York State under the general supervision of a Clinical Laboratory Director after you meet the education requirement and before you pass the licensing examination and are licensed)

Use this method if you:

1. received a baccalaureate or higher degree awarded upon successful completion of a baccalaureate or higher degree program with a major in biology, chemistry, or the physical sciences registered by the Department or be determined by the Department to be the substantial equivalent of such program; AND
2. completed an advanced certificate from a credit bearing program in cytotechnology that is registered as licensure qualifying for licensure as a cytotechnologist or the substantial equivalent of such program.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $371 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 5 and $50 limited permit fee (if you intend to practice in New York State under the general supervision of a Clinical Laboratory Director after you meet the education requirement and before you pass the licensing examination)

Substantial Equivalence

For a program to be determined substantially equivalent to a registered cytotechnology program, it must:

1. be a program in cytotechnology leading to a baccalaureate or higher degree or advanced certificate which contains didactic and clinical education that integrates pre-analytical, analytical, and post-analytical components of laboratory services, including the principles and practices of quality assurance/ quality improvement; and which is designed to prepare graduates to practice cytotechnology using independent judgment and responsibility;
2. include coursework, which shall include a laboratory component in each area, in each of the following subject areas or their equivalent as determined by the department:
   1. inorganic chemistry;
   2. anatomy and physiology;
   3. cell biology;
   4. cytopathology, including but not limited to, female genital tract, respiratory tract, gastro-intestinal and genitourinary tracts, body fluids, evaluation of specimens from washes and brushes of all body sites, and evaluation of specimens from fine needle aspiration biopsies of all body sites;
   5. cytopreparatory techniques, including but not limited to, preparation, staining and processing of body samples; and
   6. microscopic evaluation and interpretation of cytopathology of the sample types and body systems identified in paragraph (4) of this subdivision;
3. include curricular content in each of the following subject areas or their equivalent as determined by the department:
   1. organic chemistry;
   2. mathematics and statistics;
   3. infection control and universal precautions (standard precautions);
   4. human genetics;
   5. immunology;
   6. clinical microbiology;
   7. the maintenance of equipment and records; and
   8. ethics; and
4. include a supervised clinical experience of at least 30 hours per week for at least 10 weeks or its equivalent as determined by the department, in the practice of cytotechnology.

Certified Histological Technician

There are three Pathways to apply for a New York State certified histological technician license - Grandparenting, Transition and Standard - encompassing six methods by which applicants may apply. You must select the Method you will use and verify that you meet the requirements. You must indicate the method number at the top of your Application for Licensure (Form 1).

(Note: This pathway is only available until January 1, 2009.)

Grandparenting provisions provide a pathway to licensure for individuals who meet special provisions prior to specified dates without having to meet education requirements or pass an examination or both for licensure that are required under the transition pathway and the standard pathway.

To be eligible for licensure under grandparenting, you must file an Application for Licensure (Form 1) and pay the $263 fee for licensure and first registration prior to January 1, 2009, be at least 18 years of age, be of good moral character, and meet the other specified requirements by the dates indicated.

If you file Form 1 of your application and the appropriate fee by January 1, 2009 and certify in good faith that you have, or will have, met the requirements for licensure under the grandparenting method you choose by the specified date, but no later than July 1, 2009, you will be able to practice as a certified histological technician from the date you file the application with the Department until the Department acts on your application.

After filing your Form 1 and fee, you must provide documentation of having met all other requirements for licensure on the appropriate forms.

Use this method if, prior to December 31, 2007, you have successfully performed the duties of a certified histological technician for five years (at least 7,200 clock hours).

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $263 fee for licensure and first registration
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 4A

Use this method if you have 6 months of experience (at least 720 clock hours) and competence as a certified histological technician attested to by a director of a clinical laboratory regulated by the Department of Health from December 31, 2004 through December 31, 2007.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $263 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 4C

Use this method if you:

• have successfully performed the duties of a certified histological technician for two years (at least 2,880 clock hours) during the period from December 31, 2002 and December 31, 2007; and
• will, by July 1, 2009 meet a transition pathway education requirement or a standard pathway education requirement for licensure as a certified histological technician (see "Transition Pathway Education Requirements" and "Standard Pathway Education Requirements").

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $263 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 4A

Use this method if you hold a Certificate of Qualification to practice as a certified histological technician that was issued by the New York City Department of Health prior to 1995.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $263 fee for licensure and first registration
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Copy of Certificate of Qualification from the New York City Department of Health

(Note: This pathway is only available until September 1, 2013.)

If you do not meet any of the grandparenting pathway requirements, you may be eligible for licensure under the transition pathway. This pathway to licensure will generally apply to those who have recently graduated or who are currently in educational programs.

If you meet the transition pathway education requirements prior to September 1, 2013, you will have met the education requirements for licensure. If you meet all other requirements for licensure, except the examination for licensure, you will be eligible for a limited permit authorizing you to practice for one year to enable you to take the examination for licensure. Limited permits are effective for one year and may be renewed for one additional year for good cause as determined by the Department.

Transition Pathway Education Requirements

Use this method if you will receive a associate or higher degree in certified histological technician or a related title prior to September 1, 2013 that:

1. prepares graduates for employment as a certified histological technician; AND
2. contains didactic and clinical education that integrates pre-analytical, analytical, and post-analytical components of laboratory services, including the principles and practices of quality assurance/quality improvement, and that is designed and conducted to prepare graduates to practice as certified histological technicians under the supervision of a clinical laboratory technologist, laboratory supervisor, or director of a clinical laboratory; AND
3. meets one of the following requirements:
   • is registered by the Department for general educational purposes but need not be specifically registered for licensure purposes, OR
   • is accredited by an accrediting agency acceptable to the Department, such as the National Accrediting Agency for Clinical Laboratory Sciences (NAACLS), or the Commission on Accreditation of Allied Health Education Programs (CAAHEP), or other acceptable organizations that accredit educational programs. Please Note: This does not include private membership organizations which may, or may not, offer examinations and list individuals for areas of general or specialty practice, OR
   • is recognized by the appropriate civil authorities of the jurisdiction in which the program is offered as a program that prepares the applicant for professional practice as a certified histological technician.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $263 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside of New York State)
• Form 5 and $50 limited permit fee (if you intend to practice in New York State under the general supervision of a Clinical Laboratory Director after you meet the education requirements and before you pass the licensing exam)

Individuals who do not qualify for licensure through grandparenting or the transition pathways should apply for licensure through the standard pathway. This pathway to licensure will generally apply to those who will attend a program registered as licensure qualifying and then apply for licensure.

Standard Pathway Education Requirements

Use this method if you will receive a associate or higher degree from:

• a certified histological technician program registered by the Department as licensure qualifying; or
• a program in certified histological technician or a related title that is determined by the Department to be the substantial equivalent of a registered program in certified histological technician that is accredited by an acceptable accrediting agency or recognized by the appropriate civil authorities of the jurisdiction in which the program is offered as a program to prepare individuals for professional practice as certified histological technicians.

You must submit, or have submitted on your behalf, the following items and forms to document that you meet these requirements.

• Form 1 and $263 fee for licensure and first registration
• Form 2
• Form 3 (only if you hold, or ever held, a professional license/certificate outside New York State)
• Form 5 and $50 limited permit fee (if you intend to practice in New York State under the general supervision of a Clinical Laboratory Director after you meet the education requirements and before you pass the licensing exam and are licensed)

Substantial Equivalence

For a program to be determined substantially equivalent to a registered certified histological technician program, it must:

1. be a histological technician program leading to an associate or higher degree which contains didactic and clinical education that integrates pre-analytical, analytical, and post-analytical components of laboratory services, including the principles and practices of quality assurance/ quality improvement;
2. include curricular content in each of the following subject areas or their equivalent as determined by the department:
   1. anatomy and physiology;
   2. inorganic chemistry;
   3. histology, to include microscopic analysis;
   4. histological techniques, to include microtome techniques, chemistry of stains, and staining techniques;
   5. quality assurance;
   6. ethics; and
   7. infection control and universal precautions; and
3. include a supervised clinical experience of at least 30 hours per week for at least 8 weeks, or its equivalent as determined by the department, in the practice of histological technician.

Additional Educational Requirements

For all pathways to licensure, except for those who are applying under Method 2 or under Method 1, 1A or 3 for certified histological technician, in addition to meeting the specific education requirements, you must also certify that you have reviewed the rules and regulations of the New York State Department of Health and the U.S. Department of Health and Human Services listed below, relating to practice as a cytotechnologist or certified histological technician in New York State. By signing your Application for Licensure (Form 1), you will be certifying that you are generally familiar with the specified rules and regulations and where to locate specific information you may need; you are not required to have a detailed knowledge of all the material.

Applicants should be familiar with the following general rules and regulations of any clinical laboratory, as well as rules and standards of specific relevance to areas of testing and reporting in which they are or expect to be engaged.

New York State Public Health Law and Regulations

The laws, rules and regulations listed below can be accessed on the Web at www.wadsworth.org/labcert/regaffairs/RAindex.htm

• Article V, Title V Clinical Laboratory and Blood Banking Services
• Article 31 Human Blood and Transfusion Services
• Article 27F HIV and AIDS Related Information
• Article 43-B, Organ, Tissue, and Body Parts
• Article V, Title VI Laboratory Business Practices
• Section 79.1 of the New York State Civil Rights Law, Confidentiality of Genetic Testing
• Part 19 of 10 (NYCRR) Clinical Laboratory Directors
• Subpart 34-2 of 10 (NYCRR) Laboratory Business Practices
• Subpart 58-1 of 10 (NYCRR) Clinical Laboratories (See 58.12 and 58.13 for requirements related to cytopathology and cytotechnology)
• Subpart 58-2 of 10 (NYCRR) Blood Banking
• Subpart 58-5 of 10 (NYCRR) Hematopoietic Progenitor Cell Banks
• Subpart 58-8 of 10 (NYCRR) Human Immunodeficiency Virus (HIV) Testing
• Subpart 63 of 10 (NYCRR) AIDS/HIV Testing, Reporting and Confidentiality

Federal Laws and Regulations

The laws and regulations listed below can be accessed on the Web at www.cms.hhs.gov/clia/

• Current CLIA Regulations
• Part 493 Laboratory Requirements

Examination Requirements

Cytotechnologists

You must pass The American Society for Clinical Pathology (ASCP) Board for Registry's examinations for cytotechnology with a converted score of at least 75 as determined by the State Board for Clinical Laboratory Technology.

Eligibility

To be eligible to sit for the examination you must:

• Apply for licensure, pay the fee for licensure and first registration and submit all supporting documentation; and
• meet the education requirements as stated in statute.

When the Department has determined your eligibility, we will send you a letter informing you of your eligibility. Your next step is to complete the ASCP State Licensure Application Found online at www.ascp.org/pdf/StateLicensureApplication.aspx. You will receive an admission letter with a phone number from the ASCP Board of Registry or scheduling your appointment to take the examination for medical technologist, for medical laboratory technician, or for cytotechnologist. You should schedule an appointment to take the examination within the assigned three month examination period. More information is available at www.ascp.org/FunctionalNavigation/certification/GetStateLicensure.aspx.

The examination is administered by:

ASCP Board of Registry
3335 Eagle Way
Chicago, IL 60676
Phone: 312-541-1033
E-mail: bor@ascp.org

Certified Histological Technicians

The examination requirements for certified histological technicians has not been determined at this time.

Reasonable Testing Accommodations

If you have a disability and may require reasonable testing accommodations for the examinations, please contact the ASCP Board of Registry for information.

Limited Permits

A limited permit authorizes an individual who has met all requirements for licensure as a cytotechnologist or certified histological technician, except the licensing examination, to practice as a cytotechnologist or certified histological technician under the general supervision of the director of a clinical laboratory.

The limited permit is valid for one year. The permit may be extended for one additional year if the applicant can document good cause, such as, a specific physical or mental disability certified by an appropriate health care professional or other good cause which, in the judgment of the Department, made it impossible for the applicant to complete the examination required for licensure.

You may apply for a limited permit by submitting the Application for Limited Permit (Form 5) and limited permit fee of $50 at the same time or any time after you submit you Application for Licensure (Form 1), licensure and first registration fee of $371, and evidence of satisfactory education.