Summary:
Summary Statement of Deficiencies D5209 PERSONNEL COMPETENCY ASSESSMENT POLICIES CFR(s): 493.1235 As specified in the personnel requirements in subpart M, the laboratory must establish and follow written policies and procedures to assess employee and, if applicable, consultant competency. This STANDARD is not met as evidenced by: Baseds upon a review of the CMS 209 form, records of testing personnel competency assessment, lack of documentation and interview with laboratory staff, the laboratory failed to assess testing personnel competency utilizing the six procedures required by CFR 493.1413(b)(8) for 2 of sixteen testing personnel included on the form CMS 209. Findings follow: A) Review of the authorizations to perform testing signed by the laboratory director, testing personnel (numbers 10 -11 on form CMS 209) are authorized to perform moderately complex testing in chemistry, hematology, coagulation, and urinalysis specialties. B) Review of the competency assessment records for testing personnel (numbers 10 and 11 on the form 209) dated January 2023, January 2024, and January 2025 revealed that the personnel were evaluated as competent to perform patient testing on the Alinity chemistry analyzer, the Sysmex 1000/XN hematology analyzer, the Sysmex CA-600 coagulation analyzer, and the Clinitek Advantus urinalysis analyzers but the competency evaluations did not indicate the procedures used to evaluate the personnel competencies. C) Upon request, the laboratory could not provide documentation that the competencies of testing personnel (numbers 10 and 11 on the form CMS 209) were evaluated using the six procdures required by CFR 493.1413(b)(8). D) In an interview on 7/22/25 at 11:05 a. m., the laboratory staff member (number 2 on the form CMS 209) confirmed that the testing personnel (numbers 10 and 11 on the form CMS 209) performed moderately complex patient testing and the competencies were not evaluated using the six required procedures. Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 3 -- D5415 TEST SYSTEMS, EQUIPMENT, INSTRUMENTS, REAGENT CFR(s): 493.1252(c) (c) Reagents, solutions, culture media, control materials, calibration materials, and other supplies, as appropriate, must be labeled to indicate the following: (c)(1) Identity and when significant, titer, strength or concentration. (c)(2) Storage requirements. (c)(3) Preparation and expiration dates. (c)(4) Other pertinent information required for proper use. This STANDARD is not met as evidenced by: Based upon a review of the Dade application sheet for on-board stability for innovin reagent for the Sysmex CA 600 analyzer, observations made during a tour of the laboratory, and interview with a laboratory staff member, the laboratory failed to document the expiration date and time of the innovin reagent used for prothrombin time (PT) testing on the Sysmex CA-600 coagulation analyzer. Findings follow: A) Review of the application sheet for on-board stability of innovin reagent on the Sysmex CA 600 coagulation analyzer revealed an on-board stability of 24 hours. B) During a tour of the laboratory at 08:40 a.m. on 7/24/25, the container of innovin in use on-board the Sysmex CA-600 analyzer was observed, labeled with the word "innovin" on the container, and no other labeling as to date/time placed into use or expiration date/time. C) When asked when the innovin was placed into use, the laboratory staff member ( number 1 on the form CMS 209) stated "at 12:00 a.m. on 7 /24/25" and explained the laboratory staff replaces the innovin at midnight with fresh innovin which is placed in a container labeled "innovin". D) When asked if it was possible that the laboratory staff on duty at 12:00 a.m. could possibly forget to change the innovin reagent the laboratory staff member ( number 1 on the form CMS 209) confirmed that it was a possibility. E) When asked if there was documentation which would allow laboratory staffing during the day hours to determine if the time/date of the last innovin change, the laboratory staff member ( number 1 on the form CMS 209) responded that there was not such documentation available. D5441 CONTROL PROCEDURES CFR(s): 493.1256(a)(b)(c)(g) (a) For each test system, the laboratory is responsible for having control procedures that monitor the accuracy and precision of the complete analytic process. (b) The laboratory must establish the number, type, and frequency of testing control materials using, if applicable, the performance specifications verified or established by the laboratory as specified in 493.1253(b)(3). (c) The control procedures must-- (c)(1) Detect immediate errors that occur due to test system failure, adverse environmental conditions, and operator performance. (c)(2) Monitor over time the accuracy and precision of test performance that may be influenced by changes in test system performance and environmental conditions, and variance in operator performance. This STANDARD is not met as evidenced by: Based upon the review of the Individualized Quality Control Plans (IQCP) for High Sensitivity Troponin (TNI) performed on the I-Stat instrument, Naturetic Peptide Tests (BNP) on I-Stat instrument, and microbiological assays performed by Polymerase Chain Reaction (PCR) procedures on the Cepheid GeneXpert instrument the laboratory failed to specifiy the external quality control (QC) material employed in the IQCP of three of three plans reviewed. Finding follow: A) Review of the IQCP for -- 2 of 3 -- TNI assays performed on the I-Stat instrument revealed that external QC will be performed monthly and when a new lot number and shipment of reagents are received. The identity of the control material used was not specified. B) Review of the IQCP for BNP assays performed on the I-Stat instrument revealed that external QC will be performed monthly and when a new lot number and shipment of reagents are received. The identity of the control material used was not specified. C) Review of the IQCP for PCR assays performed on the Cepheid GeneXpert instrumentrevealed that external QC will be performed monthly and when a new lot number and shipment of reagents are received. The identity of the control material used was not specified. D) In an interview on 7/24/25 at 11:45 a.m., the laboratory staff member (number 2 on the form CMS 209) confirmed that the IQCP's identified above did not specify the identity of the external control materials used in the QC process. D5783