Baptist Memorial Health Care

CLIA Laboratory Citation Details

5
Total Citations
12
Total Deficiencyies
8
Unique D-Tags
CMS Certification Number 44D0666807
Address 7424 Hwy 64 Ste 111, Bartlett, TN, 38133
City Bartlett
State TN
Zip Code38133
Phone(901) 385-3877

Citation History (5 surveys)

Survey - September 26, 2022

Survey Type: Special

Survey Event ID: 1FNM11

Deficiency Tags: D2016 D6000 D0000 D2130 D6016

Summary:

Summary Statement of Deficiencies D0000 The following condition level deficiencies were cited: D2016 - 42 C.F.R. 493.803 Condition: Successful participation [proficiency testing] D6000 - 42 C.F.R. 493.1403 Condition: Laboratory Director, Moderate Complexity D2016 SUCCESSFUL PARTICIPATION CFR(s): 493.803(a)(b)(c) (a) Each laboratory performing nonwaived testing must successfully participate in a proficiency testing program approved by CMS, if applicable, as described in subpart I of this part for each specialty, subspecialty, and analyte or test in which the laboratory is certified under CLIA. (b) Except as specified in paragraph (c) of this section, if a laboratory fails to participate successfully in proficiency testing for a given specialty, subspecialty, analyte or test, as defined in this section, or fails to take remedial action when an individual fails gynecologic cytology, CMS imposes sanctions, as specified in subpart R of this part. (c) If a laboratory fails to perform successfully in a CMS- approved proficiency testing program, for the initial unsuccessful performance, CMS may direct the laboratory to undertake training of its personnel or to obtain technical assistance, or both, rather than imposing alternative or principle sanctions except when one or more of the following conditions exists: (1) There is immediate jeopardy to patient health and safety. (2) The laboratory fails to provide CMS or a CMS agent with satisfactory evidence that it has taken steps to correct the problem identified by the unsuccessful proficiency testing performance. (3) The laboratory has a poor compliance history. This CONDITION is not met as evidenced by: Based on a desk review of the Center for Medicare and Medicaid Services Casper Report 0155D (CMS 155), the laboratory's American Proficiency Institute (API) proficiency testing records,and staff interview, the laboratory failed to maintain 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 -- satisfactory proficiency testing (PT) performance for the automated white blood cell differential (WBC Diff) for three out of five testing events, resulting in non-initial unsuccessful PT participation. (Refer to D2130) D2130 HEMATOLOGY CFR(s): 493.851(f) Failure to achieve satisfactory performance for the same analyte in two consecutive events or two out of three consecutive testing events is unsuccessful performance. This STANDARD is not met as evidenced by: Based on a desk review survey of the CMS 155, the laboratory's 2021 and 2022 API PT records, and phone interview with the laboratory liaison, the laboratory failed to maintain satisfactory performance in three out of five PT events for the WBC Diff analyte, resulting in non-initial unsuccessful PT participation. The findings include: 1. Review of the CMS 155 revealed the following unsatisfactory PT scores for the WBC Diff analyte: 2021 Event one: 36% 2021 Event three: 28% 2022 Event two: 60% 2. Review of the laboratory's API PT performance evaluation records revealed the following unsatisfactory scores for WBC Diff analyte: 2021 Event one: 36% 2021 Event three: 28% 2022 Event two: 60% 3. Phone interview with the laboratory liaison on September 26, 2022 at 4:40 pm confirmed the survey findings. D6000 MODERATE COMPLEXITY LABORATORY DIRECTOR CFR(s): 493.1403 The laboratory must have a director who meets the qualification requirements of 493. 1405 of this subpart and provides overall management and direction in accordance with 493.1407 of this subpart. This CONDITION is not met as evidenced by: Based on review of the CMS 155 report, the laboratory's API PT records, and interview with the laboratory liaison, the laboratory director failed to ensure the laboratory performed PT in such a manner as to achieve and maintain satisfactory performance with successful PT for the WBC Diff analyte, resulting in non-initial unsuccessful PT participation. (Refer to D6016) D6016 LABORATORY DIRECTOR RESPONSIBILITIES CFR(s): 493.1407(e)(4)(i) The laboratory director is responsible for the overall operation and administration of the laboratory, including the employment of personnel who are competent to perform test procedures, and record and report test results promptly, accurate, and proficiently and for assuring compliance with the applicable regulations. (e) The laboratory director must-- (e)(4)(i) Ensure that the proficiency testing samples are tested as required under Subpart H of this part; This STANDARD is not met as evidenced by: Based on a desk review survey of the CMS 155 and the laboratory's 2021 and 2022 API PT evaluation records, staff interview, and laboratory communication, the laboratory director failed to ensure the laboratory performed PT in such a manner as -- 2 of 3 -- to achieve and maintain satisfactory performance, resulting in unsatisfactory performance for three out of five PT events for the WBC Diff analyte, and non-initial unsuccessful PT participation. Refer to D2130. -- 3 of 3 --

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Survey - February 22, 2022

Survey Type: Special

Survey Event ID: GK4U11

Deficiency Tags: D2016 D2130

Summary:

Summary Statement of Deficiencies D2016 SUCCESSFUL PARTICIPATION CFR(s): 493.803(a)(b)(c) (a) Each laboratory performing nonwaived testing must successfully participate in a proficiency testing program approved by CMS, if applicable, as described in subpart I of this part for each specialty, subspecialty, and analyte or test in which the laboratory is certified under CLIA. (b) Except as specified in paragraph (c) of this section, if a laboratory fails to participate successfully in proficiency testing for a given specialty, subspecialty, analyte or test, as defined in this section, or fails to take remedial action when an individual fails gynecologic cytology, CMS imposes sanctions, as specified in subpart R of this part. (c) If a laboratory fails to perform successfully in a CMS- approved proficiency testing program, for the initial unsuccessful performance, CMS may direct the laboratory to undertake training of its personnel or to obtain technical assistance, or both, rather than imposing alternative or principle sanctions except when one or more of the following conditions exists: (1) There is immediate jeopardy to patient health and safety. (2) The laboratory fails to provide CMS or a CMS agent with satisfactory evidence that it has taken steps to correct the problem identified by the unsuccessful proficiency testing performance. (3) The laboratory has a poor compliance history. This CONDITION is not met as evidenced by: The laboratory failed to maintain satisfactory participation in two out of three proficiency testing (PT) events for the White Blood Cell Differential analyte resulting in the first unsuccessful PT occurrence. (Refer to D2130) D2130 HEMATOLOGY CFR(s): 493.851(f) Failure to achieve satisfactory performance for the same analyte in two consecutive events or two out of three consecutive testing events is unsuccessful performance. Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 2 -- This STANDARD is not met as evidenced by: Based on a desk review of the Centers for Medicare and Medicaid Casper Report 155 (CMS 155) and the laboratory's proficiency testing (PT) evaluation reports, the laboratory failed to maintain satisfactory performance in two out of three PT events for the White Blood Cell (WBC) Differential analyte in 2021. The findings include: 1. Review of the CMS 155 report revealed the following unsatisfactory WBC Differential analyte scores: 2021 Event one = 36% 2021 Event three = 28% 2. Review of the laboratory's 2021 PT hematology event one performance summary report revealed the following: Score of 0% for Basophils, 0% for Eosinophils, 80% for Lymphocytes, 100% for Monocytes, and 0% for Neutrophils, resulting in an overall score of 36% for the WBC Differential. 3. Review of the laboratory's 2021 PT hematology event three performance summary report revealed the following: Score of 0% for Basophils, 0% for Eosinophils, 60% for Lymphocytes, 80% for Monocytes, and 0% for Neutrophils, resulting in on overall score of 28% for the WBC Differential and the first unsuccessful PT occurrence for the WBC Differential. -- 2 of 2 --

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Survey - November 4, 2019

Survey Type: Standard

Survey Event ID: ZK8W11

Deficiency Tags: D5791

Summary:

Summary Statement of Deficiencies D5791 ANALYTIC SYSTEMS QUALITY ASSESSMENT CFR(s): 493.1289(a)(c) (a) The laboratory must establish and follow written policies and procedures for an ongoing mechanism to monitor, assess, and when indicated, correct problems identified in the analytic systems specified in 493.1251 through 493.1283. (c) The laboratory must document all analytic systems assessment activities. This STANDARD is not met as evidenced by: Citation number one Based on review of the laboratory's quality assessment plan, calibrations for the Beckman Coulter AcT Diff 2 complete blood count (CBC) instrument, and interview with the laboratory liaison, the laboratory failed to follow the quality assessment plan in 2018 and 2019. The findings include: 1) Review of the laboratory's quality assessment plan revealed that the laboratory is to: evaluate calibrations to ensure they are performed per written policy; identify problems in our laboratory and apply

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Survey - May 10, 2019

Survey Type: Special

Survey Event ID: LWRT11

Deficiency Tags: D2016 D2130

Summary:

Summary Statement of Deficiencies D2016 SUCCESSFUL PARTICIPATION CFR(s): 493.803(a)(b)(c) (a) Each laboratory performing nonwaived testing must successfully participate in a proficiency testing program approved by CMS, if applicable, as described in subpart I of this part for each specialty, subspecialty, and analyte or test in which the laboratory is certified under CLIA. (b) Except as specified in paragraph (c) of this section, if a laboratory fails to participate successfully in proficiency testing for a given specialty, subspecialty, analyte or test, as defined in this section, or fails to take remedial action when an individual fails gynecologic cytology, CMS imposes sanctions, as specified in subpart R of this part. (c) If a laboratory fails to perform successfully in a CMS- approved proficiency testing program, for the initial unsuccessful performance, CMS may direct the laboratory to undertake training of its personnel or to obtain technical assistance, or both, rather than imposing alternative or principle sanctions except when one or more of the following conditions exists: (1) There is immediate jeopardy to patient health and safety. (2) The laboratory fails to provide CMS or a CMS agent with satisfactory evidence that it has taken steps to correct the problem identified by the unsuccessful proficiency testing performance. (3) The laboratory has a poor compliance history. This CONDITION is not met as evidenced by: Hematology: The laboratory failed to maintain satisfactory participation in two consecutive events for the automated white blood cell (WBC) differential, resulting in the first unsuccessful proficiency testing (PT) occurrence for the automated WBC differential analyte. (Refer to D2130) D2130 HEMATOLOGY CFR(s): 493.851(f) Failure to achieve satisfactory performance for the same analyte in two consecutive Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 2 -- events or two out of three consecutive testing events is unsuccessful performance. This STANDARD is not met as evidenced by: Based on a desk review of the Centers for Medicare and Medicaid Services Report 155 (CMS 155) and the laboratory's proficiency testing (PT) records the laboratory failed to maintain satisfactory performance for automated white blood cell (WBC) differential for 2018 event three and 2019 event one, resulting in the first unsuccessful occurrence. The findings include: 1) Review of the CMS 155 report revealed failing scores for the automated WBC differential as follows: 2018 event three=60%, 2019 event one=60%. 2) Review of the 2018 event three PT evaluation report revealed the following: Lymphocytes-Sample number Hem-11 scored as unacceptable; Monocytes /Mids-Sample numbers Hem-11, HEM-12, Hem-13 scored as unacceptable; Granulocytes-Sample numbers HEM-11 and HEM-12 scored as unacceptable; resulting in an overall automated WBC differential score of 60%. 3) Review of the 2019 event one PT evaluation report revealed the following: Monocytes/Mids-Sample numbers HEM-01, HEM-03, HEM-05 scored as unacceptable; Granulocytes-Sample numbers HEM-01, HEM-03, HEM-05 scored as unacceptable; resulting in an overall score for the automated WBC differential of 60%. -- 2 of 2 --

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Survey - March 1, 2018

Survey Type: Standard

Survey Event ID: USY711

Deficiency Tags: D3037 D3031

Summary:

Summary Statement of Deficiencies D3031 RETENTION REQUIREMENTS CFR(s): 493.1105(a)(3) Analytic systems records. Retain quality control and patient test records (including instrument printouts, if applicable) and records documenting all analytic systems activities specified in 493.1252 through 493.1289 for at least 2 years. This STANDARD is not met as evidenced by: Based on review of the laboratory's quality control records, the laboratory's procedure manual and interview with the laboratory liaison, the laboratory failed to retain the manufacturer's quality control assay information sheets for 2 of 8 randomly selected control lots in 2016. The findings include: 1. Review of the laboratory's quality control records revealed the laboratory failed to retain quality control assay information sheets for quality control lots 064700-low, 072800-normal, 084600-high (in use on 7.16.16); and 065500-low, 073300-normal, 085100-high (in use on 10.28.16). 2. Review of the laboratory's procedure manual revealed no policy requiring two year retention of manufacturer's quality control assay information sheets. 3. Interview with the laboratory liaison on March 1, 2018 at 3:20 pm confirmed the laboratory failed to retain manufacturer's quality control assay information sheets in 2016 and the laboratory has no policy requiring two year retention of laboratory quality control records. D3037 RETENTION REQUIREMENTS CFR(s): 493.1105(a)(4) Proficiency testing records. Retain all proficiency testing records for at least 2 years. This STANDARD is not met as evidenced by: Based on review of the laboratory's American Proficiency Institute (API) proficiency Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 2 -- testing records and interview with the laboratory liaison, the laboratory failed to retain proficiency testing records for at least 2 years for one of five proficiency testing events. 1. Review of the laboratory's API proficiency testing records for 2016 events two and three and 2017 events one, two, and three revealed that the laboratory did not retain the instrument printouts for 2016 event two. 2. Interview with the laboratory liaison on March 1, 2018 at 3:20 pm confirmed the laboratory failed to retain the instrument printouts for proficiency testing for 2016 event two. -- 2 of 2 --

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