Summary:
Summary Statement of Deficiencies D0000 An announced CLIA recertification survey was conducted at Bay Dermatology and Cosmetic Surgery PA on 02/21/2023. The laboratory is not in compliance with 42 CFR Part 493, Requirements for Laboratories. The following is a description of the standard level 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: Based on record review and interview with the Office Manager, the laboratory failed to perform competency evaluations in accordance with written policies and procedures for three (Testing Personnel #B, #C, #D) out of four Testing Personnel (Testing Personnel #A - #D) for two out two years reviewed (2021 and 2022). Findings Included: Record review of the laboratory's policy " Testing Personnel Competency Assessment" with "Date Issued:" date of 03/01/21 revealed "Practitioners performing Histology, KOH [fungi], & parasitology (scabies) testing will be evaluated bi-annually to assess their competency in performing these tests." Review of the Laboratory Personnel Report (CMS-209) dated and signed by the Laboratory Director on 2/21/2023 revealed Testing Personnel #B performed high complexity testing for H&E stain interpretation. Review of competency assessment records revealed no documentation of competency being performed for Testing Personnel #B for 2021 and 2022 for H&E stain interpretation. Review of the Laboratory Personnel Report (CMS- 209) revealed Testing Personnel #C performed moderate complexity testing of KOH and parasitology (scabies) testing. Review of competency assessment records revealed that Testing Personnel #C did not have any evidence of bi-annual documentation of KOH competency for 2021 and 2022. Additionally, Testing Personnel #C had only 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 -- one out of two competency records for each year in 2021 and 2022 (10/14/21 and 11/9 /22). Review of the Laboratory Personnel Report (CMS-209) revealed Testing Personnel #D performed moderate complexity testing of KOH and parasitology (scabies) testing. Review of competency records revealed that Testing Personnel #D had KOH competency performed only one time in 2021 and 2022 (12/6/21) and parasitology competency performed only one time in 2021 and 2022 (11/10/22). On 02 /21/2023 at 11:55 AM, the Office Manager confirmed that the laboratory had not performed competency evaluations correctly. D5217 EVALUATION OF PROFICIENCY TESTING PERFORMANCE CFR(s): 493.1236(c)(1) At least twice annually, the laboratory must verify the accuracy of any test or procedure it performs that is not included in subpart I of this part. This STANDARD is not met as evidenced by: Based on record review and interview with the Office Manager, the laboratory failed to ensure the accuracy for twice a year testing for mycology (fungi) and parasitology (scabies) testing for three Testing Personnel ( #B, #C, and #D) out of four Testing Personnel (#A, #B, #C, and #D) for two out of two (2021-2023 ) years reviewed. Findings included: Record review of the laboratory's policy titled "Quality Assurance of KOH [sic potassium hydroxide, fungi] and Ectoparasite" revealed "A program has been set-up to review 1% of the results semi-annually by a dermatologist...All cases that are reviewed are documented on the appropriate review sheet and are signed by the reviewing dermatologist." Record review of the "KOH & Ectoparasite Lab Testing Log" revealed that "EVERY 5th TEST" was marked for review without consideration for who performed the test. Record review of the "KOH & Ectoparasite Lab Testing Log" revealed that Testing Personnel #B, #C, and #D performed KOH lab testing. Closer review revealed Testing Personnel #B did not have records for twice annual verification of fungi (KOH) testing for 2022, Testing Personnel #C did not have twice annual verification of fungi testing records for 2021, and only one (12/15/22) twice annual verification of fungi testing in 2022, and Testing Personnel #D did not have twice annual verification of fungi testing records for 2021 and 2022. Record review of the "KOH & Ectoparasite Lab Testing Log" log for Ectoparasite (scabies) showed that Testing Personnel #B, #C, and #D performed scabies testing. Closer review of the logs for Testing Personnel #B had two (10/12/21 and 12/6/22) twice annual verification of scabies testing records, Testing Personnel #C had one (11/9/22) twice annul verification of scabies testing record, and Testing Personnel #D had one (11/10 /22) twice annual verification of scabies testing record. On 02/21/23 at 11:50 AM, the Office Manager confirmed that there was missing semi-annual verification of fungi and scabies testing. -- 2 of 2 --