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: Review of the CMS 209 Laboratory Personnel Report, personnel records and confirmed in interview, the laboratory's competency assessment policy failed to include a procedure to evaluate the competency of all supervisors and consultants performing moderate complexity. The findings included: 1. Review of the CMS report 209 Laboratory Personnel Report found that the laboratory designated two technical consultants for moderate complexity testing. 2. Review of personnel files found no documentation of competency assessment for technical consultant two (as listed on Form CMS-209). 3. Interview of technical consultant one (as listed on Form CMS- 209) on July 17, 2019 at 10:15 hours confirmed that the laboratory director had not evaluated the competency of all supervisors and consultants. Key: CMS - Centers for Medicare and Medicaid Services D5401 PROCEDURE MANUAL CFR(s): 493.1251(a) A written procedures manual for all tests, assays, and examinations performed by the laboratory must be available to, and followed by, laboratory personnel. Textbooks may supplement but not replace the laboratory's written procedures for testing or examining specimens. This STANDARD is not met as evidenced by: Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 8 -- A. Based on review of laboratory polices, review of patient records, and confirmed in staff interview, it was revealed that the laboratory failed to follow its own policy for documenting Gram Stain quality control. The findings were: 1. Review of the laboratory's policy titled, "Standard Operating Procedure: Gram Stain" reviewed and approved by the technical director on March 10, 2019 under "Quality Control" it stated, "Quality control slides are available and should be done at least once per day that the procedure is performed or whenever a new lot of stain is opened. Results should be documented in the appropriate QC manual and signed by the Tech performing the test. QC slide contain both Gram Positive Cocci and Gram Negative Bacilli in different areas of the slide." 2. Interview with testing personnel three (as listed on Form CMS-209) on July 17, 2019 at 16:00 hours in the laboratory revealed that the laboratory's practice is to perform a patient Gram Stain if the colony count is greater than 100,000 for females and greater than 10,000 for males. 3. Review of Gram Stain quality control records from January 2019 to July 2019 found the following female patient records when the colony count was greater than 100,000 and the laboratory failed to follow its own policy to document quality control test performance based on patient culture colony counts: 387699 58494 385207 384413 383288 382611 382130 381834 380966 4. The laboratory failed to follow its own policy for Gram Stain quality control documentation. Key: QC - quality control CMS - Centers for Medicare and Medicaid Services B. Based on review of laboratory policy, manufacturer's instructions, review of patient records, and confirmed in interview the laboratory failed to follow its own written policy for sending platelet flagged results to a reference laboratory for 1 of 1 patients in 2019 (random review June-July 2019). Findings: 1. Review of CBC Confirmation policy page 5 stated: "6) Giant platelet/Platelet Clumps These may be counted as WBC's and may show in the histogram. If this is the case send the specimen out to the reference laboratory for correct count and pathology review." 2. Review of the Sysmex operator's manual revealed the following: "Suspect, PLT Clumps? The PLT Clumps? IP Message is determined by abnormal clustering if the DIFF scattergrams. Asterisks (*) will appear next to the PLT result. Dashes may appear in place of data for the MVP or the MPV may be marked with an asterisk (*). The asterisk (*) indicates these results may be unreliable and should be confirmed according to your laboratory protocol prior to reporting." 3. Review of patient records in 2019 (random review) revealed the following: Patient ID 28653 CBC test date 06/14/2019 at 09:41 WBC result: 6.49* [10*3/uL] PLT result: 144*[10*3/uL] On the bottom of the result was a platelet estimate calculation: "12/8 X100= 150,000" The CBC was repeated on 06/14/2019 at 09:44 WBC result: 6.49*[10*3/uL] PLT result: 157*[10*3/uL] On the bottom of the result was a had written note stating: "platelet clumps" and a label stating: "VERIFIED BY REPEAT ANALYSIS AND BLOOD SMEAR" The laboratory failed to follow its own written policy and send the specimen to the reference laboratory for correct count and pathology review. 4. During an interview on 07/17 /2019 at 3:03 pm, testing person 1 (as documented on the CMS 209 form) stated that platelet clumps seen on a blood smear are sent out to the reference laboratory. 5. During an interview on 07/17/2019 at 3:30 pm, the laboratory director stated the patient's specimen was not sent to the reference laboratory, confirming the laboratory failed to follow its own written policy for sending platelet flagged results to a reference laboratory. D5403 PROCEDURE MANUAL CFR(s): 493.1251(b) The procedure manual must include the following when applicable to the test procedure: (1) Requirements for patient preparation; specimen collection, labeling, -- 2 of 8 -- storage, preservation, transportation, processing, and referral; and criteria for specimen acceptability and rejection as described in 493.1242. (2) Microscopic examination, including the detection of inadequately prepared slides. (3) Step-by-step performance of the procedure, including test calculations and interpretation of results. (4) Preparation of slides, solutions, calibrators, controls, reagents, stains, and other materials used in testing. (5) Calibration and calibration verification procedures. (6) The reportable range for test results for the test system as established or verified in 493.1253. (7) Control procedures. (8)