Summary:
Summary Statement of Deficiencies D5415 TEST SYSTEMS, EQUIPMENT, INSTRUMENTS, REAGENT CFR(s): 493.1252(c) Reagents, solutions, culture media, control materials, calibration materials, and other supplies, as appropriate, must be labeled to indicate the following: (1) Identity and when significant, titer, strength or concentration. (2) Storage requirements. (3) Preparation and expiration dates. (4) Other pertinent information required for proper use. This STANDARD is not met as evidenced by: Based on surveyor observation and confirmed in interview of facility personnel, the laboratory failed to identify 3 of 3 reagents found in Coplin jars with lot number and expiration date. The findings were: 1. Surveyor observation on January 18, 2021 at 13: 52 hours in the laboratory found three (3) Coplin jars that contained reagents. The jars were not labeled with lot number or expiration date. Jar 1: Fixative Solution I No Lot Number No Expiration Date Jar 2: Fixative Solution II No Lot Number No Expiration Date Jar 3: Deionized Water No Lot Number No Expiration Date: 2. Reagent Log posted in the Hematology Department documented when reagents were changed but also did not include lot numbers or expiration dates. 3. Interview with the Laboratory Manager on January 18, 2021 at 14:00 hours in the laboratory confirmed the findings. D5445 CONTROL PROCEDURES CFR(s): 493.1256(d)(1)(2)(g) Unless CMS Approves a procedure, specified in Appendix C of the State Operations Manual (CMS Pub. 7), that provides equivalent quality testing, the laboratory must-- (d)(1) Perform control procedures as defined in this section unless otherwise specified in the additional specialty and subspecialty requirements at 493.1261 through 493.1278. (d)(2) For each test system, perform control procedures using the number and frequency specified by the manufacturer or established by the laboratory when Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 6 -- they meet or exceed the requirements in paragraph (d)(3) of this section. (g) The laboratory must document all control procedures performed. This STANDARD is not met as evidenced by: Based on review of the laboratory's IQCP (Individualized Quality Control Plan) for D- Dimer, Mono, Rheumatoid Factor, Helicobacter pylori, and Leuko EZ Vue, review of the laboratory's quality control records, review of patient test logs, and confirmed in interview of facility personnel it was revealed that the laboratory failed to have documentation of a complete risk assessment that identified the sources of error and evaluate the frequency and impact of those sources on the quality of testing. The findings were: Note: Manufacturer-provided tools and templates, if available, may be helpful for laboratories implementing IQCP; however, laboratories need to supplement these materials with laboratory-specific information as part of the Risk Assessment. The manufacturer information is not sufficient in and of itself. In-house data, established by the laboratory in its own environment and by its own personnel, must be utilized to demonstrate that the stability of the test system as it is used in the laboratory supports the number and frequency of the QC documented in the Quality Control Plan (QCP). 1. A review of the laboratory's IQCP studies for D-Dimer, Mono, Rheumatoid Factor, Helicobacter pylori, Leuko EZ Vue, and Sensititre for antibiotic susceptibility found the plans were incomplete. The risk assessment failed to include the evaluation of frequency and impact of possible sources of error obtained from the laboratory's own data. 2. Review of the IQCP studies found the laboratory utilized only the manufacturer's instructions to develop the plans. The laboratory did not utilize either previous EQC (Equivalent Quality Control) plans or new studies to develop its plan to perform testing with each new lot number, new shipment, and every 30 days. 3. A review of the laboratory's quality control records from March 1, 2020 to April 30, 2020 found that the laboratory performed quality control testing procedures as follows: Mono Spot Two levels of external quality control performed on: March 1, 2020 (Kit Lot #B31960) April 1, 2020 (Kit Lot #B31960) RA Factor Two levels of external quality control performed on: March 1, 2020 (Kit Lot #B30982) March 23, 2020 (Kit Lot #B32356) new lot number April 1, 2020 (Kit Lot #B2356) April 3, 2020 (Kit Lot #B32356) Helicobacter pylori Two levels of external quality control performed on: March 1, 2020 (Kit Lot #HP8720025) April 1, 2020 (Kit Lot #HP9082011) Leuko EZ Vue Two levels of external quality control performed on: 03-01-2020 (Kit Lot #0619044) 04-01-2020 (Kit Lot #0619044 Sensititre March 2, 2020 March 9, 2020 March 16, 2020 March 23, 2020 March 30, 2020 April 6, 2020 April 13, 2020 April 20, 2020 April 27, 2020 4. Review of the laboratory's patient test logs from March 1, 2020 to April 31, 2020 found the following patients were tested when the laboratory's IQCP studies were incomplete: Mono Spot No patients tested in March or April 2020 RA Factor Accession No.: 25162 Result Date: March 6, 2020 Result: Negative Accession No.: 25399 Result Date: March 7, 2020 Result: Negative Accession No.: 28913 Result Date: March 25, 2020 Result: Negative Accession No.: 29774 Result Date: March 30, 2020 Result: Positive Accession No.: 30105 Result Date: April3, 2020 Result: Negative Helicobacter pylori Accession No.: 24363 Result Date: March 8, 2020 Result: Positive Accession No.: 27468 Result Date: March 12, 2020 Result: Positive Accession No.: 27530 Result Date: March 17, 2020 Result: Negative Accession No.: 28867 Result Date: March 24, 2020 Result: Negative Accession No.: 28801 Result Date: March 24, 2020 Result: Positive Accession No.: 28903 Result Date: March 24, 2020 Result: Negative Accession No.: 29906 Result Date: March 31, 2020 Result: Negative Accession No.: 29926 Result Date: March 31, 2020 Result: Negative Accession No.: 29874 Result Date: March 31, 2020 Result: Negative Accession No.: -- 2 of 6 -- 29988 Result Date: March 31, 2020 Result: Negative Accession No.: 30014 Result Date: March 31, 2020 Result: Negative Accession No.: 31377 Result Date: April 7, 2020 Result: Positive Accession No.: 31385 Result Date: April 7, 2020 Result: Negative Accession No.: 31430 Result Date: April 7, 2020 Result: Negative Accession No.: 32780 Result Date: April 15, 2020 Result: Negative Accession No.: 34019 Result Date: April 21, 2020 Result: Negative Accession No.: 35347 Result Date: April 27, 2020 Result: Negative Accession No.: 35510 Result Date: April 28, 2020 Result: Leuko EZ Vue Accession No.: 31689 Result Date: April 9, 2020 Result: Positive Accession No.: 34350 Result Date: April 22, 2020 Result: Positive Sensititre (See Patient Alias List) 5. An interview with the Laboratory Manager on January 19, 2021 at 12:45 hours confirmed the findings. He revealed that he used only the manufacturer's instructions to develop the IQCP studies. D5781