Greenfield Labs Llc

CLIA Laboratory Citation Details

2
Total Citations
18
Total Deficiencyies
8
Unique D-Tags
CMS Certification Number 23D2170820
Address 23350 Greenfield Road Suite 201, Oak Park, MI, 48237
City Oak Park
State MI
Zip Code48237
Phone(248) 544-3600

Citation History (2 surveys)

Survey - August 24, 2023

Survey Type: Complaint

Survey Event ID: WDIZ11

Deficiency Tags: D0000 D5209 D5401 D6000 D0000 D5209 D5401 D6000

Summary:

Summary Statement of Deficiencies D0000 The purpose of this unannounced survey was for complaint #MI00138853. The Department of Licensing and Regulatory Affairs has evaluated this facility and determined that it is not in compliance with CLIA regulations (42 CFR Part 93, effective April 24, 2003) and the following Condition: 493.1403 Condition: Laboratories performing moderate complexity testing; laboratory director 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 Testing Personnel #1, the laboratory failed to follow its personnel competency policies for 3 (Technical Consultant, Testing Personnel #1 and Testing Personnel #2) of 3 laboratory personnel listed on Form CMS-209. Findings include: 1. A review of the laboratory's "Performance Assessment" policy revealed a section stating, "All existing laboratory personnel will be appraised and evaluated at least annually." 2. A review of the laboratory's competency assessments revealed the Technical Consultant, Testing Personnel #1, and Testing Personnel #2 were last evaluated on 5/1/22. 3. An interview on 8/24/23 at 1:20 pm with Testing Personnel #1 confirmed laboratory personnel had not been assessed at least annually according to the laboratory's policy. 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 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 -- may supplement but not replace the laboratory's written procedures for testing or examining specimens. This STANDARD is not met as evidenced by: . Based on record review and interview with Testing Personnel #1, the laboratory failed to have written procedures for its qualitative toxicology testing for 2 (August 2021 to August 2023) of 2 years. Findings include: 1. The surveyor requested the laboratory's test procedures for its qualitative urine toxicology testing performed using the Medica Easy RA on 8/24/23 at 11:00 am and it was not made available. 2. An interview on 8/24/23 at 1:20 pm with Testing Personnel #1 confirmed test procedures were not available. ***This is a repeated deficiency from the 11/21/22 recertification survey*** 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 record review and interviews, the laboratory failed to have a director for three years and nine months (November 2019 to August 2023) since the change in laboratory director was made on 11/14/19. Findings include: 1. A review of email correspondence from the Laboratory Director to the surveyor on 8/16/23 revealed the Laboratory Director had been unaware of being listed as the laboratory director for Tox Testing Inc, stating "I have no knowledge of being a Laboratory Director or any knowledge of the following laboratories: Tox Testing located in the State of Michigan." 2. A review of the CMS laboratory database revealed a change in laboratory director to the currently listed laboratory director was effective 11/14/19. 3. The surveyor requested documentation of any contracts or agreements between the currently listed Laboratory Director and the laboratory for laboratory director services between November 2019 to present on 8/24/23 at 11:58 pm and it was not made available. 4. An interview on 8/24/23 at 11:36 am with the Laboratory Manager revealed he may have met the Laboratory Director once or twice, but the Laboratory Director had never been to the laboratory before. 5. An interview on 8/24/23 at 12:55 pm with Testing Personnel #1 revealed he had never met the Laboratory Director. 6. A review of email correspondence with the Technical Consultant on 8/28/23 revealed no documentation of contracts or agreements between the currently listed Laboratory Director and the laboratory or consulting company were available. -- 2 of 2 --

πŸ”’ Unlock Deficiency Summary

Get full access to the detailed deficiency summary for this facility

One-time payment β€’ Lifetime access

Survey - November 21, 2022

Survey Type: Standard

Survey Event ID: V06S11

Deficiency Tags: D5311 D5401 D5401 D5445 D6022 D3037 D3037 D5311 D5445 D6022

Summary:

Summary Statement of Deficiencies 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 record review and interview with Testing Personnel #1 (TP1), the laboratory failed to ensure all testing data from proficiency testing events was retained for at least two years for 1 (2020 Chemistry Event #2) of 4 proficiency testing events reviewed. Findings include: 1. A review of the laboratory's American Proficiency Institute proficiency testing records revealed a lack of testing data generated from the 2nd event of 2020 with the review date of 11/24/20. 2. The surveyor requested testing data for the proficiency testing samples from the 2nd event of 2020 on 11/21/22 at 11: 34 am and they were not made available. 3. An interview on 11/21/22 at 12:58 pm with TP1 confirmed the laboratory had not retained the testing data from the 2nd event of 2020. D5311 SPECIMEN SUBMISSION, HANDLING, AND REFERRAL CFR(s): 493.1242(a) The laboratory must establish and follow written policies and procedures for each of the following, if applicable: (1) Patient preparation. (2) Specimen collection. (3) Specimen labeling, including patient name or unique patient identifier and, when appropriate, specimen source. (4) Specimen storage and preservation. (5) Conditions for specimen transportation. (6) Specimen processing. (7) Specimen acceptability and rejection. (8) Specimen referral. This STANDARD is not met as evidenced by: . Based on record review, observation, and interview with Testing Personnel #1 (TP1), 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 -- the laboratory failed to ensure its specimen labeling policy was followed for 1 of 1 specimen observed. Findings include: 1. A review of the laboratory's "Specimen Handling Policy" revealed a section stating, "All specimens received must have a permanently attached label with a unique identifier (such as patient name or ID number). TWO Patient ID required for collection." 2. The surveyor observed Testing Personnel #2 (TP2) perform urine qualitative toxicology testing on 11/21/22 at 12:37 pm revealed the specimen being tested was labeled with the patient first name only and did not include a last name or second identifier. 3. An interview on 11/21/22 at 12: 58 pm with TP1 confirmed TP2 had not followed the laboratory's specimen labeling policy as established. 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: . Based on a lack of procedures and an interview with Testing Personnel #1 (TP1), the laboratory failed to have written procedures for its qualitative toxicology testing performed on the Easy RA analyzer for 2 (November 2020 to November 2022) of 2 years. Findings include: 1. The surveyor requested the laboratory's testing procedures for its qualitative urine toxicology testing using the Easy RA analyzer on 11/21/22 at 11:36 am and none were provided. 2. An interview on 11/22/22 at 12:58 pm with TP1 confirmed the laboratory did not have procedures for the performance of qualitative urine toxicology testing using the Easy RA analyzer. 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 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 record review and interview with Testing Personnel #1 (TP1), the laboratory failed to perform quality control testing at least each date of patient testing for its urine qualitative toxicology testing for 2 (11/19/20 and 11/25/20) of 13 patient testing dates reviewed. Findings include: 1. A review of the laboratory's quality control documentation for its urine qualitative toxicology testing using the Easy RA analyzer revealed a lack of documentation for 11/19/20 and 11/25/20. 2. A review of patient test reports revealed 7 patients received testing on 11/19/20 and 3 patients -- 2 of 3 -- received testing on 11/25/20. 3. An interview on 11/21/22 at 12:22 pm with TP1 confirmed the laboratory did not have documentation of quality control performed on the dates listed above when patient testing was reported. D6022 LABORATORY DIRECTOR RESPONSIBILITIES CFR(s): 493.1407(e)(5) 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)(5) Ensure that the quality control and quality assessment programs are established and maintained to identify failures in quality as they occur. This STANDARD is not met as evidenced by: . Based on a lack of documentation and an interview with Testing Personnel #1 (TP1), the Laboratory Director failed to ensure a quality assessment program was established and performed for 2 (November 2020 to November 2022) of 2 years reviewed. Findings include: 1. The surveyor requested the laboratory's quality assessment policies and records on 11/21/22 at 11:36 am and they were not made available. 2. An interview on 11/21/22 at 12:58 pm with TP1 confirmed the laboratory had no quality assessment policies or records of quality assessments performed between November 2020 and November 2022. -- 3 of 3 --

πŸ”’ Unlock Deficiency Summary

Get full access to the detailed deficiency summary for this facility

One-time payment β€’ Lifetime access