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: Based on personnel interview and document review on December 13, 2023 at 10:10 am, the laboratory failed to establish and follow written policies and procedures for personnel competency assessments, including remedial training or continuing education needs, that included all the elements listed at 42 CFR 493.1451(b)(8). Findings included: a. It was the practice of the laboratory to include quizzes in initial testing personnel competency assessments. A review of initial testing personnel competency assessments indicated the following: i. Testing Personnel 3's (TP-3's) Cepheid quiz was upgraded. ii. TP-5's "moderate complexity" initial quiz was scored as "failed." iii. Only 1 of 5 TP had a "moderate complexity" quiz. b. Interview with the Technical supervisor (TS) confirmed that the laboratory did not have written policies and procedures for conducting laboratory personnel competency assessments. c. According to laboratory records, the laboratory performed approximately 171,000 tests annually. 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: Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 7 -- Based on interview with the laboratory director (LD) and document review on December 13, 2023 at 3:00 pm, at least twice annually, the laboratory failed to verify the accuracy of C-Reactive Protein (CRP) and measured total iron-binding capacity (TIBC), tests or procedures it performed that is not included in subpart I of this part, in 2023. Findings include: a. It is the laboratory's practice to enroll in CRP and TIBC proficiency testing (PT) to meet the requirement at 42 CFR 493.1236(c)(1). b. A review of the laboratory's 2023 PT records showed that the laboratory received unsatisfactory CRP and TIBC PT test scores (i.e., obtain a minimum proficiency test score of 80%) in two consecutive proficiency testing events or two out of three consecutive proficiency testing events. Year Event Score Analyte 2023 1st 50% CRP 2023 2nd 50% CRP 2023 1st 60% TIBC 2023 2nd 40% TIBC c. Interview with the LD confirmed these findings. d. The laboratory performed and reported approximately 900 patient CRP and TIBC test results annually. D5291 GENERAL LABORATORY SYSTEMS QUALITY ASSESSMENT CFR(s): 493.1239(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 general laboratory systems requirements specified at 493.1231 through 493.1236. This STANDARD is not met as evidenced by: Based on laboratory personnel interviews and postanalytic systems quality assessment policies and procedures record review on December 13, 2023 at 10:30 am, the laboratory failed to establish written policies and procedures for an ongoing mechanism to monitor, assess and, when indicated, correct problems identified in the general laboratory systems specified in 493.1231 through 493.1236. Findings included: a. As confirmed by laboratory personnel, the laboratory maintained no written policies and procedures detailing the laboratory's quality assessment mechanisms to monitor, assess and, when indicated, correct problems identified in the laboratory's general laboratory systems. b. According to laboratory records, the laboratory performed approximately 171,000 tests on patient blood specimens annually 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 testing personnel interview and specimen collection policies and procedures record review on December 13, 2023 at 10:00 am, the laboratory failed to establish written policies and procedures for the collection of blood specimens. Findings included: a. It was the practice of the laboratory to collect patient blood specimens using routine phlebotomy procedures. b. As confirmed by testing personnel, the -- 2 of 7 -- laboratory maintained no written policies and procedures detailing the laboratory's phlebotomy protocols. c. According to laboratory records, the laboratory performed approximately 171,000 tests on patient blood specimens annually. D5391 PREANALYTIC SYSTEMS QUALITY ASSESSMENT CFR(s): 493.1249(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 preanalytic systems specified at 493.1241 through 493.1242. This STANDARD is not met as evidenced by: Based on laboratory personnel interviews and analytic systems quality assessment policies and procedures record review on December 13, 2023 at 10:15 am, the laboratory failed to establish written policies and procedures for an ongoing mechanism to monitor, assess and, when indicated, correct problems identified in the preanalytic systems specified in 493.1241 through 493.1242. Findings included: a. As confirmed by laboratory personnel, the laboratory maintained no written policies and procedures detailing the laboratory's quality assessment mechanisms to monitor, assess and, when indicated, correct problems identified in the laboratory's preanalytic systems. b. For example, the laboratory maintained no written policies and procedures establishing the laboratory's preanalytic systems quality assessment protocol to ensure written policies and procedures for the collection of blood specimens were established. See D5311. c. According to laboratory records, the laboratory performed approximately 171,000 tests on patient blood specimens annually. 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, 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)