Summary:
Summary Statement of Deficiencies D2009 TESTING OF PROFICIENCY TESTING SAMPLES CFR(s): 493.801(b)(1) The individual testing or examining the samples and the laboratory director must attest to the routine integration of the samples into the patient workload using the laboratory's routine methods. This STANDARD is not met as evidenced by: Based on review of proficiency testing (PT) records and confirmed by laboratory personnel identifier #2 (refer to the Laboratory Personnel Report) at approximately 9: 00 am on 08/26/2021, the testing personnel and laboratory director failed to attest to the routine integration of PT samples into the patient workload for five out of five proficiency testing events (2020 events 1, 2 and 3; 2021 events 1 and 2) from 1/1 /2020 - 08/26/2021. The findings include: 1. For 2020 event 1, the laboratory director did not sign the miscellaneous chemistry PT attestation statement. 2. For 2020 event 2, the laboratory director did not sign the miscellaneous chemistry PT attestation statement. 3. For 2020 event 3, the following PT attestation statements were not signed: *Core chemistry- laboratory director *Hematology/coagulation- laboratory director and testing personnel *Immunology/immunohematology- laboratory director *Microbiology- laboratory director 4. For 2021 event 1, the following PT attestation statements were not signed: *Core chemistry- laboratory director *Hematology /coagulation- laboratory director *Immunology/immunohematology- laboratory director and testing personnel *Miscellaneous chemistry- laboratory director and testing personnel 5. For 2021 event 2, the following PT attestation statements were not signed: *Core chemistry- laboratory director and testing personnel *Microbiology- laboratory director and testing personnel D5026 IMMUNOHEMATOLOGY CFR(s): 493.1217 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 -- If the laboratory provides services in the specialty of Immunohematology, the laboratory must meet the requirements specified in 493.1230 through 493.1256, 493. 1271, and 493.1281 through 493.1299. This CONDITION is not met as evidenced by: Based on review of patient testing records, quality control records, the Micro Typing Systems Anti-Human Globulin Anti-IgG manufacturer's package insert, and confirmed by laboratory personnel identifiers #1 and #2 (refer to the Laboratory Personnel Report) at approximately 1:00 pm on 08/26/2021, the laboratory failed to perform a negative and positive control material each day of patient testing as specified in D5449. D5429 MAINTENANCE AND FUNCTION CHECKS CFR(s): 493.1254(a)(1) For unmodified manufacturer's equipment, instruments, or test systems, the laboratory must perform and document maintenance as defined by the manufacturer and with at least the frequency specified by the manufacturer. This STANDARD is not met as evidenced by: A. Based on review of the Dimension EXL maintenance records from January- August 2021 and confirmed by laboratory personnel identifier #2 (refer to the Laboratory Personnel Report) at approximately 10:45 am on 08/26/2021, the laboratory failed to perform and document weekly maintenance on the Dimension EXL chemistry instrument for 14 out of 33 weeks of patient testing from 01/03/2021- 08/21/2021. The findings include: 1. According to the Dimension EXL Weekly /Monthly Maintenance log, the manufacturer requires the laboratory to perform and document the following weekly maintenance: *Clean outside of R2 Probe *Clean outside of HM wash probes 2. The Dimension EXL Weekly/Monthly Maintenance log indicated that the laboratory did not document weekly maintenance during the following weeks: 01/03/21, 01/17/21, 02/07/21, 02/21/21, 03/21/21, 03/28/21, 05/23 /21, 05/30/21, 06/06/21, 06/20/21, 07/04/21, 07/11/21, 08/01/21, and 08/08/21. 3. At the time of the survey, personnel identifier #2 confirmed that the laboratory failed to perform and document weekly maintenance on the Dimension EXL chemistry instrument as required by the manufacturer for the weeks listed above. B. Based on review of the Dimension EXL maintenance records from January- August 2021 and confirmed by laboratory personnel identifier #2 (refer to the Laboratory Personnel Report) at approximately 10:45 am on 08/26/2021, the laboratory failed to document monthly maintenance on the Dimension EXL chemistry instrument for four out of eight months of patient testing from January- August 2021. The findings include: 1. According to the Dimension EXL Weekly/Monthly Maintenance log, the manufacturer requires the laboratory to perform and document the following monthly maintenance: *Clean clot check drain on IMT port *Replace IMT pump tubing *Clean IMT system *Replace/clean air filters *Stylette HM wash probes *Replace HM pump heads *Clean R2 drain *Clean R3 drain 2. Review of the Dimension EXL Weekly/Monthly Maintenance log indicated that the laboratory did not perform the following monthly maintenance: *January 2021: Replace/clean air filters *February 2021: All maintenance activities *May 2021: Replace HM pump heads *June 2021: All maintenance activities 3. At the time of the survey, personnel identifier #2 -- 2 of 3 -- confirmed that the laboratory failed to perform and document monthly maintenance on the Dimension EXL chemistry instrument as required by the manufacturer for the months listed above. D5449 CONTROL PROCEDURES CFR(s): 493.1256(d)(3)(ii)(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-- At least once a day patient specimens are assayed or examined perform the following for-- Each qualitative procedure, include a negative and positive control material; (g) The laboratory must document all control procedures performed. This STANDARD is not met as evidenced by: Based on review of patient testing records, quality control (QC) records, the Micro Typing Systems (MTS) Anti-Human Globulin Anti-IgG manufacturer's package insert, and confirmed by laboratory personnel identifiers #1 and #2 (refer to the Laboratory Personnel Report) at approximately 1:00 pm on 08/26/2021, the laboratory failed to perform a negative and positive control material each day of patient testing for five out of five days of patient testing from 02/01/2021- 03/31/2021. The findings include: 1. The laboratory uses the MTS Anti- Human Globulin Anti- IgG card to perform unexpected antibody detection testing. 2. The MTS Anti- Human Globulin Anti- IgG Card instructions for use state, "To confirm the specificity and reactivity of the MTS Anti-IgG card, it is recommended that each lot be tested each day of use with known positive and negative antibody samples with the appropriate red blood cells." 3. The laboratory performed unexpected antibody detection testing on the following dates: *02/05/2021- 1 patient *02/24/2021- 1 patient *03/03/2021- 1 patient *03/16/2021- 1 patient *03/23/2021- 1 patient 4. Personnel identifiers #1 and #2 confirmed that the laboratory routinely performs a positive control on the MTS Anti- Human Globulin Anti-IgG card each day of patient testing, but not a negative control. 5. At the time of the survey, the laboratory did not have negative control records for the dates of patient testing listed above. -- 3 of 3 --