Summary:
Summary Statement of Deficiencies D2010 TESTING OF PROFICIENCY TESTING SAMPLES CFR(s): 493.801(b)(2) The laboratory must test samples the same number of times that it routinely tests patient samples. This STANDARD is not met as evidenced by: Based on review of the laboratory's proficiency testing (PT) policy and procedure, American Proficiency Institute (API) proficiency testing documentation, hematology instrument result printouts, staff schedules, and interview with the Technical Supervisor (TS), the laboratory failed to test the 2017 3rd testing event hematology samples the same number of times that it routinely tests patient samples. Findings Include: 1. Review of the laboratory's policy and procedure titled "PROFICIENCY TESTING" states: "B. All surveys are to be treated and tested only in accordance with the written directions and in accordance with all CLIA regulations." 2. Review of the laboratory's API PT documentation for the 3rd testing event of 2017 in the specialty of hematology found Testing Personnel (TP) #3 signed the attestation form stating they performed analysis on PT sample COU-12 on 11/20/2017. The API PT due date for the hematology/coagulation 3rd testing event of 2017 was 12/01/2017. 3. Review of the laboratory's hematology instrument printouts included with the API PT documentation found three separate analyses of PT sample COU-12: Sample ID: API COU-12 Date: 11/20/2017 Time: 07:52 Sample ID: 17API_COU-12 Date: 11/29 /2017 Time: 15:31 Sample ID: 17API_COU-12 Date: 11/29/2017 Time: 15:34 3. Review of the laboratory's staff schedule found that TP #3 was not scheduled to be present in the laboratory on 11/29/2017 at 15:30. The schedule states that TP #3's shift ended at 14:30 on 11/29/2017. 4. The TS confirmed that it is not routine laboratory practice for a patient's sample to be reanalyzed nine days after the first analysis by a different TP. The TS stated they were unable to provide any laboratory policies or procedures that stated patient samples would be handled in a manner similar to the testing process described above. The interview occurred 08/03/2018 at 12:05 PM. Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 5 -- D2015 TESTING OF PROFICIENCY TESTING SAMPLES CFR(s): 493.801(b)(5)(6) (5) The laboratory must document the handling, preparation, processing, examination, and each step in the testing and reporting of results for all proficiency testing samples. The laboratory must maintain a copy of all records, including a copy of the proficiency testing program report forms used by the laboratory to record proficiency testing results including the attestation statement provided by the PT program, signed by the analyst and the laboratory director, documenting that proficiency testing samples were tested in the same manner as patient specimens, for a minimum of two years from the date of the proficiency testing event. (6) PT is required for only the test system, assay, or examination used as the primary method for patient testing during the PT event. This STANDARD is not met as evidenced by: Based on review of the laboratory's policies and procedures, 2017 and 2018 proficiency testing documentation, and interviews with the Technical Supervisor (TS) and anonymous Testing Personnel (TP), the laboratory failed to document and maintain documentation of the handling, preparation, processing, examination, and each step of the testing and reporting of results for all proficiency testing (PT) samples for a minimum of two years from the date of the proficiency testing event. Findings Include: 1. Review of the laboratory's American Proficiency Institute (API) PT documentation for 2017 and 2018 found the following altered results: Hematology 2018 - 1st Testing Event: Blood Cell Identification: Sample BCI-01 "Lymphocyte, normal" crossed out, "Hairy Cell" filled in - no testing documentation located Fibrinogen instrument printout results unreadable, results handwritten on instrument printout - laboratory unable to locate electronic copy of results or readable printout of results 2017 - 3rd Testing Event: Urinalysis & HCG: Samples UA-05 and UA-06 Result UA-05: 1.009 crossed out, 1.025 written below Result UA-06: 1.009 crossed out, 1.015 written below No documentation explaining the 1.009 results located Coagulation: Samples COA-11, COA-12, COA-13, COA-14, and COA-15 Fibrinogen instrument printout results unreadable, results handwritten on instrument printout - laboratory unable to locate electronic copy of results or readable printout of results Chemistry 2017 - 2nd Testing Event: Body Fluid Crystals: Sample CYS-04 Laboratory log sheet: dated 10/19/2017 and result "Calcium oxalate (dehydrate) crystals observed" documented API Result Form: result "Calcium oxalate crystal(s)" crossed out, "Crystals seen, referred for ID" filled in - corrections dated 11/2/17 Cell Count: Sample BFL-04 Laboratory log sheet: Count 1: WBC - 94 Count 2: WBC - 100 API Result Form: WBC (manual-CSF/BF) result of 83 crossed out, 94 written above - no documentation explaining the 83 result located 2017 - 1st Testing Event: Blood Gas: Sample BG-03 API Result Form: pH 7.43 crossed out, 7.26 written above pCO2 18 crossed out, 54 written above pO2 227 crossed out, 159 written above Original results (crossed out) dated 2/6/17 and initialed by TP #3, results written above dated 2/7 and initialed by TP #6 No instrument printout for the original results dated 2/6/17 located. Immunology/Immunohematology 2017 - 2nd Testing Event: CRP Quantitative: Sample QCP-04 Result QCP-04: 0.1 crossed out, 6.5 written above - no documentation explaining the 0.1 result located 2. Review of the laboratory's policy and procedure titled "PROFICIENCY TESTING" found no mention or reference to PT documentation retention requirements or practices. 3. Anonymous TP stated the TP submit the instrument printouts from PT analysis and the completed API bubble sheets to the TS. The TP stated they did not participate in PT result submission after that point. The TP further stated that the TS would, on occasion, come back and -- 2 of 5 -- ask the TP to rerun the PT samples after reviewing the instrument printout and bubble sheets the TP had submitted to the TS. The anonymous interviews occurred 08/03 /2018 at 11:30 AM. 4. The TS confirmed the TP submitted the instrument printouts and completed API bubble sheets to them but was unable to provide and explanation for the results missing instrument printouts or the numerous changes to the results. The interview occurred 08/03/2018 at 12:20 PM. D2087 ROUTINE CHEMISTRY CFR(s): 493.841(a) Failure to attain a score of at least 80 percent of acceptable responses for each analyte in each testing event is unsatisfactory analyte performance for the testing event. This STANDARD is not met as evidenced by: Based on review of the laboratory's 2018 American Proficiency Institute (API) proficiency testing (PT) documentation and documentation by the Technical Supervisor (TS), the laboratory failed to attain a score of at least 80 percent of acceptable responses for the pO2 analyte resulting in unsatisfactory analyte performance for the 2nd testing event of 2018. Findings Include: 1. Review of the laboratory's API PT documentation for the 2nd testing event of 2018 found the laboratory scored a 60 percent for the analyte pO2 after obtaining unacceptable results for samples BG-07 and BG-09. 2. The TS confirmed the laboratory received unacceptable scores for the pO2 analyte on samples BG-07 and BG-09 on the PT