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 a proficiency testing (PT) record review and an interview with the general supervisor, the laboratory failed to retain the 2018 cytology PT records and signed attestation statements from the College of American Pathologist (CAP) for two out of three cytotechnologists. Findings: 1. A review of the 2018 CAP cytology PT records revealed 2 out of 3 cytotechnologists failed to maintain the signed attestations statements and proficiency records from 2018. 2. An interview on September 11, 2019 at 10:35 AM, with the general supervisor, confirmed the laboratory failed to retain 2 out of 3 cytologist PT records from CAP. 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 a record review of personnel competency assessments, a review of the procedure manual, and an interview with the laboratory general supervisor, the laboratory failed to establish and follow procedures to evaluate the competency assessments for testing personnel, general supervisor, and technical supervisor in the specialties and subspecialties of bacteriology, mycology, parasitology, virology, immunology, Syphilis serology, chemistry, endocrinology, toxicology, hematology, Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 8 -- immunohematology, and histopathology since the last survey on November 30, 2017. Findings: 1. A review of the procedure manual revealed the laboratory failed to establish a policy or procedure to evaluate the competencies for 15 out of 15 testing personnel, 1 general supervisor, and 2 technical supervisors as listed on the CMS-209 Personnel Report form. 2. A review of personnel competency assessments revealed the laboratory failed to evaluate the competencies of the testing personnel, the general supervisor, and the technical supervisors for the laboratory since the last survey. 3. An interview on September 12, 2019 at 3:35 PM, with the general supervisor, confirmed the laboratory failed to establish in writing and failed to evaluate the competency assessments for the testing personnel and the supervisors. 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: Based on a record review and an interview with the general supervisor, the laboratory failed to verify the accuracy of 52 out of 52 immunohistochemical (IHC) stains, 20 out of 20 special stains, and brain natriuretic peptide (BNP) analyte at least twice a year since the last survey on November 30, 2017. This is a repeat deficiency from the last survey on November 30, 2017. Findings: 1. A document review revealed the laboratory failed to verify the accuracy of IHC stains, special stains, and BNP at least twice a year since the last survey. 2. The laboratory performed approximately 34 BNP tests during the past year. 3. The laboratory performed approximately 5700 IHC and special stains during the past year. 4. An interview on September 13, 2019 at 12:35 PM, with the general supervisor, confirmed the laboratory failed to document the accuracy of the stains and BNP at least twice a year. 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 a procedure manual review and an interview with laboratory staff member A, the laboratory failed to establish in writing a procedure or policy for the acceptability criteria when receiving client's specimens since the last survey on November 30, 2017. Findings: 1. A review of the specimen processing procedure revealed the laboratory failed to include the client specimen acceptability criteria such as specimen labeling, specimen source, processing, and referral. 2. An interview on September 12, 2019 at 3:35 PM, with laboratory staff member A, confirmed the client specimen processing procedure failed to include criteria for acceptability of specimens. -- 2 of 8 -- 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)