Rush Univ Med Center Dermatology Patient Svcs

CLIA Laboratory Citation Details

3
Total Citations
8
Total Deficiencyies
7
Unique D-Tags
CMS Certification Number 14D0424105
Address 1725 W Harrison St, Ste 264, Chicago, IL, 60612
City Chicago
State IL
Zip Code60612
Phone(312) 947-7546

Citation History (3 surveys)

Survey - December 8, 2025

Survey Type: Standard

Survey Event ID: RWJD11

Deficiency Tags: D2007 D2009 D5221 D5601

Summary:

Summary Statement of Deficiencies D2007 TESTING OF PROFICIENCY TESTING SAMPLES CFR(s): 493.801(b)(1) (b)(1) The samples must be examined or tested with the laboratory's regular patient workload by personnel who routinely perform the testing in the laboratory, using the laboratory's routine methods. This STANDARD is not met as evidenced by: Based on review of the CMS-209 (Laboratory Personnel Report) Form, laboratory records, and interview with the laboratory representative; the laboratory failed to test proficiency testing (PT) samples by personnel who routinely perform potassium hydroxide (KOH) testing in the subspecialty of mycology for five of five events in 2024 and 2025. Findings include: 1. Review of the CMS-209 (Laboratory Personnel Report) Form and laboratory competency records revealed 37 testing personnel (TP) authorized to perform KOH testing in the subspecialty of mycology. 2. Review of American Proficiency Institute (API) PT documentation and interview with the laboratory representative on 12/08/2025, at 1:44 pm, revealed five of five PT events were performed by TP #8. Year, Event: TP #: 2024 - Event 1 8 2024 - Event 2 8 2024 - Event 3 8 2025 - Event 1 8 2025 - Event 2 8 3. Interview with the laboratory representative on 12/08/2025, at 1:44 pm, confirmed the laboratory failed to test PT samples by personnel who routinely perform KOH testing in the subspecialty of mycology for five of five events in 2024 and 2025. D2009 TESTING OF PROFICIENCY TESTING SAMPLES CFR(s): 493.801(b)(1) (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. 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 -- This STANDARD is not met as evidenced by: Based on review of laboratory records, lack of documentation, and interview with the laboratory representative; the laboratory failed to ensure attestation statements were completed for five of five proficiency testing (PT) events for potassium hydroxide (KOH) testing in the subspecialty of mycology in 2024 and 2025. Findings include: 1. Review of American Proficiency Institute (API) PT records for 2024 and 2025 revealed a lack of attestation statements for five of five KOH events in the subspecialty of mycology in 2024 and 2025. Year, Event: Attestation Completed: 2024 - Event 1 No 2024 - Event 2 No 2024 - Event 3 No 2025 - Event 1 No 2025 - Event 2 No 2. Interview with the laboratory representative on 12/08/2025, at 1:40 pm, confirmed the laboratory failed to ensure attestation statements were completed for five of five PT events for KOH testing in the subspecialty of mycology in 2024 and 2025. D5221 EVALUATION OF PROFICIENCY TESTING PERFORMANCE CFR(s): 493.1236(d) All proficiency testing evaluation and verification activities must be documented. This STANDARD is not met as evidenced by: Based on review of laboratory policies and procedures, laboratory records, lack of documentation, and interview with the laboratory representative; the laboratory failed to evaluate results of bi-annual method accuracy (proficiency testing/peer reviewed Mohs micrographic surgery results) for eight of eight events from the beginning of 2024 through the date of survey, 12/08/2025, in the subspecialty of histopathology. Findings include: 1. Review of laboratory policies and procedures revealed the policy titled "[Quality Control/Quality Assurance] QC/QA Program", which stated, "3. Five surgical cases per quarter shall be reviewed by a Dermatopathologist. Their diagnoses shall be compared against each other and against the original diagnoses. If needed, appropriate action shall be taken and documented." 2. Review of laboratory records revealed a lack of documentation of evaluations of results upon receipt of peer reviewed Mohs micrographic surgery results for eight of eight reviewed biannual method accuracy events. Year, Quarter (Q): Results Reviewed: 2024 - Q1 No 2024 - Q2 No 2024 - Q3 No 2024 - Q4 No 2025 - Q1 No 2025 - Q2 No 2025 - Q3 No 2025 - Q4 No 3. Interview with the laboratory representative on 12/08/2025, at 2:11 pm, confirmed the laboratory failed to evaluate results of bi-annual method accuracy (proficiency testing/peer reviewed Mohs micrographic surgery results) for eight of eight events from the beginning of 2024 through the date of survey, 12/08/2025, in the subspecialty of histopathology. D5601 HISTOPATHOLOGY CFR(s): 493.1273(a)(f) (a) As specified in 493.1256(e)(3), fluorescent and immunohistochemical stains must be checked for positive and negative reactivity each time of use. For all other differential or special stains, a control slide of known reactivity must be stained with each patient slide or group of patient slides. Reactions of the control slide with each special stain must be documented. This STANDARD is not met as evidenced by: -- 2 of 3 -- Based on review of laboratory records, lack of documentation, and interview with the laboratory representative; the laboratory failed to document dermatopathology special stain known reactivity and immunohistochemical (IHC) stain positive and negative reactivity for two of three patients tested from the beginning of 2025 through the date of survey, 12/08/2025. Findings include: 1. Review of patient testing records for dermatopathological interpretations revealed one of three patients tested failed to document special stain known reactivity with each patient slide or group of patient slides. Report Date: Case #: Special Stain(s): 01/22/2025 DU25-00198 Periodic acid- Schiff (PAS) Gram Stain (GMS) 2. Review of patient testing records for dermatopathological interpretations revealed one of three patients tested failed to document IHC stain positive and negative reactivity each time of use. Report Date: Case #: IHC Stain(s): 06/09/2025 DU25-02307 PRAME SOX10 Melan-A P16 HMB45 3. Interview with the laboratory representative on 12/08/2025, at 4:53 pm, confirmed the laboratory failed to document dermatopathology special stain known reactivity and immunohistochemical (IHC) stain positive and negative reactivity for two of three patients tested from the beginning of 2025 through the date of survey, 12 /08/2025. -- 3 of 3 --

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Survey - April 19, 2023

Survey Type: Standard

Survey Event ID: X4TR11

Deficiency Tags: D5217

Summary:

Summary Statement of Deficiencies 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 review of laboratory records, lack of documentation, and interview with the laboratory consultant (LC), the laboratory failed to evaluate the biannual method accuracy for potassium hydroxide (KOH) mycology testing at least twice a year in 2021 and 2022. Findings include: 1. Review of the "Competency and Proficiency Testing Policy" revealed: a. "For Provider Performed Microscopy (PPM) testing: The Dermatology clinic utilizes the API program for KOH and CAP program for Scabies." 2. Review of laboratory proficiency testing records and lack of documentation revealed that the laboratory failed to evaluate and document the biannual method accuracy for potassium hydroxide (KOH) testing in 2021 and 2022. Affecting a total of 31 test results: a. Annual KOH testing volume (2021) = 7 b. Annual KOH testing volume (2022) = 24 3. On 04/19/2023 at 11:15 a.m., LC #2 stated, "The laboratory failed to enroll in proficiency testing for KOH in 2021 and 2022". Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 1 --

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Survey - August 7, 2018

Survey Type: Standard

Survey Event ID: IVPB11

Deficiency Tags: D5209 D5217 D5791

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 the surveyor's review of the Laboratory Personnel Report (CMS 209), the laboratory's policies, procedures and records, and an interview with the laboratory manager, the laboratory failed to establish written policies and procedures that meet the personnel requirements in subpart M to assess employees performing Microbiology testing, affecting 6 out of 6 testing personnel (TP). Findings: 1. The CMS 209 lists 6 licensed physicians performing Potassium Oxide (KOH), Scabies, and Tzanck testing in the laboratory. 2. The personnel documents revealed that 6 out of 6 TP have not received competencies for the years of 2016 thru 2018, but were performing patient testing during this period. 3. The laboratory's manual does not include an established competency policy and step-by-step procedure for TP performing KOH, Scabies, and Tzanck testing that includes the following personnel assessment requirements: a) Direct observations of routine patient test performance, including patient preparation, if applicable, specimen handling, processing and testing; b). Monitoring the recording and reporting of test results (for example, recording patients and their results in the labs' test log and/or EMR system); c). If applicable, review of intermediate test results or worksheets, quality control records, proficiency testing results, and preventive maintenance records; d). Direct observation of performance of instrument maintenance and function checks (i.e. microscope maintenance, etc.); e). Assessment of test performance through testing previously analyzed specimens, internal blind testing samples or external proficiency testing samples; and f). Assessment of problem solving skills; and g). Evaluating and documenting the performance of individuals responsible for moderately complex 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 -- testing at least semiannually during the first year the individual tests patient specimens. Thereafter, evaluations must be performed at least annually. 4. On a Recertification survey conducted on 08/07/2018 at 1:35 PM, the laboratory manager confirmed the above findings. 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 the surveyor's review of the laboratory's policies, procedures, test records, and an interview with the laboratory manager; the laboratory failed to verify the accuracy of tests performed in the specialty of Microbiology at least twice annually, affecting 242 patients. Findings: 1. The manual and test records reveal that the laboratory performs the following tests: Potassium Hydroxide (KOH), Tzancks, and scabies. 2. The laboratory's manual does not define the method and procedure the laboratory will use to verify the accuracy of its KOH, Tzancks, and scabies testing. 3. During the period of 07/30/2018 through 07/06/2018, the laboratory performed KOH testing on 242 patients. 4. On a Recertification survey conducted on 08/07/2018 at 1: 30 PM, the laboratory manager confirmed the above findings. D5791 ANALYTIC SYSTEMS QUALITY ASSESSMENT CFR(s): 493.1289(a)(c) (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 analytic systems specified in 493.1251 through 493.1283. (c) The laboratory must document all analytic systems assessment activities. This STANDARD is not met as evidenced by: Based on the surveyor's review of the laboratory's manual, records and an interview with the laboratory manager; the laboratory failed to establish and follow written policies and procedures for an ongoing mechanism to assess, and when indicated, correct problems identified in the analytic systems specified in 493.1251 through 493.1283. Findings: 1. The laboratory's freezer temperature charts revealed the following: a). It states that the acceptable temperature range of the freezer is -27 to -30 degrees. b). The recorded temperatures from December of 2017 through August 2018 were not within the required temperature range. c). No written evidence that the decreasing temperatures recorded on the charts (from 12/2017 thru 08/2018) had been identified as being out of the required temperature range. d). No documented evidence was provided to show

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