Summary:
Summary Statement of Deficiencies D3011 FACILITIES CFR(s): 493.1101(d) Safety procedures must be established, accessible, and observed to ensure protection from physical, chemical, biochemical, and electrical hazards, and biohazardous materials. This STANDARD is not met as evidenced by: Based on observation of the histopathology department and interview with the Histotechnologist, the laboratory failed to establish and follow safety procedures to keep 3 of 3 containers of Xylene in the correct storage area on the date of survey. Findings: 1. Epredia Xylene Safety Data Sheets (SDS) states for storage of xylene reagent, " Keep containers tightly closed in a dry, cool and well-ventilated place. Keep away from heat, sparks, flame and other sources of ignition (i.e., pilot lights, electric motors and static electricity). Keep in properly labeled containers. Do not store near combustible materials. Keep in an area equipped with sprinklers. Store in accordance with the particular national regulations. Store in accordance with local regulations. Store locked up. Keep out of the reach of children. Store away from other materials." 2. The surveyor observed on 9/14/2022 at 09:25, 3 of 3 bottles of Xylene were in a cabinet with other laboratory reagents in the Histopathology area, the cabinet was not appropriate for storage of flammable reagents. 3. Interview with the HT, on 09/14/2022 at 09:30 am, confirmed the above findings. 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. 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 -- This STANDARD is not met as evidenced by: A. Based on review of the laboratory's competency policy, competency assessment records and interview with the Laboratory Manager (LM), the laboratory failed to establish a competency assessment procedure to assess the competency of 1 of 2 Technical Consultants (TC), 1 of 2 Technical Supervisors (TS), and 1 of 12 General Supervisors (GS) for their supervisory roles from 06/17/2020 to the date of survey. Findings include: 1. On the day of survey, 09/14/2022 at 09:33 am, the LM could not provide a competency assessment policy to assess the competency of the following personnel for their supervisory skills from 06/17/2020 to 09/14/2022: - 1 of 2 TC (on CMS 209, personnel #2) - 1 of 2 TS (on CMS 209, personnel #2) - 1 of 12 GS (on CMS 209, personnel #2) 2. The LM could not provide documentation for delegation of duties for the TS,TC,GS (CMS 209, personnel #2). 3. The LM confirmed the findings above on 09/15/2022 around 02:15 pm. B. Based on review of the laboratory's Employee Competency procedure, annual competency records, and interview with Laboratory Manager (LM), the laboratory failed to establish a complete procedure that includes all six components required for competency assessment for 13 of 13 Testing Personnel who performed Hematology, Routine Chemistry, Urinalysis, Microbiology and Immunohematology examinations from 06 /17/2020 to the date of survey. Findings include: 1. On the day of survey, 09/14/2022 at 10:40 am, the competency assessment policy reviewed at the time of survey did not include the six points of CLIA required for competency assessment. 2. The LM confirmed the findings above on 09/15/2020 around 02:15 p.m. *This is a repeat deficiency. D5215 EVALUATION OF PROFICIENCY TESTING PERFORMANCE CFR(s): 493.1236(b)(2) The laboratory must verify the accuracy of any analyte, specialty or subspecialty assigned a proficiency testing score that does not reflect laboratory test performance (that is, when the proficiency testing program does not obtain the agreement required for scoring as specified in subpart I of this part, or the laboratory receives a zero score for nonparticipation, or late return or results). This STANDARD is not met as evidenced by: Based on review of the American Proficiency Institute (API) proficiency testing (PT) records and interview with the laboratory manager (LM), the laboratory failed to verify the accuracy for PT testing performed in 2020, 2021, and 2022. Findings Include: 1. On the day of survey, 09/14/2022 at 10:30 am, review of the laboratorys API proficiency testing records revealed that the laboratory did not verify the accuracy for the following analytes that were not graded by the proficiency testing agency: a.) 2022 Microbiolgy 2nd Event: -12 of 12 Blood Culture MIC/Zone Diameter Value -12 of 12 Blood Culture Susceptibility Interpretation -12 of 12 Urine Culture MIC/Zone Diamether Value b.) 2022 Immunology/Immunohematology 1st Event: -1 of 5 Antigen Identification (Blood Bank Compatibility) -1 of 5 Ortho ID- MTS Anti-IgG Gel Test c.) 2022 Microbiology 1st Event: -9 of 9 CSF Culture MIC /Zone Diameter Value -9 of 9 CSF Culture Susceptibility Interpretation -1 of 5 Gram Stain -8 of 8 Urine Culture MIC/Zone Diameter Value d.) 2021 Hematology /Coagulation 2nd Event: -1 of 5 Blood Cell Identification -1 of 2 Sperm Count (Hemacytometer) e.) 2021 Immunology/Immunohematology 3rd Event -1 of 5 Antigen Identification (Blood Bank Compatibility) f.) 2021 Chemistry Event #2: -1 of 2 Folate g.) 2021 Chemistry-Miscellaneous 1st Event -1 of 3 Body Fluid Creatinine -- 2 of 5 -- h.) 2020 Microbiology 3rd Event: -1 of 2 Wound Culture (non consensus) i.) 2020 SARS-CoV2 3rd Event: -1 of 2 SARS-CoV2 Liquid (Molecular) 2. The LM confirmed the findings above on 09/15/2022 around 02:15 pm. 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)