Details of CLIA Final QC Regulatory Changes

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Transcript Details of CLIA Final QC Regulatory Changes

Details of CLIA Final QC Regulatory Changes

Division of Laboratory Services CMS

Overview

Consolidates Subpart J, K, and P into:

– J-Facility Administration for Nonwaived Testing.

– K-Quality System for Nonwaived Testing.

– Creates one set of Nonwaived requirements.

– Parallels the flow of a specimen through the laboratory.

– Reflects the Total Testing Process: • General Laboratory Systems • Preanalytic Systems • Analytic Systems • Postanalytic Systems

Subpart A General Provisions

Revisions:

– Definitions for calibration, FDA-cleared or approved, reportable range & test system.

– Replaced National Institute for Drug Abuse (NIDA) with Substance Abuse & Mental Health Services Administration (SAMHSA).

Subpart I Proficiency Testing

Revisions:

– Changed consensus for PT program grading from 90% to 80% .

• Reduces number of ungradables.

• Permits labs to “get more for their money”.

• Facilitates better laboratory education; e.g., error ID & correction.

Subpart J Facility Administration

Revisions:

– Applies to moderate & high testing.

– Facility requirements.

• Safety precautions are accessible.

• Uni-directional workflow for molecular amplification procedures.

• Comply w/ Federal, State & local laws.

Subpart J Facility Administration

Revisions:

– Transfusion Services • Report transfusion reactions/fatalities to laboratory & authorities.

– Record/Specimen Retention • Preservation.

• Record retention for closed facilities.

• Keep test procedure & performance specifications for 2 years after use.

Subpart K Quality System

Applies to moderate & high testing.

– General Laboratory Systems.

– Preanalytic Systems.

– Analytic Systems.

– Post analytic Systems

.

• Emphasizes Quality Assessment.

Subpart K Quality System

Quality assessment (QA) requirements

– Monitor and assess quality.

– Correct problems.

– Review effectiveness of correction.

– Discuss with staff.

– Document assessment activities.

Included in each phase of testing

Subpart K Quality System

General laboratory Systems:

– Confidentiality of patient information.

– Specimen identification & integrity.

– Complaint investigations.

– Communications.

– Personnel Competency Assessment Policies.

– Evaluation of PT performance.

Subpart K Quality System

Evaluation of PT Performance:

Verify accuracy of:

- Tests w/ no evaluation or score.

- Tests when PT score doesn’t reflect test performance.

- Any test not included in Subpart I. - Regulated analytes for which compatible PT material isn’t available from PT providers twice a year.

Subpart K Quality System

Preanalytic Systems

Test request:

– Solicit patient’s gender, age or DOB.

– Solicit specimen source, when appropriate

.

Specimen submission, handling and referral:

– Date and time of receipt in laboratory.

Subpart K Quality System

Analytic Systems

Procedure Manual:

– Director must sign procedures & changes prior to use.

– Retain test procedures with the dates of initial use and discontinuance

.

Subpart K Quality System

Analytic Systems

Test systems, equipment, instruments, reagents, materials, and supplies:

– Removed the FDA product dating information to guidelines. – Follow manufacturer’s instructions for storage of reagents, specimens & test systems

.

Subpart K Quality System

Analytic Systems

Maintenance and function checks:

– Follow manufacturer’s instructions for maintenance & function checks.

Calibration and calibration verifications:

– Provides flexibility for calibration verification material.

Subpart K Quality Systems

Analytic Systems

Establishment and Verification of Performance Specifications:

– Applies to new or modified nonwaived tests.

– Verify/establish accuracy, precision, reportable range.

– Verify/establish manufacturer’s normal values.

– Determine calibration & control procedures.

– Establish analytical sensitivity & specificity.

Subpart K Quality System

Analytic Systems

Control Procedures:

– Detect immediate errors and monitor over time.

– Requires a control system capable of detecting reaction inhibition for molecular amplification.

– Test 2 controls/day or acceptable alternative.

– Use of calibrators as controls.

– Rotate QC testing among all operators.

Subpart K Quality System

Analytic Systems

Bacteriology:

– Check each batch, lot number and shipment of reagents, disks, stains, antisera, and identification systems when prepared or opened for positive and negative reactivity (and graded reactivity, if applicable).

• Less stringent for catalase, Cefinase, Tm coagulase, oxidase, bacitracin, optochin, ONPG, X,V and XV disks or strips – Check each batch, lot number and shipment of antisera for positive and negative reactivity when prepared or opened, and once every 6 months thereafter.

• Less stringent

Subpart K Quality System

Analytic Systems

Mycobacteriology:

– Check fluorochrome acid-fast stains for positive and negative reactivity each time of use.

• More stringent – Check acid-fast stains for positive and negative reactivity each day of use.

• More stringent – Each day of use check all reagents, test procedures for mycobacterial identification using positive and negative acid-fast organisms.

• More stringent

Subpart K Quality System

Analytic Systems

Mycology:

– Check each batch, lot number and shipment of reagents and fungal identification tests (germ tube) when prepared or opened for positive and negative reactivity (and graded reactivity, if applicable).

• Less stringent - frequency • More stringent - added negative control – Check each batch, lot number and shipment of lactophenol cotton blue when prepared or opened for intended reactivity with a control organism(s).

• Less stringent

Subpart K Quality System

Analytic Systems

Parasitology:

– No changes.

Virology:

– No changes.

Routine Chemistry:

– No changes.

Subpart K Quality System

Analytic Systems

Syphilis Serology and Immunology:

– Control testing reduced to each day of testing.

Hematology:

– Reduced automated hematology QC to once/day.

– Manual hematology requires QC each 8 hours of testing.

– No change to QC for coagulation (manual or automated).

Subpart K Quality System

Analytic Systems

Immunohematology:

– Includes only specific cites for FDA BB (21 CFR) requirements under CLIA.

Histopathology:

– Check immunohistochemical stains for positive & negative reactivity each time of use.

– Allows individuals trained in neuromuscular pathology to report neuromuscular path results.

Subpart K Quality System

Analytic Systems

Cytology:

– Workload limit for liquid-based slide preparatory techniques reduced from 200 to 100 for gynecologic preparations.

– Provision for automated, semi-automated screening devices added to require manufacturer’s instructions (including individual workload limits) be followed.

Subpart K Quality System

Analytic Systems

Clinical Cytogenetics:

– Resolution is appropriate for type of tissue or specimen & study required based on clinical information provided.

– Requires full chromosome analysis for sex determination.

– Utilize the International System of Cytogenetic Nomenclature on report.

Subpart K Quality System

Analytic Systems

Histocompatibility:

– Requires in-house prepared reagent typing inventory to indicate reagent specificity.

– Requires a technique that detects HLA specific antibody w/ a specificity equivalent or superior to the basic microlymphocytotoxicity assay.

– Requires using a method that distinguishes antibodies to HLA class II antigens from antibodies to Class I antigens.

Subpart K Quality System

Analytic Systems

Histocompatibility cont’d:

– Have available monthly specimens for periodic antibody screening & crossmatch on all potential transplant recipients; and develop a policy consistent w/ clinical transplant protocols for frequency of such antibody screening.

– Define test protocols for each type of cell, tissue or organ to be transfused or transplanted.

Subpart K Quality Systems

Analytic Systems

Histocompatibility cont’d:

– Follow policies that address when HLA testing & final crossmatches are required for pre sensitized non-renal transplant recipients.

– Establish technique to optimally define HLA Class I & II specificity.

– Eliminates monthly evaluation of a specimen as an unknown by each testing person.

Subpart K Quality System

Postanalytic Systems

Test Report:

– State date of test report on report & include specimen source, if applicable.

– Include name & ID no. or unique patient identifier & ID no.

Subpart M Personnel

Applies only to doctoral degree (non-MD) qualifications:

– Represents only remaining complexity dependent requirements.

– As of 2/24/03 “grandfathers” individuals currently as high complexity directors.

– Requires board certification for

new

directors

.

– Approved Boards to be listed in Appendix C of Surveyor Guidelines and on website.

CLIA FINAL QC REGULATIONS

CONTACT INFORMATION:

– CMS WEB SITE: www.cms.hhs.gov

/clia – CMS LAB DIVISION: 410-786-3531(phone) 410-786-1224 (fax)

THE END THANK YOU!!

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