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CMS - Medicare/Medicaid Services/CLIA 

College of American Pathologists  POCT Requirements

Centers for Medicare & Medicaid Services (CMS

 CMS, formerly known as HCFA,   performs a number of quality-focused activities, including regulation of laboratory testing (CLIA) and quality-of-care improvement. The Centers for Medicare & Medicaid Services has a new website, cms.hhs.gov.  

http://www.hcfa.gov/medicaid/clia/cliahome.htm  CMS regulates all laboratory testing performed on humans in the U.S. through the Clinical Laboratory Improvement Amendments (CLIA). In total, CLIA covers approximately 175,000 laboratory entities. The Division of Laboratory Services, within the Survey and Certification Group, under the Center for Medicaid and State Operations has the responsibility for implementing the CLIA Program.

Amongst its various initiatives, CLIA has developed a quality improvement effort directed towards physician office laboratories and laboratory testing performed directly by physicians.  http://www.hcfa.gov/medicaid/clia/cowppmp.htm

Waived and Provider Performed Microscopy (PPMP) Tests
Under CLIA , waived laboratories perform only tests that are determined by FDA or CDC to be so simple that there is little risk of error. Laboratories with a PPMP certificate perform tests, using a microscope, during the course of a patient visit on specimens that are not easily transportable. In the State of New Jersey, existing NJ law defines additional regulatory requirements which go beyond the federal requirements and which take precedent.

Under CLIA, Waived laboratories must meet only the following requirements :

bulletEnroll in the CLIA program;
bulletPay applicable certificate fees biennially; and
bulletFollow manufacturers' test instructions.

The number and types of tests waived under CLIA have increased from 8 tests to approximately 40 since the inception of the program in 1992; thereby, the number of waived laboratories has grown exponentially from 20% to 56% of the total 174,500 laboratories enrolled. In the State of New Jersey, only the initial 8 tests waived in 1992 meet the criteria for State recognition as Waived.

Under CLIA, PPMP laboratories must meet only the following requirements :

bulletEnroll in the CLIA program;
bulletPay applicable certificate fees biennially; and follow
bulletCertain quality and administrative requirements.

PPMP laboratories represent 22% of the laboratories in the country; thus, 78% of the laboratories have no direct routine oversight. The regulations, however, do provide for inspections of waived and PPMP laboratories under certain circumstances.

1999 Pilot Study
Due to the increases in the types of tests waived, the large number of laboratories with no oversight, and the serious findings in complaint investigations of these waived laboratories, the States of Colorado and Ohio initiated on-site inspections of a random sample of CLIA waived and PPMP laboratories. These pilots consisted of focused on-site inspections ( Ohio did 100, Colorado did 95) with prior notification and screening of the laboratory to confirm whether the State's concerns about quality problems were correct. Significant quality and certification problems were identified in over 50% of these laboratories. If quality problems were found, the inspectors provided assistance to the laboratories to achieve accurate results. Ohio found 10 % and Colorado found 7% of the laboratories inspected to be testing beyond their certificate. These laboratories were performing moderate complexity tests and, if properly enrolled in CLIA, would be subject to biennial inspections and higher fees.

Expansion of Pilot Study-- (October 2000 through January 2001)
To follow-up and verify the scope and seriousness of these initial findings, CMS expanded this pilot to include 8 additional States across the nation. These states were Arizona , Idaho , Iowa , Massachusetts , Mississippi , New Mexico , New York , and Pennsylvania . Using Colorado and Ohio 's pilot as a model, CMS inspected 2.5% (or 436) of waived and PPMP laboratories in the 8 selected States. The inspections were conducted in the same manner as a routine compliance inspection, which entails an educational approach. CMS's findings are detailed below.

 Project Findings
Information gathered during this project is separated into waived and PPMP categories. The surveyors collected information on personnel performing waived testing. The four major categories of personnel performing waived testing were Registered Nurses (RNs), Physicians (M.D./D.O.s), Licensed Practical Nurses (LPNs) and Medical Assistants (Certified M.A.s). There were very few Medical Technologists (MTs) or Medical Laboratory Technicians (MLTs) involved in the performance of waived testing. The quality and certificate problems found under the expanded October 2000 through January 2001 survey process are listed below.

Quality Problems in Waived Laboratories
- 32 % failed to have current manufacturer's instructions;
- 32% did not perform QC as required by manufacturer or CDC;
- 16% failed to follow current manufacturer's instructions; and
- 7% did not perform calibration as required by manufacturer.

Additional Quality Problems in Waived Laboratories
- 23% had certificate issues (i.e., change of name, director or address);
- 20% cut occult blood cards and urine dipsticks;
- 19% had personnel who were neither trained nor evaluated;
- 9% did not follow manufacturer's storage and handling instructions; and
- 6% were using expired reagents/kits.

Quality Problems in PPMP Laboratories
- 38% had no PT (did not evaluate test accuracy 2 times a year);
- 36% had no microscope/centrifuge maintenance;
- 28% no director approved SOPM;
- 25% did not document personnel competency (QA); and
- 23% had certificate issues.

CAP Regulations on POCT

Checklist Changes
Overview
Inspection Process
Quality Control
Proficiency Testing
Reagents
Procedure Manuals
Testing Personnel

 

CAP Information

New Checklists Includes Many Changes

The new POCT checklist includes many new changes.  In addition, CAP has clarified a lot of question in their commentary and defined a lot of new terms. If interested in comparing the new and old version of the checklists, visit www.cap.org/html/ftpdirectory/compare.html.

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Overview

According to CAP, Point of Care Testing refers to those analytical patient tests provided within the institution, but performed outside the physical facilities of the clinical laboratories.  The central criterion of POCT is that it does not require permanent dedicated space.  This type of testing is performed by a large number of different non-laboratory healthcare personnel who have other patient care responsibilities in addition to POCT.  Another key aspect that distinguishes POCT from main laboratory testing is that it utilizes instruments and kits that are hand-carried or otherwise transported to the vicinity of the patient for immediate testing at that site.  POCT does not include limited service satellite laboratories with fixed dedicated testing space; these are covered under the Limited Service Laboratory Checklist.  

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The Inspection Process

When records are maintained centrally by a designated coordinator or POCT Director, only one copy of this Point of Care Testing Checklist need be completed.  The Inspector will review all centrally maintained records and visit at least a sampling of the testing sites in order to evaluate compliance with the standards.  If records are not maintained centrally, the Inspector must visit each POCT site, and a separate checklist must be completed for each location.  In the latter case, each POCT site will be billed as an additional laboratory section.

To be accredited, all analytes being measured under the POCT program/site must be included in the on-site inspection and comply with the CAP Standards for Laboratory Accreditation.  POCT programs may be inspected as sections of the central laboratory if they are registered under the same CLIA-88 number.  In this circumstance, they are included in the Laboratory General Checklist used for the central laboratory.  If the POCT sites are registered under separate CLIA numbers, a separate Laboratory General Checklist must be completed for each POCT program.  

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Quality Control

Quality control samples are samples that act as surrogates for patient specimens.  They are to be periodically processed like a patient sample to monitor the ongoing performance of the entire analytic process, and must be judged acceptable prior to reporting patient results.  They must be evaluated and organized such that they can be used daily by the testing personnel or supervisory technical staff to detect problems, trends, etc.  It is implicit that quality control specimens be tested in the same manner as patient specimens.  Moreover, QC specimens must be analyzed by personnel who routinely perform patient testing-this does not imply that each operator must perform QC daily, so long as each instrument/test system has QC performed at required frequencies.  

Most quantitative tests are traditionally monitored with two levels of liquid QC.  This is to be done at a frequency within which the accuracy and precision of the measuring system is expected to be stable, but at least each day that patient testing is performed.  The daily use of two levels of liquid QC may not be required for certain test systems where the daily use of electronic controls is demonstrably sufficient.  

For hematology, coagulation, and blood gas tests, two different levels of control material are required during each eight hour period of patient testing and each time there is a change of reagents. 

For qualitative tests, a positive and negative control must be included with each run of patient specimens.  As an exception to this general practice, the specific frequency of such testing for multiparameter urine chemistry dipsticks may vary according to workload and testing location, and may not occur with each run.  However, the frequency must be defined and followed by the laboratory. 

For direct bacterial or viral antigen tests that include internal positive and negative controls, a positive and negative external control must be tested with each new kit lot number or separate shipments of a given lot number.  Internal quality control tests can be used for subsequent testing, based upon the manufacturers’ recommendations. 

Oversight review of quality control must occur at least monthly by the Laboratory Director or designee.  Beyond the specific CAP requirements, a laboratory may perform more frequent review at intervals that it determines appropriate for its setting and the assays involved.  Because of the many variables, CAP makes no specific recommendations on the frequency of any additional assessment/review of QC.

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Proficiency Testing

POCT programs must participate in a CAP-approved proficiency program of interlaboratory comparison testing appropriate to the scope of their program.  Proficiency testing is required for all analytes regardless of their CLIA classification.  When possible, the proficiency testing samples must be processed as patient samples, and analyzed by personnel who routinely test patient samples, using the same method.  Further, these samples should be periodically rotated among all analyzers used for testing, and among all testing personnel.     

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Reagents

In the POCT setting, it is very important to verify reagent performance because reagents may be stored under a variety of uncontrolled conditions.  This verification is required by CAP.  Any of several methods may be used.  Such as direct analysis with reference materials, parallel testing of old vs. new reagents, and checking against routine controls.  The intent of the CAP requirements is for new reagents to be checked by an appropriate method and the results recorded before being placed in service.   Where individually packaged reagents/kits are used, there should be criteria established for monitoring reagent quality and stability.  Running “wet controls” is a typical way of validating the reagent quality and operator technique.  

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Procedure Manuals

Procedures should be written in substantial compliance and meet the intent of the NCCLS GP2-A3 document without having to precisely copy it.  Procedures should be available to all testing personnel.  Electronic manuals are acceptable, so long as the electronic versions are readily available to all personnel.  There is no requirement for paper copies to be available for the routine operation of the laboratory.  It is suggested, however, that current paper copies of electronically stored procedures be available at the time of the CAP inspection, or rapidly generated at the request of the inspector. 

Manufacturer inserts or procedure manuals for an instrument or reagent system may not be used as a replacement for a department procedure.  It may be used as part of the procedure description if the insert accurately describes the procedure performed in the laboratory.  Any modification to, or deviation from the procedure must be clearly explained and documented.

The Director of the POCT program is responsible for ensuring that the collection of policies and procedures is complete, current, and has been thoroughly reviewed by a knowledgeable person.  Therefore, there must be documentation of at least annual review of all policies and procedures for POCT by the current Director or designee.  Signature review must be at the level of each procedure, or as multiple signatures on a listing of named procedures.  A single signature on a Title Page or Index of all procedures is not sufficient documentation that each procedure has been carefully reviewed.  In addition, a signature on each page of a procedure is not required.   

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Testing Personnel

It is required that each facility performing POCT have a documented program to ensure that each person performing point-of-care testing maintains satisfactory levels of competence.  The records must clarify what skills are assessed and how those skills are measured.  The laboratory must have a system documenting that all personnel are knowledgeable about the contents of the procedures in which they perform.  This does not specifically require annual procedure sign-off by testing personnel.  However, the form of this system should be defined by the POCT Laboratory Director and followed.

References:

College of American Pathologists; Commission on Laboratory Accreditation, Laboratory Accreditation Program, Point of Care Testing Checklist, October 2001.

 This section is taken from: http://www.pointofcare.net/regulatory/cap_regs.htm

 

 

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Last modified: August 03, 2005