Massachusetts General Hospital Point of Care Testing Program

Similar documents
Standards for Laboratory Accreditation

TITLE: POINT OF CARE TESTING

Quality Assurance Program For Hospital Based Point of Care Testing. Presented by: Jeanne Mumford, MT(ASCP) Pathology Supervisor, QA Specialist

CAP Forensic Drug Testing Accreditation Program Standards for Accreditation

College of American Pathologists 325 Waukegan Road, Northfield, Illinois Advancing Excellence

CAP Most Frequent Deficiencies and How to Avoid Them. March 11, 2015

Policy Subject Index Number Section Subsection Category Contact Last Revised References Applicable To Detail MISSION STATEMENT: OVERVIEW:

Standards for Forensic Drug Testing Accreditation

Medicare Program; Announcement of the Approval of the American Association for

Medicare Program; Announcement of the Reapproval of the Joint Commission as an

Point of Care Testing

TESTIMONY OF THOMAS HAMILTON DIRECTOR SURVEY & CERTIFICATION GROUP CENTER FOR MEDICAID AND STATE OPERATIONS CENTERS FOR MEDICARE & MEDICAID SERVICES

Heart of America POC Group Quality Management Making it Meaningful

Scope of Service. Department Mission

Internal Lab Inspections: Are You Inspection Ready? Presented by: Jeanne Mumford, MT(ASCP) Manager, Point of Care Testing, JHM

Standards for Biorepository Accreditation

Fulton County Medical Center. Position Description. Pathologist, Laboratory Manager, and Medical Technologist

Personnel. From RLM, COM, GEN and TLC Checklists

ASSEMBLY BILL No. 940

IQCP. Ensuring Your Laboratory s Compliance With Individualized Quality Control Plans. November/December 2016

6/28/2016. Questions? Workshop 6 CAP Inspection Preparation Thursday, June 23, 2016

CE Update [generalist compliance/regulation management/administration and training] COLA Accreditation An Educational Experience

QC Explained Quality Control for Point of Care Testing

PROGRAM GUIDE - UNIVERSITY CLIA REGISTERED LABORATORIES COMPLIANCE COMMITTEE

Improving Your POC Program: An Upside Down Map. Sheila K. Coffman MT(ASCP)

EDUCATIONAL COMMENTARY KEY COMPONENTS OF AN INDIVIDUALIZED QUALITY CONTROL PLAN

Joint Commission Laboratory Accreditation: Why It Is Right For Your Organization

COMMISSION ON LABORATORY ACCREDITATION. Laboratory Accreditation Program TEAM LEADER ASSESSMENT OF DIRECTOR & QUALITY CHECKLIST

Point of Care Testing Clinical Practice Standard and Policy (LTR31449) Version: 2.01

The CLIA regulations..

C A L I F O R N I A L A B O R AT O RY P E R S O N N E L

Quality Laboratory Practice and its Role in Patient Safety

Individualized Quality Control Plan (IQCP) Frequently Asked Questions Date: May 5, 2015 (last updated 08/21/2017)

IQCP January Is Coming Fast What Do I Do?!? Jean Ball Bold, MBA, MT(HHS), MLT(ASCP

Tutorial: Basic California State Laboratory Law

Catholic Health Initiatives

Point of Care Testing. BOPCC May 31, 2011 Beatrice O Keefe, Chief Laboratory Field Services California Department of Public Health


MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY

Protecting, Maintaining and Improving the Health of Minnesotans

Delegated Credentialing A Solution to the Insurer Credentialing Waiting Game?

PERSONNEL REQUIREMENTS. March 9, 2018

Rapid Specimen Testing In the Medical Office (POCT)

THE SURVEY PROCESS THE ALF/SCALF SURVEY PROCESS 1/14/2016. Assisted Living Facilities and. Specialty Care Assisted Living Facilities

Best Practices for Equipment Calibration and Analytical Controls in the Diagnostics Laboratory

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY 3. NAME AND ADDRESS OF FACILITY

Laboratory Risk Assessment: IQCP and Beyond. Ron S. Quicho, MS Associate Project Director Standards and Survey Methods, Laboratory July 18, 2017

Nestor A.Guerrero,BSMT,RMT,CLS,MT(ASCP) Major (Ret), US Army Medical Service Corps

CLIA s New IQCP Requirements Are in Effect, or Are They?: Implementing Laboratory Risk Management Now to Ensure Success

2018 CREDENTIALING COMMITTEE PROGRAM DESCRIPTION

Centers for Medicare and Medicaid Services (CMS) Survey and Certification Group (SCG) Mission:

Gary Nederhoff, Unit Supervisor

Patricia Halverson, Unit Supervisor

Emergency Medical Services Division. Paramedic Preceptor Accreditation Policy August 25, 2014

Delegation Oversight 2016 Audit Tool Credentialing and Recredentialing

Laboratory Services Policy, Professional

RULES OF PROCEDURE FOR TESTING LABORATORY ACCREDITATION

Life Cycle of A New Point of Care Test Request. Managing the Chaos

Department of Environmental Health and Safety Laboratory Inspection Protocol

RULES OF PROCEDURE FOR CALIBRATION LABORATORY ACCREDITATION

VUMC Office of Research Research Core Facilities/Shared Resources 2015 Professional Development Track. Core Research Assistant I

Hannah Poczter, AVP, Laboratories, Cari Gusman, Administrative Director, Ed Giugliano, PhD, Project Manager, Certified Six Sigma Black Belt

Ch. 79 FIREARM EDUCATION COMMISSION CHAPTER 79. COUNTY PROBATION AND PAROLE OFFICERS FIREARM EDUCATION AND TRAINING COMMISSION

Highmark Reimbursement Policy Bulletin

The Future is Now: Global Application of CLSI and ISO:15189 Quality Management Systems

Subject: Quality Management for Origin date: 3/06 Point of Care and Waived Testing Reviewed: 2009 /2010 Revised: 2/2009

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL. PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY Facility ID: 00858

US ): [42CFR ]:

Point of Care Quality Management. Procedure. Approving Authority: President and CEO, Keith Dewar

POINT OF CARE TESTING MED Laboratory Branch Kim DeGroat, RMLS - Frankfurt Region Wilfred Lovelock, RMLS - Dakar Region

What s New in Point-of-Care Testing (POCT)? Marjorie W. Doty, MT(ASCP)SBB OneBlood, Inc. St. Petersburg, FL

March 2017 HOME HEALTH CONDITIONS OF PARTICIPATION (COPS) FAQ

Plan for Quality to Improve Patient Safety at the POC

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY

Content Sheet 11-1: Overview of Norms and Accreditation

James Anderson, State Fire Marshall

POLICY SUBJECT: POLICY:

CHALLENGES IN POCT. Dr. Jayesh P. Warade. Consultant Biochemistry and Quality Manager, Meenakshi Mission Hospital and Research Centre, Madurai, India

TABLE OF CONTENTS DELEGATED GROUPS

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL. PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY Facility ID: 00719

IACUC Policy 09: Researcher Non-Compliance

Emergency Medical Dispatch Provider Criteria for Endorsement

Administrative Safety

The Practice of Clinical Pathology A Quantitative Description of Laboratory Director Activities at a Large Academic Medical Center

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL. PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY Facility ID: 00695

Brenda Fischer, Unit Supervisor 09/13/2012 Colleen B. Leach, Program Specialist 09/18/2012

Authorized Personnel to Review

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL. PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY Facility ID: 00712

Michelle McFarland, HFE NEII

A COLA White Paper: FEDERAL GOVERNMENT QUESTIONS QUALITY IN WAIVED TESTING.

MEDICARE/MEDICAID CERTIFICATION AND TRANSMITTAL. PART I - TO BE COMPLETED BY THE STATE SURVEY AGENCY Facility ID: 00351

CHAPTER FIFTEEN- NEGATIVE ACTIONS

What s New and Improved for the Laboratory Program in 2013 April 23, 2013

Key Issues in HFAP Accreditation. Beverly Robins, RN, BSN, MBA Director of Accreditation October 25, 2012

Compliance and Enforcement Standards Pursuant to the Nova Scotia Day Care Act and Regulations

Guidance for the assessment of centres for persons with disabilities

International Association for Chemical Testing Recommendations for Evidential Breath Alcohol Personnel

07/23/ /21/2013 (L20)

College of Physicians and Surgeons of Saskatchewan Laboratory Quality Assurance Program. Policy Manual Edition

Transcription:

Title: POCT Program description Cross References: POCT Program Massachusetts General Hospital - Pathology Service 55 Fruit Street, Boston, MA 02114 Massachusetts General Hospital Point of Care Testing Program Program for Addressing Point-of-Care Testing Compliance with the Clinical Laboratory Improvement Amendments of 1988 Approved 1994 Updated December 27, 2012 Kim Gregory MT (ASCP), NCA, CLS - Associate Director, POCT Approved by: Kent Lewandrowski MD, 12-4-12

OVERVIEW OF CONTENTS PROGRAM Introduction Program Objectives Scope Program Summary Site Enrollment Responsibilities of the Pathology Service Responsibilities of Testing Site POCT Site Management Billing Supply Management POCT program useful links Program overview http://www.massgeneral.org/pathology/clinical/poct.aspx Approved testing list /Point of Care Testing Documentation Guide http://www.massgeneral.org/pathology/assets/poct/qc_storageorderingd ocumentationguide10_20_11.pdf Procedure manual http://www.massgeneral.org/pathology/clinical/poct_manual.aspx 2

INTRODUCTION In 1992, the Department of Health and Human Services (DHHS) issued regulations that established minimal federal standards for laboratory testing under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88). These standards apply to all clinical testing, whether performed in a traditional clinical laboratory, or other sites such as hospital care units or physicians offices. The law consists of four separate sets of regulations: 1) Laboratory standards 2) Application and user fees 3) Enforcement procedures 4) Approval and accreditation programs To perform laboratory testing, a site must be covered by a CLIA certificate issued by CMS. The Pathology Service has CLIA certificates that cover the Anatomic and Clinical Pathology Laboratories on the MGH Main Campus as well as the Health Center Laboratories. However, these certificates do not cover testing performed at sites that are not part of the Pathology Service and may not be used for billing purposes by other sites. PROGRAM OBJECTIVES 1. To identify and authorize sites outside the Pathology Service to perform selected laboratory testing. Authorization involves inclusion of the sites under the appropriate CLIA certificate. 2. To ensure that testing sites meet federal regulatory requirements mandated by law under the Clinical Laboratory Improvement Amendments of 1988 and Joint Commission standards required for hospital accreditation. 3. To maintain a single standard of quality throughout the institution. 3

SCOPE The MGH POCT program assists MGH sites using POCT technology with CLIA compliance and relevant quality and safety initiatives. These sites include practices, clinics, inpatient units, operating and procedure rooms. Practices with a MGPO component will be assisted to the extent that consistent standards of patient care are maintained. By definition, any MGPO activity is not part of the MGH organization and therefore not subject the MGH regulatory process. The MGH POCT program will assist MGPO to obtain appropriate CLIA certification. The practice leadership is responsible for meeting all relevant POCT regulations. PROGRAM SUMMARY The program expects each site to take responsibility for all aspects of testing performed at their site. In most instances, the director on a certificate (Certificate Director) is a staff pathologist with the Pathology Service. The following administrative personnel must be identified for each department: Site Director (Clinical Consultant) Site Coordinator 1 (General Supervisor) Site Coordinator 2 (General Supervisor) The Site Director has ultimate responsibility for insuring that all regulatory standards and requirements are met at their site. The Site Director is expected to identify a primary Site Coordinator and back up who will act as contacts for their site and will be responsible for the day-to-day operation of the Point of Care Testing Program. (See Responsibilities of Testing Site on page 7 of POCT Enrollment Form) Since one certificate may cover multiple testing sites or departments, a site unable to maintain expected compliance can affect other sites sharing that certificate. Sites not in compliance will be expected to develop a remedial action plan to correct deficiencies, be placed on probation, and/or suspend testing if compliance is not maintained. 4

SITE ENROLLMENT Prior to implementing a testing program a site must: 1. Notify the Pathology Service s Associate Director for POCT of their intentions. 2. Complete an MGH POCT Enrollment form and/or HCFA 116 form and agree to the program policies. 3. Work with the Pathology Service to evaluate request for clinical need. 4. Agree to meet the minimal standards of compliance, based on the level of testing desired to be performed. 5. The Pathology Service will process the CLIA application with the State Department of Public Health and relevant regulatory agencies (if required). The site may not begin testing until this process is complete. If a site is performing testing without a certificate: 1. The Pathology Service will notify the Site Director and Hospital Administration of the site s non-compliance. 2. If continued testing at the site may place a patient at risk, the site will be expected to discontinue testing while implementing the program. 3. If the test(s) may be discontinued and performed by the laboratory without risk to the patients, the site will be expected to discontinue testing while implementing the program. 4. If the test(s) can be performed at the site without risk to patients, the site will be allowed to continue testing, provided that they submit an acceptable timetable for compliance within 10 business days. Adding or Removing a Test 1. To add a test or technology, the site enrollment process is followed. 2. To remove a test: a. Reagents, supplies, and devices are removed from the site b. The CLIA certificate is modified to reflect the change, and c. All relevant documents should be maintained for 4 years. 5

RESPONSIBILITIES OF THE PATHOLOGY SERVICE 1. Provide Technical Supervisor oversight of POCT at MGH Sites. 2. Ensure that sites enrolled in the program are covered by a CLIA certificate and the appropriate agencies are notified of additions or changes. 3. Perform periodic review of testing sites to assess compliance with regulatory and accreditation standards. Periodic reports will be submitted to the Pathology Division of L&MM leadership and hospital leadership (if needed). 4. Manage the remedial action process for sites that do not meet regulatory standards. The remedial action process will ensure the quality of the tests performed; patient safety and maintain the viability of the CLIA certificates. The remedial action process, if necessary, will include placing a site on probationary status which could lead to the revocation of privileges to perform clinical testing under the certificate. 5. Assist sites in the development and review of policies/procedures that cover test and quality control procedures, quality assurance, training/competency assessment, documentation, results reporting and proficiency testing (if required). 6. Provide consultative services to hospital and individual test sites including: Regulatory requirements associated with point of care testing. Technical issues involving test procedures, method selection/validation and failed device support. Clinical issues concerning test methods/results and clinical implications. 7. Review, standardize, and approve technology. 8. Manage device connectivity set-up between testing site and Information Systems. 6

RESPONSIBILITIES OF THE TESTING SITE 1. Designate a Point of Care Testing Site Director (or Clinical Consultant) who will be responsible for ensuring compliance with the regulatory requirements and recommendations described in the POCT program document. Including: Ensures that staff complies with all regulations, standards and program requirements. Reviews and signs policies and procedures annually. Reviews, validates, signs and returns the POCT Renewal Form to the Pathology Service annually. Develops, reviews approves and implements remedial action plans as needed. Ensures that the sites are enrolled in a proficiency testing program, if required. Reviews & signs proficiency testing survey, if required to participate. Participate in Joint Commission preparation and review. 2. Designate a Point of Care Testing Site Coordinator who is responsible for day-today operation of POC Testing and ensuring that the required elements for compliance are performed and documented. This individual will: Be the contact person for the MGH POCT Coordinators and Associate Director. Read and become knowledgeable with all testing policies/procedures performed at the site. Ensure that current test and quality control procedures are available for each test performed and that they are reviewed and signed by the Site Director each year. Ensure that there is documented evidence of initial orientation, yearly continued education and competency assessment. Ensure that testing personnel adhere to the policies and procedures. Ensure that logs and worksheets are periodically reviewed, signed and dated (at least once/month). Ensure that staff complete and document remedial action in a timely manner. Ensure that required maintenance is performed and troubleshooting problems are addressed and documented. Provide the MGH POCT program staff with required information to assess compliance in a timely fashion. If required, ensure that proficiency testing is performed as mandated by CLIA. Participate in Joint Commission preparation and review. 3. Incorporate the CLIA Standards into the site s practice and workflow. a. Patient Test Management b. Quality Control c. Proficiency Testing d. Test Comparisons e. Relate results to clinical data f. Personnel g. Communications h. Complaints i. Staff review j. Records 7

4. Meet all applicable CLIA and Joint Commission standards. POCT SITE MANAGEMENT Once enrolled, the site will participate in a yearly or twice yearly review. Testing may not be authorized without this certification. Renewal of certification is contingent upon continued compliance with the standards and requirements of the program. Mock unannounced Joint Commission inspections will be conducted by the POCT program. A findings report will be furnished to the site. A complete remedial action plan is required from non-compliant sites within 7 business days of the report. Two consecutive or two out of three non-compliant notices will result in the site being placed on probation. Hospital leadership will be notified of non-compliant sites. If a site is placed on probation the medical director will be required to submit a remedial action proposal with a time table for compliance. If the site is not brought into compliance or a remedial action plan is not submitted the Pathology service will work with Hospital leadership to achieve compliance or discontinue testing. A site may apply to start testing again. Their application for re-entry must include a remedial action plan to ensure future compliance. The application will be reviewed by the POCT Leadership to approve re-entry into the program. BILLING The POCT program supports billing for point of care tests performed by MGH testing sites that utilize interfaced methods. Manual tests may be billed for by the individual testing sites. The POCT program can assist their billing departments in selecting the correct billing codes. SUPPLY MANAGEMENT Certain supplies utilized by multiple POCT sites are centrally ordered and available in the POCT offices of GRJ239. These may include i-stat cartridges, Hemocue reagents and urine dipstick quality control reagents. Approved testing sites are given directions to access the reagents as needed. These reagents are paid for out of the point of care testing cost center. Sites are encouraged to access the central supply to ensure standardized QC and effective inventory management, but participation is optional. 8