CLIA Flashcards
What are lab/facility exceptions to CLIA standards?
Forensic testing
research labs that don’t report patient results
NIDA certified labs which perform drug testing
*other testing at NIDA lab is subject to CLIA
What are the 7 criteria used by FDA to determine test complexity and categorize tests?
1) scientific/technical knowledge
2) training and experience required
3) reagents/materials preparation, stability, reliability
4) operational steps
5) calibration, QC, proficiency testing materials availability
6) test system troubleshooting and equipment maintenance
7) interpretation and judgment required to perform all 3 phases of testing
How is testing categorized between moderate and high complexity with the scorecard?
7 criteria scored from 1-3 with 1 being lowest
7 scores added together
12 OR LESS = moderate complexity
ABOVE 12 = high complexity
List the 5 CLIA certificates
1) Registration
2) Waiver
3) PPM procedures
4) Compliance
5) Accreditation
For how long are CLIA certificates valid?
2 years
Which level of complexity in labs requires registration certificate?
all labs performing moderate or high complexity or both
labs performing only WAIVED, PPM, or combination are NOT required to obtain registration certificate
only labs applying for compliance or accreditation cert will receive registration cert.
issued to labs performing non-waived testing until CLIA inspection occurs
Initially for all laboratories performing test procedures of moderate complexity (other than the subcategory of PPM procedures) or high complexity, or both; and
(2) For all laboratories that have been issued a certificate of waiver or certificate for PPM procedures that intend to perform tests of moderate or high complexity, or both, in addition to those tests listed in § 493.15(c) or specified as PPM procedures.
How complex are PPM procedures considered?
Moderate complexity
List examples of accreditation programs approved by HHS
CAP, COLA, JCAHO
Do labs with several locations require separate applications for CLIA certificates? What are the exceptions?
YES
exceptions: mobile units, health screening fairs, temporary testing locations can be covered under cert of primary site
not for profit fedreral, state or local government labs that perform limited public health testing (no more than combination of 15 moderately complex or waived tests per certificate
labs within a hospital with contiguous buildings on same campus and under common direction
What are the time limits for reporting changes to CMS?
30 days: ownership, name, location or director or technical supervisor
6 months: tests within specialty or subspecialty not included on compliance certificate
6 months: deletions or changes in test methodologies for tests included in specialty or subspecialty or both contained in compliance Cert
What are characteristics of waived tests?
1) fully automated or self-contained
2) use only unprocessed specimens
3) require no specimen manipulation before analytic phase
4) no operator intervention during analytic phase
5) direct readout of results - no calculations or conversions
6) contain fail-safe mechanisms that render no result when system malfunctions or initiates fail-safe mechanisms rendering no result when result is outside of reportable range
7) no invasive test system troubleshooting, electronic, or mechanical maintenance
8) instructions are written at 7th grade comprehension level
Who can perform PPM procedures?
physician,
midlevel practitioner under physician supervision or independent practice if state authorizes it
dentist
only during patient’s visit on specimen obtained from his patient or patient in group practice
What are main specifications of PPM procedures?
Moderate complexity
Instrument is bright-field/phase-contrast microscopy
specimen is labile
CONTROLS NOT AVAILABLE to monitor entire testing process
LIMITED specimen handling or processing required
what are examples of PPM procedures?
wet mount preparations for presence or absence of bacteria, fungi, parasites, human cellular elements
KOH preparations
pinworm examinations
fern tests
post coital, direct exams of vaignal or cervical mucous
urine sediment exams
nasal smears for granulocyts
fecal leukocyte
qualitative semen analysis
What are the requirements of PPM labs?
PT, patient test management, quality control, personnel and quality assurance
subject to inspection
What is considered satisfactory performance on PT testing?
80% correct for each analyze in most specialities
some immunohematology procedures and compatibility testing require 100% accuracy
What is considered Unsatisfactory PT performance?
failure to attain minimum satisfactory score for an analyte, test or subspecialty for testing event and requires remedial actions
What is considered unsuccessful PT?
unsatisfactory performance for SAME ANALYTE in 2 consecutive or 2/3 testing events
repeated unsatisfactory OVERALL testing event scores for 2 consecutive or 2/3 testing events for same specialty or subspecialty
unsatisfactory testing event score for those subspecialties not graded by analyte (Bacteriology, mycobacteriology, virology, parasitology, mycology, compatibility testing, unexpected antibody detection, antibody identification) for SAME subspecialty for 2 consecutive or 2/3 testing events
How long must documentation of PT records be maintained
minimum of 2 years from proficiency testing event
Is PT required for all test methods, systems or examinations during PT event?
NO only required for primary method used in patient testing
How should PT samples be tested?
With regular workload by personnel who routinely perform testing and with routine methods
For which specialities and subspecialties is satisfactory performance on PT considered 80% correct for each analyte you are being tested on?
microbiology (bacteriology, mycobacteriology, mycology, parasitology, virology)
diagnostic immunology (syphilis serology, general immunology)
chemistry (routine chemistry, endocrinology, toxicology)
hematology (no subspecialties defined here)
What is considered satisfactory PT performance in immunohematology subspecialties?
ABO/RHO 100%
Unexpected Antibody 80%
Compatibility testing 100%
Antibody identification 80%
What is considered satisfactory performance for most PT testing?
80% correct for each analyze you are being tested on ( 4/5 right per testing event)
Testing involves multiple samples of the same analyte
What is the number of samples and frequency of challenge for the subspecialties?
MYCOBACTERIOLOGY: 5 samples per testing event and 2 events per year
Immunohematology, microbiology, diagnostic immunology, chemistry and hematology = 3 times per year with 5 samples per testing event
What does failure to return PT results to PT program before deadline result in?
UNSATISFACTORY performance
score of 0 for testing event
How should the lab respond to PT failure?
Appropriate training and employ technical assistance necessary to correct problems associated with failure
remedial action must be taken and documented and maintained for 2 years
What is unsuccessful PT performance?
failure to achieve an overall testing event score of satisfactory performance for 2 consecutive events or 2/3 consecutive events
How are the pathology PT program requiremnts different?
More strict
to Participate successfully in cytology PT program for gynecological examinations
each indidivudal tested at least once per year and obtain a passing score
announced and unannounced testing will be done on site in each lab at least once a year
examination of 10 side test set
10 > 10 > 20
no more than 45 minutes to complete 10 slide test and not more than 90 for 20 slides
failure if scores less than 90% on 10 slide test set
if individual fails, lab must schedule retesting event to take place not more than 45 days after receipt of failure notification
What are the facility administration requirements for non waived testing from CLIA?
Facility: construction/arrangement/maintenance must ensure space, ventilation, utilities, minimizes contamination, unidirectional workflow
appropriate and sufficient equipment, instruments reagents, materials and supplies for volume of testing
comply with applicable federal, state and local requirements
safety precautions must be established, posted and observed
How long must records of QC, patient tests, quality assessment and PT be retained?
2 years
How long must records of test system performance specifications be retained?
for the period of time lab uses the test system but NOT LESS THAN 2 YEARS
How long must cytology slide preparations be retained
5 years
How long must original reports be retained?
2 years after date of reporting
What should the lab do with records if it ceases operation?
must take provisions to ensure all records and applicable slides, blocks and tissues are maintained and available for time frames specified
List major components of the quality systems required for non-waived testing
Confidentiality of patient information and specimen identification and integrity
complaint investigations
communications
personnel competency
Proficiency testing
General Lab systems assessment - monitor and correct problems and effectiveness
test requisition
specimen submission / handling
procedure manual
test systems, equipment, instrumentation, reagents, materials and supplies
Method performance specifications
Equipment maintenance and function checks
calibration and calibration verifications
Control procedures
Comparison of test reults
corrective actions
test records
test results
systems assessment
how often must analyte not offered by CMS-approved PT program be assessed?
at least twice annually
Are oral requests permitted for laboratory tests?
Only if lab requests written authorization for testing within 30 DAYS. Lab must maintain written authorization or attempts to obtain
How long must records of test requisitions or authorizations be retained?
minimum of 2 years
can the patient’s chart or medial record be used as test requisition?
Yes but must be available to lab at time of testing and to HHS upon request
What are the required elements of the test requisition or authorization?
Patient name OR other unique identifier
Sex AND Age/DOB
Name and Address of authorized person ordering test and if appropriate individual responsible for utilizing the test results OR name and address of lab submitting the specimen including contact for reporting panic values
Tests to be performed
Date and time of specimen collection
specimen source, if appropriate
For Pap smears Last menstrual period, age/DOB and indication whether previously had abnormal report/treatment/biopsy
any additional information relevant and necessary to a specific test to assure accurate and timely testing and reporting of results
What are the required components of policies and procedures for specimen submission and handling?
PREPARATION of patients
Specimen collection
Labelling
Preservation
Transportation
Processing
Acceptability and rejection
Referral
must assure positive ID and optimum integrity of patient specimens from time of collection until testing has been completed and results reported
Are oral explanations of instructions to patients allowed?
Oral explanation for specimen collection including patient preparation may be used as a supplement to written instructions where applicable
Can textbooks be used in lieu of laboratory written procedures for testing or examining specimens?
No, can be used as supplement only
List components that must be included in the procedure manual
Specimen collection, processing, rejection criteria
microscopic examinations, detection of inadequately prepared slides
steps to procedure including calculations and interpretation
preparation of slides, solutions, calibrators, controls reagents stains or other mateirals
calibration/calibration verification
reportable range as established or verified
control procedures
remedial action when calibration or control results unacceptable
limitations in methodologies (interfering substances included)
reference range (normal values)
imminent life threatening results /panic values
literature references
criteria for specimen storage and preservation to ensure specimen integrity until testing is completed
systems for reporting patient results including reporting of panic values
course of action if test system inoperable
criteria for referral of specimens including submission and handling
Can manufacturer package inserts or operator manuals be used?
Can be used to meet requirements and any items not provided by manufacturers must be provided by lab
How should discontinued procedures be handled?
Filed separately from active
retained for 2 years after discontinuance
List the conditions that the lab must define that ensure proper storage of reagents and accurate/relaibel test system operation and result reporting
Water quality
humidity
temperature
protection of equipment and instrumentation from fluctuations and interruptions in electrical current
What are the required elements on reagent, materials, supplies, solutions labels?
1) Identity and titer/strength/concentration when significant
2) Recommended storage requirements
3) Preparation and expiration date
4) Other pertinent information for proper use
Prior to reporting patient test results lab must verify or establish for each method performance specifications. What are these characteristics?
1) accuracy and precision
2) Sensitivity and specificity if applicable
3) reportable range
4) reference range
5) any other applicable performance characteristic
What is different about moderate or high complexity test methods in use prior to April 24 2003?
for tests in use prior to this date :
Labs NOT required to verify or establish performance specifications for moderate/high complexity
What is the purpose of calibration and verification?
Substantiate continued accuracy of test method throughout lab’s reportable range for patient test results
What is calibration?
testing and adjusting an instrument, kit or test system to provide a known relationship between the measurement response and value of the substance that is being measured by the test procedure
what is calibration verification?
assaying calibration materials in same manner as patient samples to confirm that calibration of instrument, kit or test system has remained stable through lab’s reportable range of patient test results
What is the reportable range of patient test results?
Range of known test values over which the laboratory can establish or verify the accuracy of the instrument, kit or test system measurement response
What values must be included in the labs established reportable range?
Must include at least a minimal (zero) value, midpoint value and maximum value at the upper limit of that range
How often must calibration verification procedures be performed?
at least once every 6 months
AND if the following occur:
complete change in reagents UNLESS changing reagent lot numbers does not affect range or controls
major preventative maintenance or replacement of critical parts that may influence test performance
controls reflect an unusual trend or shift or outside acceptable limits and other means of correcting the control values have failed
Labs established schedule for verifying reportable range requires more frequent verification
Is calibration verification always required when changing reagent lots?
If lab can demonstrate that changing reagent lot numbers does not affect reportable range and that control values are not affected
*if reagents are obtained from manufacturer and all reagents for a test are packaged together, lab is NOT required to perform calibration verification for each package of reagents if they are received in same shipment and contain same lot number