Inspector Information Laboratory Information TABLE OF CONTENTS Inspector Topic Page Information Introduction……………………………………………………………. 4 Inspection Objectives………………………………………………... 5 Standards for Laboratory Accreditation……………………………….. 5 Checklists……………………………………………………………. 5 Commission Philosophies……………………………………………… 8 Peer Review…………………………………………………………… 8 Thoroughness………………………………………………………….. 8 Judgment………………………………………………………….…… 8 Disputes………………………………………………………………... 9 Sexual Harassment…………………………………………………….. 9 Solicitation…………………………………………………………….. 9 Confidentiality…………………………………………………….… 9 … Conflict of Interest…………………………………………………….. 10 Applying to the CAP Laboratory Accreditation Program……………. 11 Prerequisites…………………………………………………………… 11 Application…………………………………………………………….. 11 Pre-Inspection Phase: Preparation of Application Materials…….…. 13 Inspection 13 Checklists…………………………………………………... Application Demographics Form………………………………..…….. 13 Supplemental Materials………………………………………………... 14 AABB Coordination…………………………………………………… 14 Returning the Application…………………………………………… 14 Preparing for the Inspection……………………………………………. 15 Inspection Team Leader Assignment………………………………... 15 Inspection Team Leader Qualifications……………………………... 15 Inspector Inspection Packet……………………………………….…… 16 Laboratory Disciplines………………………………………………… 17 Inspection Team……………………………………………………….. 17 Arranging the Inspection Date…………………………………….… 17 Requests for Inspection Delays……………………………………… 18 AABB Coordinated Inspection……………………………………… 18 Unprepared Laboratories………………………………………….…… 18 Conducting the Inspection: Meetings and General Principles……… 20 Meeting with the Laboratory Director…………………………….… 20 Meeting with the Hospital 20 Administrator……………………………… Meeting with a Representative of the Medical Staff………………… 20 Meetings with Direct Healthcare Providers……………………….… 21 Meetings with Clients of Independent Laboratories………………… 21 Inspecting the Laboratory Sections…………………………………….. 22 Laboratory General……………………………………………….…… 22 Conducting the Safety Inspection…………………………………… 25 College of American Pathologists Laboratory Information Laboratory Accreditation Manual Page 1 Inspector Information Laboratory Information Inspector Topic Page Information Hematology and Coagulation………………………………………….. 31 Clinical Chemistry, Special Chemistry, Toxicology………………… 33 Inspecting the Laboratory Sections (Continued) Urinalysis and Clinical Microscopy…………………………………… 34 Microbiology…………………………………………………………... 36 Transfusion 38 Medicine………………………………………………….. Immunology and Syphilis Serology……………………………….… 39 Anatomic Pathology…………………………………………………… 39 Cytopathology…………………………………………………….…… 41 Cytogenetics…………………………………………………………… 43 Histocompatibility…………………………………………………… 44 Flow Cytometry……………………………………………………….. 44 Molecular Pathology………………………………………………… 44 Point of Care Testing …………………………………………….…… 44 Inspecting Other Types of Laboratories……………………………….. 46 Special Function 46 Laboratories…………………………………….…… Affiliated Laboratories………………………………………………… 46 System Inspection Option…………………………………………… 46 Satellite Laboratories………………………………………………….. 47 Staff Inspected Laboratories………………………………………… 47 Limited Service Laboratory……………………………………….… 47 The Summation Conference…………………………………………… 49 Pre-Summation Team Meeting……………………………………… 49 Summation Conference……………………………………………… 49 Concluding the Inspection…………………………………………… 50 The Inspection Report…………………………………………………… 52 Inspector’s Summation Report (ISR)………………………………….. 52 Expense Reimbursement………………………………………….…… 52 Continuing Medical Education (CME)……………………………… 52 Return of Inspection Packet…………………………………………… 53 Post-Inspection 54 Phase……………………………………………….…… Laboratory Inspection Packet………………………………………….. 54 Packet Review…………………………………………………….…… 55 Immediate Review Criteria………………………………………….. 55 Accreditation………………………………………………………… 56 Denial/Revocation…………………………………………………… 56 Appeals………………………………………………………………… 56 Post Inspection Critique………………………….……………….…… 57 Maintaining 58 Accreditation………………………………………………. Proficiency Testing Participation and Satisfactory Performance……. 58 Self-Evaluations……………………………………………………….. 58 Anniversary of Accreditation…………………………….………..… 58 Implications of Accreditation …………………………………….…… 58 College of American Pathologists Laboratory Information Laboratory Accreditation Manual Page 2 Inspector Information Laboratory Information Inspector Topic Page Information Non-Routine Inspections………………………………………………… 60 Change in Location, Director, or Ownership………………………... 60 Added Discipline………………………………………………….…… 60 Secondary On-Site Inspection…………………………………….…. 60 Complaint Investigation……………………………………………….. 61 Appendix A: CAP Checklist 62 Usage………………………………….…… Appendix B: Guidelines for Determining Test Volume………………… 65 Appendix C: Quality Improvement………………………………………. 66 Appendix D: Sample of Inspection Confirmation Letter to Lab Director…………………………………………………… 68 Appendix E: Resources………………………………………………….. 70 Appendix F: Site Coordinators 74 Manual………………………………….. Appendix G: Retention 86 Guidelines……………………………………….. Appendix H: Glossary of Terms…………………………………………. 88 College of American Pathologists Laboratory Information Laboratory Accreditation Manual Page 3 Inspector Information Laboratory Information INTRODUCTION The College of American Pathologists (CAP) has established and directs four separate accreditation programs. These programs were created with the primary objective of improving the quality of clinical laboratory services throughout the United States, through voluntary participation, professional peer review, education and compliance with established performance standards. Since their creation, these programs have become widely acknowledged as programs of excellence. In all, the College accredits over 6,000 laboratories. The Laboratory Accreditation Program (LAP), for all clinical laboratories, was established in 1961. The Forensic Urine Drug Testing (FUDT) accreditation program was established in 1988 and the Athletic Drug Testing Program (ADT), in 1992. The Reproductive Laboratory Program (RLAP), directed jointly with the American Society of Reproductive Medicine (ASRM), was established in 1993. The accreditation programs examine all aspects of quality control and quality improvement in the laboratory, including test methodologies, reagents, control media, equipment, specimen handling, procedure manuals, test reporting, and internal and external proficiency testing and monitoring, as well as personnel, safety, and overall management practices that distinguish a quality laboratory. Management and operation of the four accreditation programs are the responsibility of the Commission on Laboratory Accreditation (CLA), except the responsibility for the RLAP is shared with the ASRM. The CLA is a group of specially qualified pathologists appointed by the president of the CAP and is composed of a chair, a vice chair, and regional and special commissioners. The CLA meets three times each year to develop standards, guidelines, and policies for the LAP, to make accreditation decisions and to consider relevant issues. Each Regional Commissioner has responsibility for a specific geographic region. The Regional Commissioners are assisted by Deputy and State Commissioners. Other commissioners oversee the revision of the inspection Checklists, develop inspector training materials, address state and federal legislative and regulatory issues, and edit the Laboratory Accreditation Newsletter. In addition, the Commission uses the expertise of numerous CAP scientific resource committees to keep the program and its requirements current. State and Division Commissioners are responsible for identifying and assigning inspectors in their geographic regions. They must make sure that inspections are conducted on a timely basis and in accordance with Commission policy. Following the on-site inspections, the Regional Commissioner, in conjunction with the CAP technical staff, reviews the inspection data and conducts any follow-up necessary to reach an accreditation decision. The Laboratory Accreditation Department at the CAP headquarters in Northfield, Illinois is staffed by technical and administrative personnel who carry out the policies and procedures of the CLA and handle administrative details of the accreditation process. College of American Pathologists Laboratory Accreditation Manual Page 4 Inspector Information Laboratory Information The inspectors who conduct the on-site laboratory inspections are the lifeblood of the program. Typically, the inspection team leader is a board-certified pathologist who has been trained by attending an inspector training seminar or evening symposium. Three documents are fundamental to the inspection process: the Standards for Laboratory Accreditation, the Checklists, and the Inspector’s Summation Report (ISR). The inspector’s role is to interpret the Standards, in the spirit of peer review, using the Checklists and ISR. The inspector collects and records the information upon which the CLA will base the accreditation decision. The inspection is a peer review educational process designed to achieve improvement of patient care activities in participating laboratories. During the course of the inspection, inspectors often will share experiences which will enhance the quality of the laboratory’s service, and inspection team members find ideas that can be implemented in their own laboratories. Inspection Objectives: In the course of an inspection, the inspector should learn to : 1. Describe how to evaluate the operating practices of a particular laboratory, by reviewing technical procedures and related materials for quality control and quality improvement. 2. Use the Standards for Laboratory Accreditation and the Inspection Checklists as tools for the assessment of unfamiliar laboratory practices for compliance and consistency with good laboratory practice. 3. Describe knowledge about new methods and technology or approaches enhanced through the inspection process. 4. Explain how interaction with administration, physicians and staff enhanced the inspector’s knowledge of current management issues and solutions. Standards for Laboratory Accreditation The Standards are the basis for the accreditation decision. Each of the four-accreditation programs has its own Standards. The Standards, which have evolved through years of study and continuous review by the CLA, are approved by the CAP Board of Governors. The inspector must be familiar with each standard and its interpretation. A copy of the Standards for Laboratory Accreditation is included with each inspection packet. The Standards should be reviewed before the inspection of the laboratory. The inspector is considered the on-site authority for the interpretation of the Standards. Checklists Detailed Checklists were developed, based on the requirements of the Standards. The Checklist format permits a comprehensive evaluation of a laboratory’s compliance with the Standards. The Checklists are organized by specific laboratory disciplines and/or important management operations: College of American Pathologists Laboratory Accreditation Manual Page 5 Inspector Information Laboratory Information Laboratory General Hematology and Coagulation Automated/General Chemistry Urinalysis and Clinical Microscopy Toxicology Special Chemistry Microbiology Transfusion Medicine Immunology and Syphilis Serology Anatomic Pathology Cytopathology Cytogenetics Histocompatibility Flow Cytometry Molecular Pathology Limited Service Laboratory Blood Gas Laboratory Point-of-Care Testing The Checklists are available in hard copy format by calling 800-323-4040, extension 6055 or 847-832-7000, extension 6055 or at the CAP Website (www.cap.org). To download Checklists from the Web page follow these directions. From the Laboratory Improvement icon, view the dropdown menu and click on Laboratory Accreditation Program. From the Laboratory Improvement screen click Download checklists. The download library screen will appear, scroll until you reach LAP Checklist. Click on LAP Checklists and the list of all Checklists will appear listing two formats. To obtain a copy of a checklist, click the download format. The HTML format will allow you to view only. These Checklists are revised periodically and consist of approximately 3,200 questions, many of which are the same item in each of the section-specific Checklists. During the inspection, the Checklist questions are used to evaluate whether or not a laboratory meets the LAP Standards. Each of the questions is uniquely numbered, worded and designed to produce: a “Yes” response, which means that the lab is compliant; a “No” response, which means the lab does not comply; or N/A which means that the question does not apply in this testing situation. Each of the questions bears a designation of Phase I (deficiency) or Phase II (deficiency). Phase I deficiencies do not seriously affect the quality of patient care or significantly endanger the welfare of a laboratory worker. Phase I deficiencies require documented responses. College of American Pathologists Laboratory Accreditation Manual Page 6 Inspector Information Laboratory Information Phase II deficiencies are major deficiencies that may seriously affect the quality of patient care or may affect the health and safety of hospital or laboratory personnel. All Phase II deficiencies must be corrected and the correction documented to the satisfaction of the CLA before accreditation will be granted. Correction requires both a plan of action and additional evidence that the plan has been implemented. College of American Pathologists Laboratory Accreditation Manual Page 7 Inspector Information COMMISSION PHILOSOPHIES Peer Review Purpose: Improve laboratory performance through objective evaluation and constructive criticism. The inspector can enhance the spirit of peer review and educational benefit of the inspection process by keeping in mind the following items: Inspectors are representatives of the accreditation program and the CAP; they must strive for an objective and fair review. There may be more than one way to respond to a requirement and be in compliance. The inspection team leader should be a peer of the medical director and serve as a guest consultant to the laboratory. If a deficiency can be corrected to the inspector’s satisfaction while the inspector is on site, that deficiency should not be cited in the Inspector’s Summation Report. Deficiencies should be presented factually with recommendations for improvement. A negative, unduly critical, or punitive attitude should be avoided. Deficiencies cited by the inspection team may be challenged. Dialogue between the medical director and the inspection team leader strengthens the program and can provide insight to both to the director and the team leader. Such discourse may lead to changes to Checklist questions or clarification of requirements. The director is encouraged to respond in writing to the CAP about any disputed citation. Supporting documentation should be included in the any response. The Regional Commissioner, in conjunction with the entire Commission, will adjudicate the challenge. An inspector should encourage the appeal process, if necessary, to avoid conflict at the Summation Conference. Thoroughness Participating laboratories expect a thorough, detailed, and fair inspection. All pertinent items in the Checklist should be considered. Most laboratories spend considerable time and effort preparing for the inspection; they appreciate and deserve a comprehensive inspection. Overlooking seemingly minor deficiencies does not do anyone a favor. Judgment The Commission relies upon the inspector’s judgment more than any other attribute in the assessment of a laboratory. This attribute is, however, the most difficult to standardize. There will be occasions when a conscientious inspector will have difficulty deciding whether a Checklist item should be answered “Yes” or “No” or N/A. Many of these situations involve partial compliance with the wording in the question. The inspector must be as detailed as possible in the description of a deficiency in the Inspector’s Summation Report (ISR). In some cases, there may be doubt as to whether the item actually applies to the specific laboratory inspected. College of American Pathologists Laboratory Accreditation Manual Page 8 Inspector Information Disputes If a laboratory wishes to challenge a particular citation, it must state its disagreement in the deficiency response. That response should include documentation that demonstrates that the laboratory was in compliance before the time of inspection. The Regional Commissioner will review disputed items and determine if the deficiency can be expunged from the record. The Laboratory Accreditation staff at the CAP office in Northfield may assist an inspector by telephone on the inspection day to help resolve questionable citations. Sexual Harassment Employees of laboratories inspected by the CAP are entitled to a workplace environment free from sexual harassment. Prohibited sexual harassment includes any comments, gestures, innuendo, or physical contact of a sexual nature that create an intimidating, offensive or hostile environment. Inspectors on a CAP team, whether team leader or team member, must conduct themselves in a manner that cannot reasonably be construed as sexual harassment. Team leaders must ensure that the behavior of team members is consistent with this position; they must intervene actively if inappropriate conduct is observed. Inappropriate conduct on the part of team leaders or team members should be reported to the Director of the Laboratory Accreditation Program at 800-323-4040, extension 7479 or 847-8327489. The CAP does not tolerate sexual harassment. In cases of documented sexual harassment, the CAP will take appropriate action against the responsible individual. Solicitation Inspectors should not in any way solicit either the institution or the laboratory for any purpose. They should conduct themselves at all times in a manner that cannot reasonably be construed to be a solicitation. Inspectors should not request any information from the institution or laboratory regarding fees or other business-related matters that are not related to quality assessment and quality improvement activities. Moreover, the inspector should not request any information regarding the director’s contractual relationship with the institution’s administration. Confidentiality All inspection findings are confidential. They should not be discussed in any context other than the inspection itself. Moreover, they should not be disclosed to anyone not associated with the accreditation process unless appropriate prior documented consent has been obtained. College of American Pathologists Laboratory Accreditation Manual Page 9 Inspector Information Conflict of Interest The CLA believes that an inspection performed by a team from a laboratory or institution that competes with the subject laboratory or institution does not represent a conflict of interest. Further, the CLA believes that team leaders and inspectors will conduct inspections objectively and professionally regardless of whether they are in competition with the subject institution. In this connection, it should be noted that the inspection team does not make the accreditation decision, and the subject laboratory may challenge any deficiency citation. The Regional Commissioner resolves any challenge based on documentation provided by the subject laboratory. Nevertheless, any laboratory can discuss the specifics of a perceived conflict of interest with the State and/or Regional Commissioner before the inspection. The State or Regional Commissioner has discretion to make a reassignment if a conflict of interest appears. College of American Pathologists Laboratory Accreditation Manual Page 10 Laboratory Information APPLYING TO THE CAP LABORATORY ACCREDITATION PROGRAM Prerequisites Laboratories must participate regularly in a CAP-approved proficiency testing (PT) program for each patient-reportable analyte, whenever an appropriate program is available. Each separately accredited laboratory must be enrolled in such a program under its own CAP number. It is preferable that the laboratory has a performance history of one or two shipments of proficiency testing before an initial inspection. The CLA requires that each accredited laboratory must provide and/or be responsible for providing an inspection team of a size and composition similar to that required for its own inspection. This team (if requested by the Regional, State or Division Commissioner) must perform at least one inspection during its two-year accreditation cycle. Application Once an application request form, along with a non-refundable deposit, is received in the CAP Northfield office, the necessary application materials will be sent to the applying laboratory. The deposit is applied toward the first-year accreditation fee. The application packet contains: 1. A copy of the Laboratory Accreditation Manual that includes instructions for the completion of accreditation materials 2. A checkoff list of materials to be returned 3. Accreditation Application which includes: Addresses Laboratory Contacts Licensure and Certification Release of Data Conditions of Accreditation Personnel Qualification Form - to be duplicated and completed for each pathologist, physician, doctoral clinical scientist, consultant and supervisor Laboratory Sections to be duplicated and completed for each section of the laboratory 4. Master Activity Menu 5. A complete set of Inspection Checklists 6. Standards for Laboratory Accreditation College of American Pathologists Laboratory Accreditation Manual Page 11 Laboratory Information A new applicant to an accreditation program has six months to complete and return the application materials if its inspection is not coordinated with a CAP-accredited laboratory. A laboratory whose initial inspection is being coordinated with a CAP-accredited laboratory will be assigned a due date by which the application materials must be returned to the CAP Northfield office. All laboratories within an institution that wish to be CAP accredited and that possess CLIA numbers different from the main clinical laboratory’s must be accredited separately. Accreditation is matched one-for-one with CLIA certification. Laboratories operating under separate CLIA certificates must submit separate deposits and application request forms. The Standards for Laboratory Accreditation and the inspection Checklists, as noted earlier, are available on the Website if the laboratory wishes to review them before applying to the program. If you do not have access to the Website you may call the Laboratory Accreditation Program at 800-323-4040, extension 6055 or 847-832-7000, extension 6055 to request a copy. College of American Pathologists Laboratory Accreditation Manual Page 12 Laboratory Information PRE-INSPECTION PHASE: PREPARATION OF APPLICATION MATERIALS Inspection Checklists CAP Checklists are method- or discipline-specific. Checklist usage is determined in the CAP office from the activity menu completed for each laboratory section. Supervisors should review their departments using the appropriate discipline-specific Checklist(s). A complete set of CAP inspection Checklists is included with your application packet. (The Checklists may be copied for your use, if needed. Checklists should not be returned to the CAP office.) See Appendix A for a detailed explanation of Checklist usage. Duplicate Checklists are required in instances where there is more than one discrete laboratory section, under the operation of different supervisors, performing testing within the same discipline, (i.e., a separate blood gas laboratory with a different medical or technical supervisor). The appropriate quantity of each Checklist will be provided to your inspector. The Commission on Laboratory Accreditation expects that the laboratory will have met the Standards by the date the application materials are returned to the CAP. Accreditation Application The laboratory must complete a Laboratory Section page of the Application for each section of the laboratory. The laboratory must complete the Master Activity Menu for all laboratory sections and physically attach (paper clip or staple) the appropriate pages to each Laboratory Section form. It may be necessary to copy the selected pages of the Master Activity Menu if testing is performed in more than one section. The Master Activity Menu is a list of all tests and nontest activities categorized by subdiscipline that could be performed by a laboratory. The laboratory should provide all information requested, including attachments if necessary. The laboratory should provide detailed annual test volumes for each discipline with the laboratory section. (See Appendix B for detailed information on calculation of test volumes.) The Release of Data and Conditions of Accreditation forms must be signed by the medical director responsible for the laboratory (MD, PhD, or DO). The director must indicate if the CAP inspection is to be used for regulatory purposes by checking the appropriate agency on this form. If your laboratory is affiliated with other laboratories and you prefer to have a coordinated inspection, complete the Affiliated Laboratories section of the application. Personnel Qualification Forms must be submitted for the laboratory directors and supervisors. Curriculum Vitae are to be submitted for laboratory directors only. College of American Pathologists Laboratory Accreditation Manual Page 13 Laboratory Information Note: Florida laboratories will receive a blank Clinical Laboratory Personnel Roster. The laboratory must complete a roster for each laboratory section, including any non-laboratory based employees performing Point of Care Testing classified by HCFA as moderate or high complexity. The Personnel Roster may be photocopied if more than one page is needed. The completed Personnel Roster form must be signed by the preparer and, along with a copy of each employee’s State of Florida License, must be returned with the application/reapplication packet. Supplemental Material A sketch of the laboratory floor plan should submitted on 8½” x 11” paper whenever possible. Laboratories should not submit blueprints. An organizational chart for the laboratory should be provided. Curriculum vitae should be submitted for the laboratory director. AABB Coordination Laboratories wishing to have a CAP/AABB coordinated inspection of their transfusion medicine service must contact the CAP office and the AABB National office as early as possible in the application process to allow sufficient time for administrative processing. Please refer to the sections in this manual on “Preparing for the Inspection” for further information on AABB coordination. CAP Central Office - 800-323-4040, option 2 or 847-832-7000, extension 6055 AABB National Office - 301-907-6977 Returning the Application Please retain the inspection Checklists as an educational tool to prepare for the inspection. All other application materials should be returned to: LABORATORY ACCREDITATION DEPARTMENT COLLEGE OF AMERICAN PATHOLOGISTS 325 WAUKEGAN ROAD NORTHFIELD, ILLINOIS 60093-2750 College of American Pathologists Laboratory Accreditation Manual Page 14 Inspector Information PREPARING FOR THE INSPECTION Inspection Team Leader Assignment Inspection team leaders are assigned by the State, Deputy, Divisional or Regional Commissioner. The State, Deputy, Divisional or Regional Commissioner: Contacts the inspection team leader by telephone or letter. Sends a confirmation letter to the inspection team leader and laboratory director. Faxes a copy of the Inspector Appointment Form (IAF), providing the inspection team leader’s name and address, to the CAP Northfield office. Handles any potential conflict of interest concerns as soon as possible. Team Leader qualifications Board-certified pathologist * Preferably a CAP fellow Preferably affiliated with a CAP-accredited laboratory Trained in the inspection process and preferably has completed the inspector training seminar, evening symposium, or self-study Peers of the laboratory director with similar status, type of practice and hospital or lab size Preferably not a close acquaintance of the laboratory director that will be inspected * A non-pathologist inspector may serve as a team leader only with the prior agreement of the laboratory director and under the supervision of a qualified pathologist. A pathologist, board certified in anatomic pathology, must inspect the anatomic pathology section. * CAP staff medical technologists perform inspections for certain limited service laboratories. The Staff Inspector Operations Specialist at the CAP Northfield office makes these assignments. See “Staff Inspected Labs.” College of American Pathologists Laboratory Accreditation Manual Page 15 Inspector Information Inspector Inspection Packet The Inspection Packet, sent to the inspection team leader from the CAP Northfield office, includes the following materials: Laboratory Accreditation Manual Standards for Laboratory Accreditation Team Member List Form Claim for Inspector Reimbursement Continuing Medical Education Evaluation (CME) Accreditation Unit (AU) Materials 1. Inspector Summation Report (ISR) 2. Accreditation Application 3. Laboratory specific Activity Menu 4. Proficiency Testing Enrollment Letter (if applicable) 5. Organizational structure 6. Laboratory Floor Plan 7. Laboratory Director’s Curriculum Vitae 8. Personnel Qualification Forms for key staff (director, pathologists, consultants, managers, and supervisors) 9. Previous Inspector’s Summation Report (ISR) Checklist Selection Report The Checklist Selection Report will indicate which Checklist(s) will be used in each laboratory section. Checklists Name tags for the team (every team member should wear a nametag while in the host facility) in an envelope. Prepaid mailer envelope to return the packet to the CAP after the inspection is complete. These mailers may only be used within the 48 contiguous states. Notes: Florida laboratory packets include a Clinical Laboratory Personnel Roster. During the on-site inspection, the inspector must sign the Personnel Roster, indicating verification of current State of Florida employee licenses and that the licenses are displayed. Licenses must also be verified for all non-laboratory based employees who perform Point of Care Testing classified by HCFA as moderate or high complexity. Oregon laboratory inspectors should verify the specialty/subspecialties listed by the laboratory and that the State Certificate is displayed in a prominent place. State Licensure - Many states license clinical laboratories. The extent to which the CAP accreditation program is recognized by state governments varies. The College will make the results of the accreditation decision available to a state agency upon request from the laboratory director. College of American Pathologists Laboratory Accreditation Manual Page 16 Inspector Information Laboratory Disciplines Accreditation by the CAP is limited to those disciplines specifically addressed within the CAP Laboratory Accreditation Program. ALL services provided by the laboratory as defined by the CLIA number in the application will be inspected. The College does not accredit portions of laboratories. CAP disciplines/subdisciplines and HCFA specialties/subspecialties (when appropriate) will be determined by the selection of activities from the Master Activity Menu. The accreditation letter lists only those disciplines that are reviewed at the time of the on-site inspection. Laboratories that add disciplines after the inspection must notify the College in writing; in some cases additional inspections may be required. (See the section of this manual titled “Non-Routine Inspections”.) Inspection Team The team leader assembles an inspection team appropriate for the size and scope of the laboratory. Information regarding the size of the previous inspection team is included in the packet. Inspection team members: have expertise in their assigned area, enhancing the peer review and education philosophy; may include pathology residents, medical technologists, cytotechnologists, clinical scientists, laboratory supervisors and laboratory managers; may be located using the CAP inspector database; (Lists of trained inspectors may be obtained from the CAP central office by calling 1-800323-4040, extension 6065 or 847-832-7000, extension 6065.) are trained in the inspection process by completing a didactic seminar or self-study; and should review the inspection process, laboratory packet and reference materials (Laboratory Accreditation Manual, Standards for Laboratory Accreditation, etc.) before the inspection. Arranging the Inspection Date The inspection team leader must: contact the laboratory director within two weeks of receiving the Inspectors Inspection Packet. contact all directors, if special function laboratories are to be inspected in conjunction with the main clinical laboratory, to notify them of the inspection date. ensure that the inspection occurs within the 30 days before the laboratory’s accreditation anniversary date. A mutually acceptable date is preferable; however the inspection is scheduled at the convenience of the inspector. notify the Laboratory Accreditation Program at the CAP Northfield office of the inspection date by telephone, fax or mail. send a courtesy letter to the laboratory director(s) indicating the inspection date, team listing, special requests (e.g., histology slides for review) and preliminary instructions (see an example of the letter in Appendix D). College of American Pathologists Laboratory Accreditation Manual Page 17 Inspector Information Requests for Inspection Delays The policy of the CLA requires that laboratories performing patient testing be prepared for inspection at any time. Any problems encountered in scheduling inspections should be brought to the attention of the State or Regional Commissioner for resolution. AABB Coordinated Inspection The laboratory director or supervisor is responsible for contacting the AABB (preferably at the time of application or reapplication) to request coordination. AABB telephone number: (301) 907-6977. Additionally, the laboratory director should notify the LAP of the intent to coordinate the inspection. The name and telephone number of the CAP team leader will be provided to the AABB inspector by the CAP upon notification of the AABB inspector assignment. The Transfusion Medicine Inspection Checklist will be sent to the AABB inspector along with an Inspector Summation Report (ISR), return instructions, and a return envelope. The AABB inspector should contact the CAP team leader to see if concurrent inspections are possible. If possible, the AABB inspector will join the team on the inspection day. The laboratory director is responsible for contacting the AABB concerning any coordination arrangements. If the AABB inspection cannot be concurrent: The AABB inspector may schedule a separate inspection of the blood bank and is responsible for notifying the CAP of the inspection date. The inspection date must not precede the CAP anniversary date by more than 30 days. Following the AABB inspection, the completed CAP Transfusion Medicine ISR will be returned to the CAP in the envelope provided. The CAP team leader should not hold his/her report to await the AABB Inspection report. CAP office staff is responsible for ensuring that the Transfusion Medicine Checklist report is returned. Each organization (CAP and AABB) makes separate accreditation decisions and one organization’s decision does not affect the other’s. Unprepared Laboratories Occasionally, during the on-site inspection, an inspector is asked to inspect one or more laboratories that have not completed application materials before the inspection. Unless an inspection packet has been completed before the on-site inspection, and received by the inspector as part of the total inspection package, such laboratories are not inspected. College of American Pathologists Laboratory Accreditation Manual Page 18 Inspector Information If however, an application has been completed but a specific Checklist is missing from the packet, the inspector should notify the CAP Northfield office immediately, (a Checklist copy may sometimes be faxed). The laboratory must be inspected at this time with the abovementioned specific Checklist, if required, in order to prevent an additional inspection visit. This only pertains to laboratories that are affiliated with the main laboratory, are under the responsibility of the same director, and have the same CLIA certificate number as the main laboratory. Special function laboratories that are under separate administrative and professional direction (e.g., blood gas laboratory, pediatric hematology laboratory), and have not applied in advance for inspection will not be inspected. The inspector should inform the director that formal application must be made through the CAP Northfield office for an inspection to be scheduled at a later date. College of American Pathologists Laboratory Accreditation Manual Page 19 Inspector Information CONDUCTING THE INSPECTION: MEETINGS AND GENERAL PRINCIPLES Meeting with the Laboratory Director Purpose: To determine whether or not the laboratory director has sufficient responsibility and authority for day-to-day operations of the areas inspected, or if the sections function independently of the designated laboratory director. The interview should: help in evaluating the director’s activities as listed in the Laboratory General Checklist and the Standards for Laboratory Accreditation. review any problems that the inspection experience might serve to resolve (e.g., space problems, staffing shortages, etc.) Meeting with the Hospital Administrator For hospital-based laboratories, the inspector should meet with the hospital administrator. Approximately 10-15 minutes should be allowed for the meeting. Purpose: To extend the College’s appreciation for participating in the accreditation program and to record an evaluation of the pathology service. The interview should: be relevant to the inspection itself and ascertain the hospital’s perception of the laboratory service. address the effectiveness of the working relationship between the laboratory, its director and the hospital director. determine whether the laboratory service meets the expectations of the administration communicate potential areas of conflict. The interview must not include a discussion of financial and/or contractual arrangements. Meeting with a Representative of the Medical Staff For laboratories closely associated with organized medical staffs, the inspector should meet with a representative of the medical staff. The representative should be the Chief of Staff, but may be any physician who uses the laboratory’s services frequently and is familiar with staff issues. The inspector should allow for a 10-15 minute discussion. Purpose: To determine whether the director and the laboratory staff have established an effective working relationship with the medical staff. College of American Pathologists Laboratory Accreditation Manual Page 20 Inspector Information The interview should: evaluate how effectively the scope, quality, and timelines of the laboratory services meet the patient care needs of the hospital. assess the contribution of the pathologist and laboratory staff to teaching conferences and meetings. determine the cooperation of medical staff and pathologist in problem resolution. help judge the medical community’s perception of the pathologist. Meetings with Direct Healthcare Providers While not a formal requirement, it may be useful for the inspector to visit direct patient care areas. If the inspector wishes to do so, this should be requested of the laboratory director before the inspection date. Purpose: To determine how the laboratory data and communications are used by medical, nursing, and clerical staff. The visit should include: observation of phlebotomy by laboratory personnel review of laboratory portions of patient charts for clarity of presentation through interviews, assessment of laboratory responsiveness to clinical needs identification of concerns that can be relayed to the laboratory director Meetings with Clients of Independent Laboratories Meetings with administrators or clients during an inspection of an independent laboratory are not required. The corporate manager of a commercial reference laboratory may be interviewed as a courtesy. Purpose: To define the functional relationships described in the organizational plan and determine if the director meets the qualifications outlined in Standard I. The interview should: provide the inspector with an opportunity to review the requirements for the director (See the Laboratory General Checklist and the Standards for Laboratory Accreditation.) enable the inspector to confirm the functional relationships described in the organizational plan. College of American Pathologists Laboratory Accreditation Manual Page 21 Inspector Information INSPECTING THE LABORATORY SECTIONS Note: Checklists are frequently revised and requirements may change. When information in this manual is not consistent with the currently published Checklists, the Checklist information prevails. Laboratory General The Laboratory General Checklist covers the laboratory overall and is used with every laboratory inspection. Issues such as management, personnel, specimen collection, computer function, inventory control, safety policies, quality improvement (QI), and general quality control (QC) procedures are included. Many of the items are repeated in the subsequent discipline- or methodspecific sections and are tailored to the special needs of individual departments. Proficiency Testing: Proficiency testing (PT) is an integral part of the CAP program along with the on-site inspection and self-evaluation. All labs that are seeking CAP accreditation must participate in a PT program approved by the Commission on Laboratory Accreditation. (A list of approved PT programs is included in the application and inspection packets. Any questions may be directed to the Proficiency Testing Specialist in the CAP Northfield office (800) 323-4040, extension 7580 or 847-832-7000, extension 7580.) If PT for an analyte is not commercially available, not graded, or not compatible with all methods, the laboratory is still required to perform an alternative method of proficiency evaluation at least every six months. Alternative methods include blind testing of specimens with known results, exchange of specimens with other laboratories or other equivalent systems specifically recommended and approved by the laboratory director. Inspectors should verify the performance of all proficiency testing, including any alternate methods. There must be documentation of identification and corrective action for any problems discovered through proficiency testing and documentation that the laboratory director or designee has reviewed all PT results and evaluations. Personnel: Randomly selected personnel files should be reviewed to determine whether the required information (job description, health, continuing education records, etc.) is included. If the qualifications of a supervisor (chief technologist or department head) are in question, concerns should be described in the Summation Report. Suggestions related to staffing levels and pathologist coverage issues should be discussed with the laboratory director before, or in lieu of, bringing such subjects up in the Summation Conference. The laboratory director must: meet the qualifications found in Standard I. be a physician or doctoral scientist. have sufficient authority to implement the Standards. meet the requirements in Laboratory General Checklist. College of American Pathologists Laboratory Accreditation Manual Page 22 Inspector Information Note: the director need not personally discharge all responsibilities. Administrative functions may be delegated to qualified laboratory managers or supervisors. Medical and technical responsibilities may be delegated to other physicians and qualified laboratory personnel. Consulting Pathologist When the director cannot adequately discharge all of the responsibilities appropriate for the pathology or laboratory service, the services of a qualified consulting pathologist must be retained. A policy regarding the duties of the consulting pathologist must be in place. The consulting pathologist must: provide documentation of activities performed and a documented report with evaluation and recommendations in writing for each consultation visit. visit the laboratory as often as required. serve as a consultant to the medical staff and play an active role in the educational programs of the laboratory and institution. Quality Improvement: The laboratory must have a planned and systematic program for the monitoring and evaluation of the quality and appropriateness of its patient care services, for resolving identified problems, and for ensuring that the program is implemented throughout all laboratory sections by the director. (See appendix C for an expanded discussion of quality improvement.) Quality Control: The quality control questions are designed to determine whether procedures are clearly defined, the laboratory director uses the quality control program to evaluate performance, and corrective actions are taken when necessary. Tolerance limits for procedures must be defined in the manuals and documented. Space and Facilities: Deficiencies in space and facilities are considered Phase II if severe enough that they affect the results of tests or compromise the health and safety of personnel. Less severe deficiencies are considered Phase I and are itemized to help the director plan for the future. Specimen Collection: Instructions must be provided for the collection and handling of specimens for all tests, both within and outside of the laboratory. If the laboratory accepts specimens collected by hospital nurses and house officers, a typical nursing station should be checked for availability of the instructions. In independent laboratories, a copy of the directions provided to client physicians should be reviewed. Handwritten Reports: As part of the inspection of individual departments, examples of completed reports for each format in use should be available for review. Legibility and completeness of demographic information are key issues. College of American Pathologists Laboratory Accreditation Manual Page 23 Inspector Information Computer-Generated Reports: The laboratory's computer system should be able to identify each individual contributing to or editing the printed released result. The data must be secure and the backup system functional. If reference laboratory data are transcribed, the identity of the original laboratory must be retained. Electronic signatures are permissible if the pathologist has personally verified the result. Review of Results: A routine system must be in operation to detect clerical errors or unusual laboratory results, and to provide for timely correction of those errors. Computer systems that report data are not exempt from this review. The review mechanism must be described in the quality control policies and procedures. Record Retention: Specimen requisitions (including the patient chart or medical record only if used as the requisition), patient test results and reports, instrument printouts, accession records, quality control records, proficiency testing records, and quality improvement records must be retained for two years. Instrument maintenance records must be retained for the life of the instrument. Serum and body fluid specimens (excluding urines) must be retained for 24 hours. Blood films, permanently stained body fluid slides, and microbiology slides must be retained for 7 days. Additional detailed requirements or recommendations are found in section-specific Checklists. Any deficiencies noted by the inspector must be detailed in the ISR. For data transmitted by computer interface (on-line system), it is not necessary to retain paper worksheets, printouts, etc., so long as the computer retains the data for at least two years. Manual entry of patient result data requires that all worksheets, printouts, etc. are retained by the laboratory for at least two years. Self-Evaluation Documentation: Laboratories inspected for re-accreditation must have conducted a self-inspection the previous year. The laboratory director must present documentation validating the occurrence of the self-inspection. If any Phase II deficiencies were found, the laboratory must have documentation of the corrective actions that were taken at that time. College of American Pathologists Laboratory Accreditation Manual Page 24 Inspector Information Conducting the Safety Inspection Introduction: Checklist questions are based upon current understanding of hazard control and common sense. Many items have been included to help the laboratory to comply with federal regulations. The inspector must be familiar with these regulations to provide proper consultation to the laboratory and uncover potential violations of regulatory code. It is important that no instance of non-compliance with such regulations is overlooked during a CAP inspection. Most safety items are contained in the Laboratory General Checklist. All items are to be considered when individual departments and specialty sections are inspected and evaluated. When a team inspects the laboratory, each member of the team must inspect for safety hazards that portion of the laboratory for which he/she is responsible. Each specialty Checklist also has a safety question that should be used to help specify the area where attention is needed. The observations should be detailed in the Inspector’s Summation Report Part B. General Safety: Safety program policies must be documented. Procedures should be posted or otherwise available to all employees. Instruction in these safe work practices should be a documented part of new employee orientation. The inspector should review the documented safety manual for completeness. Several items should be selected from the safety manual for interviewing an employee regarding knowledge about safety issues. By law, the laboratory must report serious accidents and illnesses to the Occupational Safety and Health Administration (OSHA)1, but all injuries that require medical treatment or time lost from work should be reviewed as part of the laboratory's QA program. This includes every needlestick requiring treatment with Immune Serum Globulin or Hepatitis B Immune Globulin. An inspector should ask about recent injuries or occupational illnesses and review the adequacy of the documented follow-up. Fire Protection: National Fire Protection Association (NFPA) documents are used as references for fire prevention and preparedness questions. An accredited laboratory must: (1) have an automatic fire extinguishing system; or (2) be separated from a contiguous inpatient facility by fire-resistant construction that has a minimum rating of two hours and class B self-closing door assemblies rated at three-quarter hours; or (3) be located in buildings classified as "business occupancy." In all cases, a fire bell, public address system, or other alarm system must be audible in all sections. This includes lavatories, darkrooms, storage areas, and offices. Ask employees if there are areas in which the alarm system is difficult to hear. If there is any area where the alarm is inaudible cite a deficiency. If there is any doubt as to the arrangement of the laboratory area or applicability to fire codes, the inspector should ask to see documentation that the local fire authorities have approved the current arrangement. 1 29CFR 1904.8 College of American Pathologists Laboratory Accreditation Manual Page 25 Inspector Information Fire drills must be held at a frequency so that all laboratory personnel, from all areas and on all shifts, participate at least once per year. Drills need not be noisy affairs that disturb patients, nor empty the laboratory of all employees. Orderly, walk-through drills that involve different groups of employees at varying times are acceptable. Class B portable fire extinguishers must be located in all areas where flammable or combustible liquids are stored or handled. There must be documentation that personnel have been properly trained in the use of these devices. The inspector should note the details of the fire extinguishing devices in the ISR if the type of device, or its location, is in question. Ignitable liquids must be stored properly. Up to two gallons may be stored, per 100 square feet of space, if contained within flammable liquid storage cans or safety cabinets. Up to one gallon per 100 square feet may be stored if the material is stored outside of safety cans and cabinets. Up to four gallons per 100 square feet may be stored in laboratories with sprinkler systems. Safety cabinets may be unvented or vented to the outdoors. If unvented, the bung caps must be in the venting ports. If vented to the outdoors, ventilation ducts must be explosion proof. Electrical Hazards: All laboratory instruments and appliances should be adequately grounded and checked for current leakage before initial use, after repair or modification, and when a problem is suspected. Those that are double insulated are exempted. All electrical outlets in technical work areas should be checked at least annually for ground integrity, and records of these checks should be maintained. Tasks may be delegated to biomedical and electrical engineers, however, documentation must be present on inspection day, or a deficiency should be cited. Chemical Hazards: The hazards of all dangerous chemicals used in the laboratory must be contained. The director must have a comprehensive signage and labeling system in use and applied throughout the laboratory. Each hazardous chemical must be labeled with the type of hazard and what to do if accidental contact occurs. Any container regardless of size must be properly labeled. Material safety data sheets (MSDS) must be on file for each hazardous chemical, and the location of the MSDS file should be conspicuously posted for the employees' benefit.2 The inspector should select one or two hazardous chemicals found in the laboratory and question an appropriate employee about the safe work practices that relate to that substance. 2 29 CFR 1910,1200 College of American Pathologists Laboratory Accreditation Manual Page 26 Inspector Information OSHA requires each laboratory to develop a comprehensive, documented Chemical Hygiene Plan (CHP).3 All chemicals regardless of type of risk, volume, or concentration, must be included in the CHP. A separate CHP for each chemical is not required, but the pertinent portions of the CHP should be identified. The plan should define storage requirements, handling procedures (including requirements for personal protective equipment), location of OSHAapproved MSDS (and other pertinent references), and the medical procedures to be followed if contact or overexposure occur. Monitoring of vapor levels is required initially and whenever there is reason to believe that safe levels are routinely exceeded. Indications for monitoring must be defined in the CHP. The CHP must specify the clinical signs and symptoms or the environmental conditions (such as a spill) that would indicate that overexposure has occurred. When such conditions exist, the CHP should describe the medical attention that will be provided. There should be evidence that the plan is reviewed annually for its effectiveness and that it is part of new-employee orientation and continuing education programs. Chemical carcinogens, reproductive toxins, and other severely toxic chemicals are special concerns. The laboratory must be surveyed annually for the presence of carcinogenic and potentially carcinogenic chemicals. This includes any chemical for which OSHA has specific occupational regulations.4 (Formaldehyde, ethylene oxide, benzidine, and benzene are examples in this group that are reasonably likely to be found in laboratories.) The regulations also apply to any chemical that is believed to be potentially carcinogenic. For practical purposes, this includes any substance so identified by the National Toxicology Program or by the International Agency for Research on Cancer. The director or designee must have gone through this exercise before the inspection, and a deficiency should be cited if there is no documentation that such a review has taken place. Personal protective equipment (PPE) appropriate to each hazardous task must be provided and its use must be mandated where appropriate. Such items include face shields, aprons, and gloves constructed of materials appropriate to the type of chemical handled. There should be a safety shower or other emergency source of water in any area in which quantities of concentrated caustics are manipulated. Piped eyewash fountains or the equivalent should be present. It is a deficiency if this equipment is present but access to it is obstructed. Chemical fume control devices such as hoods must be checked annually for proper function. 3 4 29 CFR 1910,1450 29 CFR 1910,1001-1047 College of American Pathologists Laboratory Accreditation Manual Page 27 Inspector Information OSHA requires all workers to be protected from dangerous levels of vapors and dusts. Regulated substances are listed in 29 CFR 1910, Subpart Z. Formaldehyde vapor is the most likely air contaminant to exceed the regulatory threshold in the clinical laboratory. Current OSHA regulations require vapor levels not to exceed 0.75 ppm (measured as an 8-hour, time-weighted average [TWA]) and 2.0 ppm (measured as a 15-minute, short-term exposure). OSHA requires monitoring for formaldehyde vapor wherever formaldehyde is used in the workplace. The laboratory must have evidence, at the time of the inspection, that formaldehyde vapor levels have been measured, and that both 8-hour and 15-minute exposures must have been determined. If each is below the permissible exposure limit and the 8-hour measurement is below 0.5 ppm, no further monitoring is required if laboratory procedures remain constant. If the 0.5 ppm 8-hour TWA or the 2.0 ppm 15-minute level is exceeded, however, monitoring must be repeated semiannually. If either the 0.75 ppm 8-hour TWA or the 2.0 ppm 15-minute level is exceeded, employees are required to wear respirators. Accidental skin contact with aqueous formaldehyde must be avoided with the use of proper clothing and equipment. Inspectors should cite a deficiency if compliance with any of these requirements is lacking, doubtful, or even unclear. Warning signs must be posted where significant hazards exist. NFPA 704, the standardized hazard identification system for fire protection, should be found on access doors to the laboratory and on the outside of storage closets and cabinets, unless local fire authorities have recommended otherwise. Reagent vessels containing hazardous substances should be labeled appropriately. Microbiologic Hazards: A system of universal precautions against the infectious hazards of blood and body fluids must exist. OSHA requires that all employees whose work involves the potential for contact with such substances to be properly educated in universal or standard precautions. Those whose work likely involves contact with body substances must use gloves and other appropriate personal protective devices. This may include phlebotomist and most technologist functions. The inspector should cite a deficiency if the use of gloves or any other item commonly associated with universal precautions is not part of the laboratory's practice. Glove must fit properly. Cleaning and disinfecting of disposable gloves for reuse is prohibited. Gloves, aprons, or lab coats and protective eyewear must be provided and are required for those activities likely to splash the skin. Non-latex or powder free latex gloves are recommended to prevent hypersensitivity reactions to latex proteins. College of American Pathologists Laboratory Accreditation Manual Page 28 Inspector Information The laboratory should have developed policies and procedures for assessing the occupational risk associated with exposure to infectious agents handled in the microbiology laboratory. The four biosafety levels for working with infectious agents are described in the CDC-NIH guideline (Biosafety in Microbiological and Biomedical Laboratories, U.S. Dept. of Health and Human Services, Third Edition, 1993). The laboratory should assess the biosafety level in which it operates and have policies, procedures, and work practice controls appropriate to that level. Laboratory procedures should specify additional precautions if the level of hazard is especially severe. For example, extraordinary precautions must be specified within the procedure manual for surgical pathology specimens and autopsies on patients with Creutzfeldt – Jakob disease or an undiagnosed encephalopathy. A functional biological safety cabinet (BSC) must be in use when culturing mycobacteria, fungi and viruses. Biosafety in Microbiological and Biomedical Laboratories5 has an extensive discussion of cabinet types and their requirements. The inspector must answer: "Does the laboratory have the appropriate equipment in use?" and "Does the equipment function as intended?" The inspector must cite a deficiency when the equipment is present but not regularly used by the personnel for the task intended. Each BSC must be certified annually, normally by an outside vendor because of the specialized equipment required. The inspector should review the records to ensure that the annual inspection included filter checks, flow rate measurements, and tests for seam integrity. Filters need not be replaced annually, only as needed (usually every five years). Waste Disposal: The method for the disposal of all solid and liquid waste must be in compliance with applicable local, state, and federal regulations. The laboratory must have documentation of review of the applicable codes. Federal regulations for chemical waste disposal vary depending on the regulatory status of the facility. Every clinical laboratory is a hazardous chemical waste generator, but only those that are part of a facility that generates more than 100 kg of such waste per month have significant documentary requirements. Many laboratories will also be classified as "hazardous waste storage facilities" if waste chemicals remain on site more than 90 days. Others are "hazardous waste disposal facilities" if they manage the final disposition of those wastes as well. The entire program must be reviewed annually. There should be an ongoing program for hazardous waste minimization. The Environmental Protection Agency regulates the disposal of biohazardous waste such as specimen collection tubes, tissues, and bacteriologic cultures. In general, all such waste must be either incinerated or disinfected before burial in a sanitary landfill. All sharps, especially those contaminated with potentially infectious materials, must be properly discarded in puncture-resistant containers with tightly fitted lids. 5 HHS publication, 1993 stock #017-040-00523-7 College of American Pathologists Laboratory Accreditation Manual Page 29 Inspector Information The inspector should review the laboratory's documented policies and procedures for waste disposal and cite the laboratory if the manual lacks appropriate detail or omits important items. Technologists should be questioned regarding the segregation of wastes by hazard class at the point of generation to determine whether they understand the facility's policy. An inspector should visit the collection point at which wastes are collected for transportation to an offsite facility or for final disposition and try to determine the director's understanding of the final handling of all hazardous wastes. The generator retains "cradle-to-grave" responsibility for any damage to the environment that follows mismanagement of the facility's waste. Radioactive Hazards: Laboratories using radionuclides must manage them in a responsible manner. The inspector should begin this portion of the inspection by review of the radiation safety manual. The Checklist provides a series of questions against which this manual must be compared. The Laboratory General Checklist prompts an inspector to review policies and procedures for radiation safety and to review personnel records for documentation of radiation exposure when indicated. The inspector should ask to see the facility’s radiation license. The laboratory may be regulated under a general license 6 if the facility uses only small amounts of radioactive materials. This is commonly the case when the only contact with radionuclides is with commercially prepared kits for radioligand analysis. Alternatively, the facility may hold a specific license granted to it by the Nuclear Regulatory Commission. A specific license has all the elements of a general license as well as additional items that have been tailored to the requirements of that facility. The Special Chemistry Checklist should be used as guide to inspect laboratories using radionuclides. The Checklist itemizes several questions that commonly apply to facilities with a specific license, however the inspector should inspect such a facility according to the actual requirements listed in that specific license. A specific question in the surgical pathology section of the Anatomic Pathology Checklist addresses specimens that contain radioactive material. Disaster Preparedness: The laboratory safety manual must have a section on "Internal and External Disaster Preparedness." A series of policies and procedures must be available to be followed in the event of a catastrophe such as fire, flood, electrical outage, or spill of hazardous volatiles (internal disaster) or a tornado, earthquake, or other mass-casualty situation (external disaster). The form that this portion of the safety manual takes is unique to each laboratory. The inspector should not hesitate to cite a deficiency if it is believed that the laboratory's documented plans are inadequate. 6 10CFR31.11 College of American Pathologists Laboratory Accreditation Manual Page 30 Inspector Information Hematology and Coagulation Automated Blood Cell Counting: The laboratory must have a documented, detailed procedure for calibration of automated complete blood count (CBC) instruments, including indications from the quality control system of when recalibration is needed. Calibration techniques may include the use of fresh whole blood specimens or stabilized commercial preparations. Value assignment to calibrators, either by primary reference methods or by verification of manufacturers' assigned values, is essential to obtaining accurate results. Commercial materials marketed as controls may lack the careful value assignments of those sold as calibrators. If nonadjustable, precalibrated instruments are used, calibration must be verified with appropriate control materials. Procedures for daily quality control may include any combination of the following three approaches, with tolerance limits defined: 1. Processing of stabilized commercial control materials. Two different concentrations (preferably normal and high) are required for each 8 hours of patient testing; there is no requirement for 3 control levels. The laboratory should plot standard Levy-Jennings graphs with control limits and apply at least some Westgard multi-rule criteria for determining if results are analytically acceptable. It is important for the laboratory to not confuse package insert values for expected recovery range with ± 2 S.D. limits based on their own instrument's between day imprecision. There is no requirement for three control levels, and the use of dilute low particle concentration controls is discouraged. 2. Retained patient specimens. While traditionally applied to CBC instruments, this approach is only valid if there are defined limits of numeric agreement for each parameter between successive samplings. 3. Moving average algorithm for erythrocyte indices and other parameters. The laboratory should set limits that are sensitive to significant alterations in calibration status, yet insensitive to minor fluctuations in patient population values. Fluids used with CBC instruments must be periodically checked for contamination by performing background counts on the instrument. Since nucleated erythrocytes and blood megakaryocytes may have an additive effect on the instrument leukocyte count, appropriate count correction procedures must be present for these constituents. There also must be protocols for common interferences that may affect the accuracy of CBC data, such as lipemia, in-vitro hemolysis, microclots, cold agglutinins, rouleaux, etc. Patient results that exceed laboratory defined reportable limits must be verified (e.g., cytopenic samples should be checked against hemocytometry or blood film estimates). College of American Pathologists Laboratory Accreditation Manual Page 31 Inspector Information Automated Differential Counters: Such instruments must be carefully evaluated against previous patient-testing methods, before being placed in service. Quality control options include periodic comparisons with manual differentials or processing of commercial control materials with at least two different classes of leukocytes or WBC surrogates. The laboratory must have criteria for checking and reviewing leukocyte differential counter data, histograms, and/or blood smears, which have clinically important results flagged by the automated counter. Manual Blood Films: There must be documented criteria for review of blood films with specified abnormalities by the pathologist, supervisor or other technologist qualified in hematomorphology. The laboratory should have a system that ensures that all personnel report microscopic morphology in a similar fashion. Suggested methods to accomplish this include: Circulation of blood films with defined leukocyte differential distributions and specific qualitative abnormalities of each class of cells, and/or Multi-headed microscopy, and/or Use of blood or bone marrow photomicrographs with referee and consensus identifications, such as those from previous CAP Surveys. Automated Reticulocytes: For flow cytometric systems not using commercial kits approved by the FDA, there should be evidence of evaluation of the strength and stability of the fluorescent dye binding to RNA or DNA-RNA. The laboratory should have precision data for its automated method, based on analysis of commercial controls or comparison with manual methods. Documented criteria should be present for identifying samples that may give erroneous results due to interferences (e.g., Howell-Jolly bodies, nucleated RBCs, basophilic stippling, macrothrombocytes). Manual Reticulocytes: To reduce imprecision of microscopic enumeration, the reported reticulocyte concentration must be based on a minimum sample size of 1,000 red cells. Use of a Miller disc is not mandatory. Bone Marrow Preparations: The inspector must review bone marrow slides (routine and cytochemical stains) to assess technical adequacy. If fixed tissue sections and aspirates are independently evaluated by different sections of the laboratory, there must be a mechanism to compare data and interpretations before reports are released by pathologists or qualified hematologists. Abnormal Hemoglobin Detection: If the laboratory uses alkaline cellulose acetate or isoelectric focusing as a separatory technique, all abnormal bands must be verified by solubility testing, acid agar electrophoresis, and/or HPLC, as appropriate. It is emphasized that solubility ("sickle") testing alone is not appropriate as a stand-alone test for hemoglobinopathy screening or evaluation. College of American Pathologists Laboratory Accreditation Manual Page 32 Inspector Information Coagulation Tests: If the laboratory is located in an acute care hospital, there must be a sufficient menu of tests for routine and emergency testing to detect, evaluate, and monitor the progress and therapy of the common disorders of coagulation. The tests should reflect coagulation factor deficiency, coagulation factor inhibitors, accelerated fibrin(ogen)olysis and the monitoring of anticoagulant therapy. Patient results should be reported with the accompanying reference ranges. Appropriate controls (at least two levels) must be performed for all procedures for each eight hours of patient testing. If factor assays are performed, the inspector should examine sample assay data to determine that appropriate calibration points and two dilutions of patient plasma are routinely used. Clinical Chemistry The Automated/General Chemistry Checklist is designed for laboratories that are providing basic chemistry procedures. The Blood Gas Checklist is used for stand-alone blood gas laboratories that are under a different director, supervisor, location and/or CLIA number. If blood gases are performed in the laboratory under the same CLIA number as the main laboratory, with the same laboratory director and supervisor they may be inspected with the Automated Chemistry Checklist. The Toxicology Checklist is required for laboratories performing testing for drugs of abuse. Screening and confirmation procedures are addressed in this Checklist. Note: If the laboratory is performing urine drug screens they must be inspected with this Checklist regardless of methodology. The Toxicology Checklist contains sections for legal alcohol and medicolegal drug-of-abuse testing. This Checklist is used for any non-medical testing such as pre-employment drug screening, criminal justice system, custody decisions, law enforcement, and medical examiner/coroner systems. The inspector must use the Checklist, even if the laboratory is enrolled in the Forensic Urine Drug Testing program, to cover positive screening results released unconfirmed per client request. The inspector should pay particular attention to chain of custody documents, security of specimens and access to forensic data in the laboratory computer system. The Special Chemistry Checklist addresses therapeutic drug monitoring regardless of instrument or method, maternal alpha-fetoprotein testing, cystic fibrosis screening, immunoassays, electrophoresis and gas, thin layer, and liquid chromatography. The Special Chemistry Checklist is also used for immunoassay testing, such as for viral markers even if the testing is done in another department. The chemistry laboratory is usually the largest department in a full-service laboratory, and its test repertoire is usually extensive. Time does not permit a detailed review of every procedure, calibration of every pipette and thermometer, or an extensive review of every quality control record. The emphasis should be selective, focusing on the areas of both highest and lowest volume as well as on areas where test results most impact patient care, and on any apparent problem areas. It is usually more instructive to review the records for 10 tests comprehensively than to review the records for 50 tests superficially. College of American Pathologists Laboratory Accreditation Manual Page 33 Inspector Information Review of personnel qualifications, test repertoire and volumes, analytical systems, and quality improvement/control methods will ensure a well-focused, meaningful inspection It is imperative that the laboratory be enrolled in all appropriate proficiency testing programs, including programs that cover infrequently tested analytes. The proficiency testing program must be well documented and show evidence of appropriate review, evaluation, and corrective action. It is important to evaluate the quality of data, especially in view of the usual great quantity. Solicit proof that the system actually results in useful "real time" data regarding the ongoing validity of the various analytical systems. Questions regarding the procedure manual, specimen handling, result reporting, and controls and standards follow. In no area of the clinical chemistry laboratory is the inspector's judgment more important than in evaluating the adequacy of control specimens (type and frequency) for the various analytical systems employed by that laboratory. Calibration, calibration verification and reportable range verification records should be examined closely to ensure the analytical system stability meets the claims of the instrument/reagent manufacturer. The laboratory must be able to convincingly demonstrate ongoing system accuracy and stability. This is particularly important if the laboratory has elected infrequent quality control for certain systems. If available, appropriate multi-level control specimens must be used at least daily whenever patient specimens are run. Blood gas analysis requires a minimum of two levels of controls each eight hours of operation. Subsequent sections of the Checklist deal with such items as pipettes, glassware, instrument maintenance, thermometers, centrifuges, analytical balances, spectrophotometers, and other basic analytic systems. Depending on the sophistication and scope of testing of the laboratory, these areas may or may not require close scrutiny. In general, if a laboratory employs such equipment as primary analytical techniques, then adequate evaluation is mandatory. When such systems are maintained for backup purposes and are infrequently employed, then evaluation should be directed to adequacy of maintenance of the system for such backup purposes. Are policies and procedures documented and adequate to describe the analytic performance characteristics that must be present and documented before such a system can be used for patient testing? The section in the Checklist devoted to Multiple Analysis Automated Instruments and Systems is brief but important since these analyzers perform the bulk of the testing. The importance of "real time" quality control with documentation of its appropriate use is especially critical with such systems. Do the documented standard procedures for the "set up," operation, and control of the systems provide adequate detail to ensure the integrity of the system? Urinalysis and Clinical Microscopy Specimens: Instructions must be provided for patients for proper collection of clean voided specimens to avoid deterioration of constituents. Specimens must be examined within 1-2 hours of collection unless properly preserved. Simple refrigeration may not be adequate, as it will not prevent the lytic effects of low specific gravity on sediment elements and may induce crystal formation. College of American Pathologists Laboratory Accreditation Manual Page 34 Inspector Information Manual Tests: Refractometer calibration must be periodically verified with at least two solutions of known specific gravity. While the definition of a "complete" urinalysis is at the discretion of the laboratory and dependent upon the population tested, the following chemical constituents are considered important: glucose, protein, blood or hemoglobin, nitrite, and leukocyte esterase. There should be documented criteria for when a routine urinalysis does not require sediment microscopy. As sediment is commonly viewed without stains, microscopes must be in excellent condition, and with Kohler illumination maintained for bright-field microscopy. Dipstick findings should be correlated with microscopy. The laboratory should have a system that ensures that all personnel report microscopy morphology in a similar fashion. Suggested methods to accomplish this include: Circulation of preserved urine sediments with defined abnormalities involving leukocytes, erythrocytes, bacteria, yeast, etc., and/or Multi-headed microscopy, and/or Use of urine sediment photomicrographs with referee and consensus identifications, such as those from former CAP Surveys. Automated/Semi-automated Tests: There should be documented criteria for identifying urine samples that may give erroneous results with a dipstick reader. Automated imaging systems must be carefully compared with manual microscopy before use for patient reporting, and cell count controls processed on each shift of patient testing. Body Fluids: The procedure manual must address handling of partially clotted specimens, cell clumps, or debris noted during hemocytometry or automated counting. For instrument counts, the laboratory should have documentation of linearity studies and defined limits beyond which instrument counts are not reliable. Differentials should always be performed on stained preparations, and use of the cytocentrifuge is strongly recommended. As with blood film morphology, there should be a system to ensure consistency of morphologic classification when multiple personnel are responsible for smear examination. A pathologist or other qualified physician must review body fluid preparations with suspected malignant cells. Semen Analysis: This new section, introduced in 1999, covers basic semen testing; more specialized requirements are found in the Reproductive Laboratory Checklist. In addition to the application of the preceding requirements for Body Fluids, there is an emphasis on issues of specimen collection, motility/viability assessment, and stained morphology classification. College of American Pathologists Laboratory Accreditation Manual Page 35 Inspector Information Microbiology The Microbiology Checklist is divided into 5 subsections: bacteriology, mycobacteriology, mycology, parasitology, and virology, as well as an initial general section applicable to all subspecialties. Judgment is required on the part of the inspector to determine whether the level of service is appropriate to the institution’s needs. Laboratories serving larger institutions will likely provide all services for the subsections listed above. Smaller laboratories may still meet the Standards by providing reliable preliminary screening and/or identification and then refer specimens or cultures for more definitive analysis to a reference laboratory when necessary for patient management. Quality Control: This section includes quality control requirements for prepared and purchased culture media, staining procedures, reagents, antimicrobial susceptibility tests, instruments, and equipment. For each procedure, medium, reagent, item of equipment, etc. to be monitored, the control methods should be defined, as well as the frequency of testing, limits for acceptability, and action to be taken when not acceptable. The inspector should note the following in regards to commercially prepared culture media: The laboratory must ensure that all media used, whether purchased or prepared in-house by the laboratory, are sterile, able to support growth appropriately, and are appropriately reactive biochemically. For laboratories preparing their own media, it will be necessary to maintain stock or reference organisms and to test the media before, or concurrently, with use. Explicit documentation of such testing is essential and must be retained for at least two years. For prepared, purchased media the laboratory must have explicit documentation that each lot of purchased medium is tested for sterility, ability to support growth of appropriate organisms, and biochemical reactivity at the time of preparation, or concurrent with use in the laboratory. Laboratories that rely on manufacturers’ quality control of media should have a copy of the NCCLS document M-22-A2, Quality Assurance for Commercially Prepared Microbiological Culture Media. The manufacturer or preparer must supply documentation to the user that its quality control activities meet the NCCLS guidelines. For each lot, the preparer should certify that quality control performance was acceptable and a record of the lot numbers for all media is retained for at least two years. The user laboratory may record that fact in place of the more detailed documentation of media performance. The user must visually examine each shipment for breakage, contamination, appearance, or evidence of freezing or overheating. College of American Pathologists Laboratory Accreditation Manual Page 36 Inspector Information The user must continue to test each lot of chocolate, Thayer-Martin, Martin-Lewis, Campylobacter, and other media not listed specifically in M22-A2 as being exempt from such testing, using quality control methods used for media manufactured in-house. In addition, each shipment or lot of a commercial identification system must be tested for appropriate performance. The director is responsible for the quality and performance of media and must document all media failures and the resultant corrective action taken. Quality control of antimicrobial susceptibility tests is accomplished by monitoring the performance of the test system with appropriate reference control organisms. Control organisms must be run with each new lot or batch of antimicrobials or media, and daily thereafter. The frequency of test monitoring may be reduced to weekly if satisfactory daily performance is documented. Whenever weekly tests yield unacceptable results, daily quality control testing must be performed until the cause of the unacceptable results is determined and resolution of the problem is documented. Bacteriology: The inspectors’ discretion is necessary to evaluate a laboratory's protocols for specimen work-up and identification of organisms and test systems. For example, no specific requirements are listed for the extent of work-up of specimens such as sputum, urine, stools, and wounds. Policies should be mutually acceptable to the medical staff and the laboratory. Selection of antibiotics to be tested and reported with each antimicrobial susceptibility test requires input from the pharmacy department and the medical staff. The inspector should assess the adequacy of the blood culture system for detection of microorganisms for the patient population. The laboratory should keep blood culture statistics to include the number of true positive cultures and the number of contaminated cultures, as a monitor of collection techniques in order to maintain a low level of contamination. Mycobacteriology: The College of American Pathologists supports a policy that encourages laboratories to use the most rapid and reliable methods available for detection and identification of mycobacteria, especially M. tuberculosis. This is of particular importance in areas where the incidence of tuberculosis is increasing. Questions relating to smears, processing, culture media, identification, and susceptibility testing of mycobacteria are recent additions to the Checklist. The inspector must assess the relevancy of these questions in view of the above stated incidence of tuberculosis in the area being served. Mycology: All staining procedures should be checked and results recorded for each new batch of preparations, and at least daily against known positive and negative control organisms. For stains such as Gomori methenamine silver, the slide itself serves as the negative control. College of American Pathologists Laboratory Accreditation Manual Page 37 Inspector Information Virology: The laboratory must have the appropriate media available for all of the virology services that are performed in the laboratory. Media for this purpose are listed in the Checklist. Parasitology: Concentration procedures and permanent stained preparations must be performed on all stools submitted for parasitological microscopic examination. A microscopic examination of liquid stools should include a direct wet mount if submitted fresh. Laboratories must have an ocular micrometer available for determining the size of eggs, larvae, etc., and the micrometer should be calibrated for the microscope in which it is used. The micrometer does not require periodic checking if the optical path is unaltered. Transfusion Medicine The Transfusion Medicine Checklist is generally consistent with the current edition of the Standards for Blood Banks and Transfusion Services of the American Association of Blood Banks (AABB), as both documents represent good practices in this area. However, accreditation by the AABB and the CAP are separate events. Therefore, if an AABB inspection is performed simultaneously with a CAP inspection, all questions in the Transfusion Medicine Checklist must still be addressed. The emphasis in this section is on proper procedure in specimen handling, preparation, reagents and controls, maintenance and procedure manuals, maintenance of instruments, and verification and documentation of reagent performance. Quality control requirements are similar to those in chemistry and diagnostic immunology, and for those laboratories performing molecular diagnostic procedures, those Checklist requirements must also be met. For laboratories involved in transplantation, the personnel and other requirements must meet federal requirements. Component Accession and Disposition Records: The component records should be traceable from inventory to disposition. It must be possible to account for every unit in the records, including quarantine, ultimate disposition, wastage, and incineration. For transfusion services, it must be possible to identify the patient receiving a given unit. Technical Procedures: Blood typing and compatibility procedures should be directly observed by the inspector to see if actual practice corresponds to the procedure manual. Transfusion and Apheresis: Patient care activities should be observed with particular emphasis on patient identification and blood component administration procedures. Those off-site activities that interface directly with the laboratory, such as blood transfusion and maintenance of remote refrigerators, should be observed as a measure of the effectiveness of laboratory communication. Transfusion reaction records and similar clinical pathology consultation should be reviewed carefully. College of American Pathologists Laboratory Accreditation Manual Page 38 Inspector Information Donor Procedures: If donors are drawn and/or units are processed at the facility, each step should be evaluated, including the details of the donor interview, phlebotomy, and storage/release/quarantine procedures. If infectious disease testing is done, the adequacy and appropriateness of procedures should be reviewed, regardless of where in the facility this is performed. If the facility is computerized, an evaluation of the adequacy of the procedures, hardware, and software should be undertaken. Immunology and Syphilis Serology Positive and negative controls for qualitative tests must be run at least once on each day of analysis, based on the manufacturer's recommendations. For quantitative tests, control samples at more than one level must be run at least once each day of analysis. When results are reported as “weakly” positive, a weakly positive control should be used. New kits and reagents must be checked against old reagents to ensure comparable reactivity. One common method for verification is the processing of matrix control materials used with the old kit using the new reagents. Certain immunologic reagent/kit systems include built-in controls. If such controls actually measure reactivity and involve all components of the system such as antigen, complement and antibody, external matrix controls may not be required, so long as the procedures are waived or of moderate complexity under CLIA ’88. However, some systems include built-in controls that involve only part of the testing process. If for example, the control in such a system produced a color change without involving an antigen-antibody reaction and an analyte, it would not be an adequate control of the method and would need to be supplemented with true external matrix controls. The Checklist provides clarification of when controls must be evaluated. Anatomic Pathology The Anatomic Pathology Checklist covers general anatomic pathology, surgical pathology, the histology laboratory, autopsy pathology, and electron microscopy. Cytopathology is covered by the Cytopathology Checklist. In keeping with the general approach of the Laboratory Accreditation Program, the inspector is expected to evaluate all aspects of quality control and quality improvement in the various sections of anatomic pathology. The inspector will consider procedural and technical activities (process or quality control), issues related to the professional role of the pathologist (quality improvement) and an evaluation of the quality of the diagnostic report (features of both quality control and quality improvement). Quality Improvement Program: The preamble to this part of the Checklist designates the activities that must be included. The design of the program is the responsibility of the laboratory director. While the type of program will vary according to the staff size and the volume and type of diagnostic material, the basic quality control/quality improvement principles of documented description, organization, systematic review, documentation and communication must apply. Practical suggestions for implementing and documenting the program can be found in the CAP Quality Improvement Manual in Anatomic Pathology (CAP 1996). College of American Pathologists Laboratory Accreditation Manual Page 39 Inspector Information Quality Control: These questions address issues concerned with collection and accessioning of specimens, the surgical specimen examination area, and procedures related to surgical specimen examination. Although not solely a quality control issue, surgical consultation (rapid diagnosis or frozen section) is addressed in this portion of the Checklist. Review of the quality of surgical pathology reports is considered in this part as well, and the questions included address the need for clear and concise gross descriptions that contain adequate information about the lesions present. The final diagnosis should correlate with the descriptions, provide sufficient information to contribute to patient management, and be available in a timely fashion. The laboratory should have a mechanism to correlate the results of specialized studies (e.g., electron microscopy, immunohistochemistry, nucleic acid probes, and cytogenetics) with the morphological diagnosis. Histology: Quality control items include evaluation of procedure manuals, histologic preparations, special stains, (both histochemical and immunohistochemical), instruments, and equipment. Questions pertaining to immunohistochemistry are included in this section. The inspector should be aware that issues related to the use of positive and negative controls are discussed in an explanatory note. Safety questions emphasize the adequacy of ventilation in areas of specimen handling and processing and the handling of infectious tissues and other contaminated materials, including special precautions related to Creutzfeldt-Jacob disease. Autopsy Pathology: Items emphasized include timely reporting of both preliminary and final diagnostic findings, and policies regarding proper conduct of autopsies on patients with known or suspected infectious diseases. In addition, the important quality assurance role of the autopsy must be addressed. Quality improvement programs must consider both the quality of the performance of the autopsy itself and the important role of the autopsy in the enhancement of the quality of patient care. Electron Microscopy: The initial part of this section is concerned with quality control issues such as procedure manuals, specimen collection, specimen preparation, instruments and equipment, reports, and records. This is followed by a review of the physical facilities and safety items that pertain specifically to the electron microscopy service. College of American Pathologists Laboratory Accreditation Manual Page 40 Inspector Information Physical Facility: Special attention should be given to the suitability of space and environment for microscopic study. Because the sections of anatomic pathology ultimately deal with subjective, consultative medical opinion, the inspector should recognize that different laboratories vary in their design and implementation of overall quality improvement programs. It is important that the inspector not insist on "my way" but rather make an effort to determine whether the programs and procedures in place achieve the fundamental goal, to provide the referring physician with an accurate, timely, and clinically relevant diagnostic report based on the interpretation of optimal technical preparations. Cytopathology The inspector should be a pathologist and/or supervisor-qualified cytotechnologist actively involved or experienced in the current practice of cytopathology and conversant with contemporary quality improvement practices, as well as the CLIA '88 regulations pertinent to cytopathology. In addition to the Checklist, it is helpful for the inspector to review the CAP Quality Improvement Manual in Anatomic Pathology and the CLIA regulations (e.g., the CAP/ASCP summary of the Final Rules). The inspector should plan to spend several hours inspecting the cytopathology section regardless of case volume. The on-site inspection will require documented review of case (slide) material, direct observation of technical procedures, and careful review of quality improvement practices. The inspection process should confirm compliance with each Checklist item pertinent to the laboratory. Personnel and Screening: The inspector should review the qualifications of the pathologist director (technical supervisor), supervisor (pathologist or cytotechnologist), and cytotechnologists, and assess documentation of performance of their respective responsibilities, as outlined in the Checklist. The importance of the screening process should be considered. Sufficient qualified personnel and space should be available to handle the case volume and variety. The inspector should evaluate whether the facility provides adequate space and a suitable environment for screening. Although CLIA '88 establishes maximum workload limits, the laboratory director is obligated to establish individual workloads, as indicated in the Checklist. The inspector should review the documented workload policy, documentation of the periodic determination of workload for individuals who screen slides, and the daily documentation of slides screened by each individual. Procedure Manual: The inspector should observe procedures for specimen accession and processing, staining, screening, hierarchic review, preparation of reports, and storage and retrieval of slides. Each of these activities should correspond to the laboratory's documented procedures. During specimen accession and processing, the adequacy of safety measures should be evaluated. College of American Pathologists Laboratory Accreditation Manual Page 41 Inspector Information Criteria should be documented and implemented for rejection of specimens and for classification of specimens as unsatisfactory, and procedures should address notification of the submitting physician in these cases. Measures for prevention of cross-contamination of specimens should be included in processing/staining procedures. Case management procedures should cover the screening process and specify criteria for rescreening and pathologist review. Documented policies and procedures must be in place for issuing of reports, including amended reports when indicated, for ensuring communication of findings to the submitting physician (especially crucial and complex findings), and retention and retrieval of reports and slides. Cytopathologic findings should be reported using standard descriptive diagnostic terminology. The use of a "class" system is insufficient for both negative and abnormal findings. On-site Case Review: An important component of the inspection of cytology is an on-site review of actual case (slide) material. The on-site review of cases offers an opportunity for the inspector to assess the laboratory's overall processes. The inspector should request a selection of gynecologic, fine needle aspiration and other nongynecologic cases, including negatives and abnormals. The cases should be selected in advance of the inspection and in a random manner defined by the team leader. The review should encompass the requisition, laboratory worksheets, information available to the cytotechnologist and/or pathologist at the time the case was evaluated (e.g., clinical data, laboratory records of previous or concurrent specimens), the slides, and the preliminary and final reports of the reviewed cases. The on-site review is designed for process evaluation, not as a comprehensive rescreening or assessment of competence. The inspector must complete the slide review chart in the ISR. If there are believed to be clinically significant diagnostic discrepancies, these should be discussed by the pathologist inspection team leader with the laboratory director. For the purpose of this review interpretations may be considered discrepant if they are not in the same series of the diagnostic menu of the CAP PAP Program (e.g.,“100 series” vs. “200 series”). Cases considered to be “satisfactory but limited” or ASCUS/AGUS either by the inspector or inspectee should not be considered in the analysis to determine significant discrepancies because of current lack of interlaboratory reproducibility of the categories. Quality Improvement: The facility's QI program should address the validation of both normal and abnormal diagnoses and the assessment of laboratory and personnel performance. Quality measures for abnormal findings should include such activities as peer and hierarchic review, correlation of cytologic findings with histologic and clinical findings, documented evaluation of significant discrepancies, and appropriate use of intradepartmental and extradepartmental consultation. College of American Pathologists Laboratory Accreditation Manual Page 42 Inspector Information Evaluation of the quality of negative findings is more difficult, but is very important in reducing the likelihood of a false negative report. Routine evaluation of specimen adequacy is essential to ensure that diagnostic interpretations are not reported on unsatisfactory specimens. Among other useful techniques are retrospective review of previous material whenever a new significant abnormality is identified and prospective rescreening of negative cases. At least 10 percent of gynecologic cases screened as negative by a cytotechnologist must be prospectively rescreened by an individual qualified to be a cytology supervisor. Rescreened slides must include both randomly selected and high-risk cases. Rescreening of random negative specimens enables monitoring of false negative fractions, whereas rescreening of specimens from "high-risk" patients is more likely to identify abnormalities. The documented rescreening program must include negative gynecological smears received within five years of a new high-grade intraepithelial lesion or cancer diagnosis, if applicable. The inspector should assess the procedures for rescreening and hierarchic review, including criteria for case selection (e.g., identification of "high risk" and retrospective review specimens) and provision of feedback to the original screener. The statistical records for gynecologic and nongynecologic specimens should be reviewed; benchmarking data from CAP interlaboratory comparison programs are useful in evaluating the laboratory's statistical results. Educational opportunities should also be appraised. A laboratory that examines gynecologic specimens must be enrolled in the CAP Interlaboratory Comparison Program in Cervicovaginal Cytology (PAP) or a CAP approved glass slide program that evaluates the laboratory employee performance. Other internal or external programs may be utilized to meet further educational and personnel evaluation needs appropriate to the laboratory's scope of practice. All quality surveillance activities should be documented, with evidence of review and evaluation. Findings should be shared with the responsible pathologists and cytotechnologists. Results should be incorporated into revisions of policies, procedures, and personnel assignments and workload. Practical suggestions for implementing and documenting these and other measures can be found in the CAP Quality Improvement Manual in Anatomic Pathology. Cytogenetics Laboratories that provide cytogenetic services should be inspected by a qualified cytogeneticist. The inspection team leader should consult with the State or Regional Commissioner, if one cannot be found. The Laboratory Accreditation Department can suggest a cytogeneticist that the team leader can call to add appropriate expertise to the team. College of American Pathologists Laboratory Accreditation Manual Page 43 Inspector Information The inspector must review at least 10 completed cases. The slides should be well prepared and banded. The documented (paper or electronic) trail of an analysis from accession to final report should be followed to verify its coherence. The final interpretation should be substantiated by the photographs and other records. Statistically significant cell sample sizes must be used. Verbal, preliminary reports must be documented on the final report and reports issued appropriately using the International System for Human Cytogenetic Nomenclature (I.S.C.N.). Histocompatibility The emphasis in this section is on proper procedure in specimen handling, and preparation of reagents and controls with verification and documentation of reagent performance. Quality control requirements are similar to those in chemistry and diagnostic immunology in regard to procedure manuals and instrument maintenance. Personnel qualifications must meet federal requirements relating to transplantation. It is important that the inspector verify that the laboratory participates in approved proficiency testing programs. Flow Cytometry This Checklist includes DNA content and cell cycle analysis. The laboratory must document the optical alignment, instrument sensitivity, and run fluorescent beads daily. All reagents must be used within the manufacturer’s stated expiration date. Regional and State Commissioners and the Laboratory Accreditation Department have names of individuals who have expertise in this area who have volunteered as inspectors. Molecular Pathology Techniques not requiring amplification may be inspected using other discipline specific Checklists. Regional and State Commissioners and the Laboratory Accreditation Department have names of individuals who have expertise in this area who have volunteered as inspectors. Point of Care Testing This Checklist is used for inspection of testing that is performed outside the physical facilities of the clinical laboratory, in non-dedicated space, within an institution (examples are bedside and/or ward testing). The testing is typically performed by nurses and other personnel without formal laboratory science backgrounds. The laboratory is encouraged to centralize coordination of the point of care testing program with laboratory personnel responsible for monitoring of testing procedures, QC, and the training of the individuals who perform the tests. Point of Care Testing (POCT) is inspected in conjunction with the inspection of the main clinical laboratory as an additional Checklist section. However, POCT is inspected as a separate additional Special Function Laboratory when under a different directorship and CLIA number than the main laboratory. College of American Pathologists Laboratory Accreditation Manual Page 44 Inspector Information When POCT records are maintained in a central location under one supervisor, use only one copy of the Point of Care Checklist and visit a few sites to review compliance. If POCT records are decentralized, a Checklist for each location must be used and each site inspected separately. An additional fee is charged for each inspection site. College of American Pathologists Laboratory Accreditation Manual Page 45 Inspector Information Laboratory Information INSPECTING OTHER TYPES OF LABORATORIES Special Function Laboratories Special function laboratories are administered independently of the main clinical laboratory, employ few personnel and are dedicated to the performance of a highly select group of clinical procedures. Examples of Special Function laboratories include blood gases performed by respiratory therapy and special hematology analyses in pediatrics. At least two Checklists are required: Laboratory General plus the Checklist appropriate to the specific function(s). The inspection team leader schedules the inspection concurrently with the main laboratory inspection and contacts all directors to notify them of the inspection date. Special function laboratories may request their own Summation Conference. The special function laboratory and main laboratory accreditation process and decision are made independently. The hospital administrator and client members of the medical staff will be interviewed for every special function laboratory within a hospital. Affiliated Laboratories Affiliated laboratories are located at physically separate sites but are affiliated by management and/or ownership. Each site is considered a separate laboratory with separate inspection fees, materials, Checklists and each site will receive a separate certificate of accreditation. Examples of affiliated laboratories are: a.) two or more merged hospitals that provide some services at each site. Often one site is designated as full service and the other is rapid turn around; b.) a large commercial laboratory that has branches in different geographic locations; or c.) remote limited service or special function laboratories. The inspection team leader needs to take into consideration the location of these laboratories when they are inspected at the same time as a laboratory with which they are associated, in order to allow time for the inspection and arrange for transportation if necessary. System Inspection Option The system option for laboratory accreditation provides Medical Directors the choice to have multiple laboratories inspected by one team of inspectors using the same Checklists within a few days of each other. This provides the opportunity for coordinated preparation and development of common strategies to comply with the CAP requirements. This initiative allows key personnel with responsibilities at multiple sites to participate in onsite inspections. Laboratories may express an interest in the Systems initiative at any time during the accreditation cycle, however six months before an accredited laboratory’s anniversary date is preferred to allow ample time for coordination of multiple laboratories. College of American Pathologists Laboratory Accreditation Manual Page 46 Inspector Information Laboratory Information For further information, please contact the Laboratory Accreditation Program at 1-800-3234040, extension 6065, 847-832-7000, extension 6065, or visit our Web Site at www.cap.org. Satellite Laboratories Satellite laboratories are usually small branch laboratories that are affiliated with, but not physically located at the same address as the central laboratory. In most cases, the services that are provided correspond with the Limited Service Laboratory Checklist. Separate fees, inspection materials and Checklists are required. This inspection can occur concurrent with the main laboratory inspection. The inspection team leader needs to take into consideration the location of the satellite laboratories when they are inspected at the same time as a laboratory with which they are associated, in order to allow time for the inspection and arrange for transportation if necessary. Staff Inspected Laboratories The Laboratory Accreditation Program’s new Expanded Eligibility Criteria were created to encompass satellite laboratories that previously did not meet the criteria for LAP accreditation. Under the new criteria, satellite and special function laboratories may now qualify for CAP accreditation if they are affiliated with a currently accredited laboratory through either directorship, ownership, or administration, regardless of the distance from the accredited laboratory. This allows the institution to have consistency in all laboratories. by using the same accrediting organization. This program is in keeping with the College’s philosophy of peer review by using CAP employed Medical Technologists to review affiliated laboratories that are often performing limited testing and have limited oversight by a pathologist. Limited Service Laboratory The Limited Service Checklist is provided as a convenience when inspecting a laboratory or a laboratory section whose scope of services is confined to a small number of commonly performed tests covering multiple disciplines. It relieves the inspector of the burden of completing multiple Checklists during on-site visits to such laboratories. The Master Activity Menu is divided into a basic list and an extended list of reportable assays. Limited Service Checklist usage is determined by the selection of Reportable Assays – Basic List (only) within a subdiscipline. If assays are selected from the basic list and the extended list of reportable assays the discipline specific Checklist must be used. The Limited Service Checklist CANNOT be used alone if toxicology, anatomic pathology, cytopathology, flow cytometry, molecular pathology, histocompatibility, cytogenetics, or point of care testing are performed. College of American Pathologists Laboratory Accreditation Manual Page 47 Inspector Information Laboratory Information No more than two additional discipline-specific Checklists may be used with the Limited Service Checklist (The Point of Care Checklist is not considered an additional disciplinespecific checklist). If additional discipline-specific Checklists are needed, then only discipline-specific Checklists will be used, rather than the Limited Service Laboratory Checklist. College of American Pathologists Laboratory Accreditation Manual Page 48 Laboratory Information THE SUMMATION CONFERENCE Pre-Summation Team Meeting The team leader should check that all appropriate sections and questions are complete, with the correct deficiency numbers on the pink sheets, and are signed by the individual inspectors. Part B of the Inspector’s Summation Report (ISR) lists the Checklist number for the deficiencies with a brief description of the reason for the deficiencies cited each page of the pink form. The brief description should provide details on the nature of noncompliance. This is the official record of the inspection and must be readable for accurate documentation and appropriate follow-up. Recommendations should be cited separately The team leader should review all findings privately with members of the inspection team before the Summation Conference. Cite the deficiencies in a straightforward manner and relate each to concrete information gathered during the inspection process. Summation Conference Education and peer review are essential parts of this conference. The findings from the inspection are reviewed with the director, supervisors and as many of the technical staff as practical. Invitations can also be extended to administrators and the chief of the medical staff. The Summation Conference should open with a short review of the objectives of LAP. The review covers all deficiencies that are listed in Part B of the ISR. The director should find no surprises in the ISR. Findings should have been discussed with the laboratory supervisors during the inspection. If the laboratory can provide adequate documentation to remedy deficiencies before the inspection concludes, such deficiencies are considered corrected and should not be reported. The post-inspection process is reviewed with the conference attendees. The inspection team leader should remind the laboratory that deficiency responses and documentation of corrective action must be submitted within 30 days of the inspection date, and that there will NOT be a formal list of deficiencies sent from the College to initiate corrective action and responses to the CAP. Note: Prior to the inspection the laboratory should have received instructions on how to respond to the inspection report. This information is also available by “Fax on Demand” (1800-323-4040, extension 6027 or 847-832-7000, extension 6027 , request document number 303). There should be adequate time allowed to present findings and answer questions. A copy of Part B of the ISR, which consists of the deficiencies and the recommendations is left with the laboratory director. College of American Pathologists Laboratory Accreditation Manual Page 49 Laboratory Information Both the laboratory director and the inspection team leader must sign Part B of the ISR. The Summation Conference is an appropriate time to discuss improvement of the laboratory in educational terms. A response and/or corrective action is not required for recommendations, but should be reviewed as suggested improvements. Phase I deficiencies require a documented response. Phase II deficiencies require a documented response along with supporting documentation. Any unresolved differences concerning interpretation of standards or Checklists should be addressed at this time. Unresolved differences should be documented in the ISR and left for the Regional Commissioner to review. Unresolved differences should be addressed by the laboratory director in the laboratory’s documented response, along with supporting documentation demonstrating compliance before the inspection. The challenged deficiencies are referred to the Regional Commissioner for possible expungement from the record. Concluding the Inspection The Inspector should: thank the director for supporting the LAP process; recruit any director/pathologists for inspection team leaders and ask permission to forward names to the Regional Commissioners; photocopy each page of the ISR Part B - leave the copy with the laboratory director and place the original in the packet returned to the CAP; return the original ISR, CME, Team Member List Form, and Claim for Inspector Reimbursement and signed state specific forms immediately in the prepaid UPS mailing envelope. This mailer can only be used in the 48 contiguous states. Materials from other inspections (example: foreign countries, Alaska) should be returned to the CAP by the most reliable service available which is traceable; send a post inspection letter thanking the director for the laboratory’s hospitality. The remaining steps in the accreditation process are performed by the College: The evaluation is based on many standards, performance, qualifications of personnel, QI and QC programs, performance in the surveys program, etc. Using the information provided by the inspector, the technical specialist evaluates the deficiency response for appropriateness and completeness and forwards the information to the Regional Commissioner. The Regional Commissioner may request additional information or recommend accreditation. Accreditation is granted by the Commission on Laboratory Accreditation . College of American Pathologists Laboratory Accreditation Manual Page 50 Laboratory Information The laboratory then receives an Accreditation Packet by mail. This packet includes: Certificate of Accreditation Letter of accreditation with disciplines listed List of specialties/subspecialties that are accredited Final List of Deficiencies Press Release College of American Pathologists Laboratory Accreditation Manual Page 51 Laboratory Information THE INSPECTION REPORT Inspector’s Summation Report (ISR) Part A of the ISR is used to report any fundamental disparities between the intent of the standards and the function of the laboratory or role of the director (this is confidential information and does not go to the laboratory). The inspector can write a separate confidential report when warranted, for review only by the technical specialist, Regional Commissioner, and the next inspector. The entire Commission reviews a laboratory's inspection report before denial (the inspector’s confidential comments are pivotal in such decisions). The ISR should include all correspondence with the laboratory. Part B of the ISR includes the deficiencies cited and the recommendations from the team. A copy of Part B of the ISR must be left with the laboratory director If the inspector realizes something was left out of the ISR, a letter must be written to CAP Northfield office explaining the addition, and a copy sent to the laboratory director. Team Member List Form Return the team member form to the CAP Northfield office once the inspection has been completed. Expense Reimbursement Return reimbursement expense claims for all team members to the CAP Northfield office with the inspection packet. The claim form includes instructions for expenses that are reimbursed, maximum allowable expenses and receipt requirements. Continuing Medical Education (CME) CME forms are provided and may be completed by all team members. (California Medical Technologists may apply the Summation Conference portion, 1-2 credit hours, toward their requirements for California state licensure.) The College of American Pathologists is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to sponsor continuing medical education for physicians. College of American Pathologists Laboratory Accreditation Manual Page 52 Laboratory Information The College designates this continuing medical education activity for up to 7 credit hours in Category 1 of the Physician’s Recognition Award of the American Medical Association and Category A1 of the Pathology Continuing Medical Education Award. Each physician should claim only those hours of credit he/she actually spends in the educational activity. This continuing medical laboratory education activity is recognized by the American Society of Clinical Pathologists as meeting the criteria for up to 7 credit hours of CLME credit. ASCP CLME credit hours are acceptable to meet the continuing education requirements for the ASCP Board of Registry Continuing Competence Recognition Program. AACC members may include inspection credits hours on their transcripts. Pathologists in accredited laboratories may claim up to 100 hours of Category A-3 CME credit over a three-year period towards the Pathology Continuing Medical Education Award. The CME forms also provide information to help maintain the CAP inspector database. Return of Inspection Packet UPS pre-paid envelopes are provided for the return of the inspection report Return in the folder: Original Inspector’s Summation Report (ISR) CME Claim for Inspector Reimbursement Team Member List Form State specific forms, signed (if applicable) Take the packet to your mail center for inclusion in your institution’s regular UPS pick-up or delivery (excluding Hawaii, Alaska, or APO). If your institution does not use UPS, the packet can be taken to a local UPS center, or you may call LAP operations (847-832-7000, extension 6055 or 800-323-4040, extension 6055) for other options. Provide an explanatory comment in the ISR if an inappropriate Checklist was present in the inspection packet College of American Pathologists Laboratory Accreditation Manual Page 53 Laboratory Information POST INSPECTION PHASE Laboratory Inspection Packet Before the onsite inspection the lab will receive: detailed instructions for completing its response to any deficiencies cited during the inspection. blank response sheet. a blank cover sheet to be signed by the laboratory director and returned with the response. Laboratory Specific Activity Menu for the laboratory’s review. Checklist Selection Report which will identify the Checklists that will be used at the on-site inspection. Additional copies of the cover sheet and deficiency response sheets are available via the CAP Fax Service at 800-323-4040, extension 6027 or 847-832-7000, extension 6027 (request document 303). The laboratory must return all responses and documentation of corrective action for deficiencies listed in the ISR within 30 days following the inspection. Laboratories that do not respond within 30 days will receive a certified reminder letter. Continued failure to respond may result in recommendation for the denial or revocation of accreditation. Phase I deficiencies are those that do not seriously affect the quality of patient care or significantly endanger the welfare of the laboratory worker. Phase I deficiencies require documented responses. Phase II deficiencies are major deficiencies that may have a serious effect on the quality of patient care or may affect the health and safety of hospital or laboratory personnel. All Phase II deficiencies require a documented response and supporting documentation of corrective action, that meets with the approval of the Commission on Laboratory Accreditation, before accreditation is granted. Examples of supporting documentation include policies and procedures, log sheets with evidence of use, internal memos, photographs, sketches, purchase orders, and meeting minutes. Organization of documentation materials should occur in the order the deficiencies were cited. Each phase II deficiency should have its own supporting documentation. It is recommended that policy and procedure changes be highlighted. Laboratories are encouraged to use the most recent edition of each Checklist which is available via the CAP Web site at www.cap.org. The Web site format includes not only Checklist questions and explanatory text but also references which may be helpful in determining corrective action. If you do not have access to the Web site, please call the Laboratory Accreditation Program at 800-323-4040, extension 6055 or 847-832-7000, extension 6055 to request a copy. College of American Pathologists Laboratory Accreditation Manual Page 54 Laboratory Information Packet Review Upon return of the inspection packet from the inspection team leader to the CAP Northfield office, an audit of the packet, and review of the ISR is performed by the laboratory accreditation staff to ensure that the material is complete. All deficiency responses and documentation of corrective action from the laboratory are thoroughly reviewed by CAP technical staff. If the laboratory wishes to challenge a particular citation, it must state in the documented response what deficiency was cited in error and provide documentation that demonstrates compliance before the time of inspection. Those deficiencies that have been approved for removal by the Regional Commissioner will not appear on the final list of deficiencies and are not part of the permanent laboratory record. The inspection report is then forwarded to the Regional Commissioner. If the responses adequately address the deficiencies, the Regional Commissioner will notify the laboratory that accreditation is recommended. Upon recommendation of accreditation: The official accreditation letter is sent to the laboratory director with copies to the administration where applicable. The laboratory will receive a press release and a final list of deficiencies. The laboratory should keep the final list of deficiencies on record for review by other accrediting agencies (e.g., Joint Commission on Accreditation of Healthcare Organizations). A copy of the list of deficiencies is included in the next inspection packet. Immediate Review Criteria Immediate review criteria flag a laboratory’s record for special follow up by the Regional Commissioner. This occurs when a laboratory is cited with more than 5 percent of the total possible Phase II deficiencies. In the past, laboratories with such large numbers of deficiencies have had difficulty correcting them within the allotted time. Following the review of these laboratories, the Regional Commissioners take prompt and appropriate action. Such action may involve one or more of the following: direct communication between the director and Commissioner to determine whether correction is probable; a focused reinspection of the problem areas; denial of accreditation. College of American Pathologists Laboratory Accreditation Manual Page 55 Laboratory Information Accreditation Accreditation is recommended by the Regional Commissioner and granted by the CLA when the laboratory has provided acceptable documented responses to Phase I and Phase II deficiencies and satisfactorily documented correction of all Phase II deficiencies. Accreditation is valid for two years from the date of the first inspection and is renewable every two years on the accreditation anniversary date. Denial or Revocation Accreditation is denied or revoked when the laboratory fails to correct Phase II deficiencies or fails to meet the Standards for Laboratory Accreditation or any other requirement for continued participation in the Laboratory Accreditation Program. Laboratories with numerous deficiencies that cannot be corrected within a reasonable period of time may be presented to the entire Commission on Laboratory Accreditation. Only the entire Commission or executive committee may make the decision to deny or revoke accreditation. New laboratories trying to achieve accreditation for the first time, if conditions warrant, may be advised to withdraw and reapply at a later time. Accredited laboratories formally denied accreditation will receive notification by certified mail. Any agencies accepting CAP accreditation, such as the Health Care Financing Administration (HCFA), will be notified. Appeals The laboratory may appeal the decision of denial or revocation within sixty days of receiving documented notice of denial. A request for reconsideration shall not stay the denial of accreditation. Request for information regarding appeal procedures should be directed to the Regulatory Analyst in the Northfield office at 800-323-4040, extension 7471 or 847-832-7471. College of American Pathologists Laboratory Accreditation Manual Page 56 Laboratory Information Post-Inspection Critique As part of on going quality assurance of the inspection process, the director will be asked to evaluate the quality of the laboratory’s inspection on the post-inspection critique questionnaire. The laboratory director and staff may offer comments or suggestions. When the questionnaires are received in the Northfield office, copies are sent to the Education Commissioner, the appropriate Regional and State Commissioners and the Director of the Laboratory Accreditation Program. The inspector may call the State Commissioner for feedback regarding the inspection critique. The post-inspection critique provides an evaluation of the following processes: Prompt processing of the application by the LAP office. Performance of the inspection in a professional manner that supports the CAP's philosophy of education and peer review. Objective assessment by the inspection team in all Checklist areas. Educational value of the inspection for the laboratory and staff. College of American Pathologists Laboratory Accreditation Manual Page 57 Laboratory Information MAINTAINING ACCREDITATION Proficiency Testing Participation and Satisfactory Performance Exceptions in proficiency testing participation and performance will be brought to the attention of the accredited laboratory's director. Laboratories must respond in a timely manner (within 19 days) to any exceptions by identifying the cause of the exception and describing the action taken to correct the exception. Self-Evaluations During the second year of the two-year accreditation cycle, laboratories complete a mandatory self-evaluation. Checklists are sent to the laboratory for completion of the selfinspection. The self-inspection verification form must be returned within 30 days of receiving the self-evaluation materials. Upon completion of the self-evaluation, the laboratory returns the self-evaluation verification form, signed by the medical director. The verification form states that the laboratory will correct all deficiencies cited and that documentation will be kept on file for review by the next CAP inspection team. The laboratory should keep the self-inspection Checklists on file for future reference. Failure to perform the self-evaluation is a serious deficiency and may result in an immediate on-site inspection or denial of accreditation. Anniversary of Accreditation Accreditation is maintained on a continuous basis provided that: reapplication forms are returned within 35 days of the date sent from the CAP Northfield office (these forms are automatically sent to the laboratory 150 days before the anniversary date); a self-evaluation is completed in the interim year; the laboratory successfully participates in approved proficiency testing programs; the College and the Health Care Financing Administration are notified in writing of a change in the laboratory's director, location, and/or ownership; and the laboratory continues to meet all other Standards for Laboratory Accreditation. The LAP functions on a fixed accreditation cycle. This means that a laboratory will be inspected within the 30 days before the accreditation anniversary date every two years. Implications of Accreditation Certain regulatory agencies and other accrediting programs have officially recognized the value of the CAP Laboratory Accreditation Program. The director has the option at the time of application to request that the results of the inspection be shared with the JCAHO or with selected governmental agencies. All inspection data, however, are confidential unless released by the director. The choice is voluntary. The regulatory and accrediting agencies that may receive copies of the inspection are listed in the following section. College of American Pathologists Laboratory Accreditation Manual Page 58 Laboratory Information Joint Commission on Accreditation of Healthcare Organizations (JCAHO) Hospitals seeking JCAHO accreditation may choose to accredit the hospital laboratory through the CAP program. The JCAHO accepts CAP accreditation of hospital laboratories. Generally, CAP accredited laboratories in JCAHO accredited hospitals will not be surveyed by a JCAHO laboratory surveyor. During the hospital's survey, however, a physician surveyor will request and review information on such intradepartmental requirements as safety and monitoring and evaluation of the quality and appropriateness of patient care. The JCAHO will validate the CAP inspection process by occasionally sending observers along with CAP inspection teams. Health Care Financing Administration (HCFA) The LAP was granted deeming authority as a private accrediting organization under CLIA '88 by the Health Care Financing Administration (HCFA). This recognition imposes significant obligations upon the LAP. The fixed accreditation cycle must be adhered to and Checklist changes have resulted. Within each facility, CLIA certificates and CAP accreditation data must be concordant, (i.e., one CLIA number corresponds to one CAP number). HCFA validates the CAP inspection process by sending surveyors to a certain percentage of laboratories, unannounced, within 60 days of completion of CAP inspections. State Licensure States also license clinical laboratories. The extent to which the CAP accreditation program is recognized by state governments varies. The College will make the results of the accreditation decision available to a state department of health upon request from the laboratory director. The inspector can determine the accreditation implications of the current inspection by reviewing the "Release of Data" form in the packet. The director's signature on the form will indicate which agencies the laboratory has designated to receive CAP accreditation information. College of American Pathologists Laboratory Accreditation Manual Page 59 Laboratory Information NON-ROUTINE INSPECTIONS Change in Location, Director, or Ownership Accreditation by the CAP does not automatically continue after there is a change in location, director, or ownership. When there is such a change, the CAP must be notified in writing within 30 days in order to satisfy CLIA ’88 requirements. Additional information may be requested from the laboratory. After reviewing the case, the Regional Commissioner may find that no substantive changes in the operation of the laboratory have been made and that all the requirements of the Standards for Laboratory Accreditation are met. In these circumstances, the Commissioner may waive reinspection and shall notify the College in writing of his or her recommendation. The laboratory will retain its accreditation until the next regularly scheduled inspection. An additional inspection, however, may be conducted at the discretion of the Regional Commissioner. A fee is assessed for this type of inspection. A letter explaining the process and request for the inspection fee will be sent to the laboratory director. An Inspector’s Summation Report and the appropriate Checklists are used. The laboratory is required to respond in the usual manner, as for any inspection, to any deficiencies found during this out-of-cycle inspection. The inspection response material will be reviewed by the technical specialist or regulatory analyst and the Regional Commissioner. Added Discipline An “added discipline inspection” occurs outside of the regular inspection cycle and is used for labs that add anatomic pathology and/or cytology testing. The addition of any other discipline may also require an inspection, at the discretion of the Regional Commissioner. A fee is always assessed for this type of inspection. If the laboratory adds a clinical pathology discipline, (e.g., toxicology, cytogenetics, etc.) additional application materials, a self-evaluation verification form, and a copy of the Checklist for that discipline will be sent. When returned, these materials will be forwarded to the Regional Commissioner for review. After reviewing these materials, the Regional Commissioner will determine if this laboratory section requires an inspection before its next scheduled on-site inspection. If the laboratory requires an inspection for the new discipline, a fee is charged for this service. A letter explaining the process and the name of the technical specialist, who will review the responses, will be sent to the laboratory director. An Inspector’s Summation Report and Checklist will be used. After response and review by the technical staff and Regional Commissioner, the discipline will be added and a new accreditation letter will be sent to the laboratory. However, if the section does not require inspection, an accreditation letter will automatically be sent after the Regional Commissioner’s review. In this case, no additional fee involved. College of American Pathologists Page 60 Laboratory Accreditation Manual Laboratory Information Secondary On-Site Inspection This inspection occurs within the regular inspection cycle and is conducted after an on-site inspection. The Regional Commissioner requests a second visit by a specialized team of inspectors to document correction of selected deficiencies in a specific discipline. This occurs usually because the deficiencies cited were so profound that paper documentation of corrections were deemed inadequate by the Regional Commissioner. A fee is always assessed unless the reason for the inspection is due to an error on the part of the CAP (e.g., inspector missed the section, or the appropriate Checklist was not supplied to the inspector). A letter explaining the process and requesting the fee will be sent to the laboratory director. The name of the technical specialist will be included in the letter for the deficiency response. An ISR and the appropriate Checklists are used. The inspection response material is reviewed by the technical specialist or regulatory analyst, and the Regional Commissioner before recommendations for accreditation or denial are made. Complaint Investigation This inspection usually follows the same process as a secondary on-site inspection and can take place at any time during the accreditation cycle. The Special Commissioner for Complaint Investigations will request this inspection when there is evidence of non-compliance with the Standards of Laboratory Accreditation in a currently accredited laboratory. The response material is reviewed by the regulatory analyst for complaint investigations and the Regional Commissioner. Fee assessment is on a case-by-case basis. Alternatively, complaint investigations may be conducted as part of a routine on-site inspection if the timing is appropriate. College of American Pathologists Page 61 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Appendix A: CAP Checklist Usage Laboratory General - Must be completed for all inspections and for each separate laboratory in the case of multiple-lab inspections. Hematology and Coagulation - Used for blood and body fluid cell counts and differentials, coagulation tests, bone marrow, and hemoglobin electrophoresis. Automated/General Chemistry - Used for common chemistry tests typically performed on automated instruments, including blood gas and oximetry. Urinalysis and Clinical Microscopy - Used for automated and semi-automated urinalysis, dipsticks and dipstick readers, morphology systems, microscopic urinalysis, crystal and microscopic body fluid analysis, and semen analysis. Toxicology - Must be used for all screening and/or confirmatory testing for drugs of abuse and legal alcohols, regardless of methodology. This includes kits such as the Biosite Triage™. NOTE: Therapeutic drug monitoring (TDM) is covered by the Special Chemistry Checklist. Special Chemistry - Used for flame photometers, atomic absorption, spectrophotometers, immunoassays (including enzyme immunoassays (EIA) and radioimmunoassays (RIA)), electrophoresis, therapeutic drug monitoring (TDM), prenatal screening, alpha-fetoprotein (AFP), cystic fibrosis screening and NON-toxicological chromatography. Microbiology - Used for bacteriology, mycobacteriology, mycology, parasitology, and virology, including DNA probes for identification purposes. NOTE: Any DNA amplification testing such as PCR or LCR is inspected with the Molecular Pathology Checklist. Transfusion Medicine - Used for blood and tissue storage, compatibility testing, transfusions, donor collection, component preparation, and parentage testing. NOTE: Laboratories limiting their immunohematology testing to ABO, Rh, and antibody screening are inspected with the Diagnostic Immunology Checklist. Immunology & Syphilis Serology - Used for serology techniques, fluorescent stains, and direct antigen detection. Anatomic Pathology - Used for all surgical pathology, including frozen sections, histology/histopathology, autopsies, and electron microscopy. Cytopathology - Used for all cytopathology, cell suspensions, screening, and pathologist evaluation. College of American Pathologists Page 62 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Cytogenetics - Used for amniotic fluid cell analyses, bone marrow cultures, chorionic villus studies, Fragile X studies, blood lymphocyte analyses, solid tumors, and non-neoplastic tissue cultures. NOTE: Biochemical genetics (e.g., amino acids) is covered by the Special Chemistry Checklist. Histocompatibility - Used for all transplant tissue compatibility (HLA) studies, including type/crossmatch and antibody identification. NOTE: If flow cytometry is used for crossmatching, the Flow Cytometry Checklist must also be used. If molecular techniques are used for typing, the Molecular Pathology Checklist must also be used. Flow Cytometry - Used to evaluate flow cytometry assays. Testing covered includes: DNA analysis, lymphocyte phenotyping, leukemia/ lymphoma immunophenotyping, and flow cytometry crossmatching for HLA. Molecular Pathology - Used for molecular techniques for oncology, genetics, HLA/ histocompatibility, parentage, forensic identity, in situ testing, and infectious disease testing using nucleic amplification such as PCR and LCR. Limited Service Laboratory - Used for multi-discipline laboratories doing a limited number of common tests (e.g., outpatient or “STAT” labs). This Checklist is not appropriate for singlediscipline or specialized laboratories; these labs should use instead the appropriate discipline Checklist(s). NOTE: The following services are NOT covered by the Limited Service Checklist for the following disciplines: Hematology – bone marrow evaluation Coagulation - factor assays Urinalysis and Clinical Microscopy - semen analysis beyond sperm count Special Chemistry - spectrophotometry, electrophoresis, chromatography, AFP, RIA Microbiology - cultures beyond initial plating, mycology other than KOH or wet preps, mycobacteriology, parasitology other than pinworm preparations, all virology Transfusion Medicine - ALL other than ABO/Rh and antibody screening Separate discipline specific Checklists are needed for: Toxicology (including drugs of abuse screening), Anatomic Pathology, Cytopathology, Cytogenetics, Histocompatibility, Flow Cytometry, Molecular Pathology, and Point-of-Care Testing. Items in these discipline specific Checklists are not covered in the Limited Service Checklist. Blood Gas Laboratory - The Blood Gas Checklist is used for stand-alone blood gas laboratories that are under a different director, supervisor, location and/or CLIA number. If blood gases are performed in the laboratory under the same CLIA number as the main laboratory, with the same laboratory director and supervisor, they may be inspected with the Automated Chemistry Checklist. If blood gases were performed in a different laboratory section with a different Supervisor, they would be inspected with the Blood Gas Checklist. College of American Pathologists Page 63 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Point of Care Testing - Used for all point of care testing (POCT) done in non-dedicated space (i.e., with portable instrumentation). NOTE: Dedicated laboratories require either a Limited Service or additional discipline Checklist. A separate Checklist must be completed for each POCT location when POCT records are not maintained in a central location. College of American Pathologists Page 64 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Appendix B: Guidelines for Determining Test Volume Chemistry profiles: each measured individual test is counted separately. Complete blood counts (CBCs): each measured individual analyte ordered and reported is counted separately. WBC differentials count as one test. Do not count calculations (e.g., A/G ratio, MCH, MCHC, and T7), quality control, quality assurance and proficiency testing assays. Urinalysis: macroscopics (dipsticks) are counted as one test for each reagent pad on the strip; microscopic examinations, each count as one test. Microbiology: susceptibility testing is counted as one test per group of antibiotics used to determine sensitivity for one organism. Cultures are counted as one per specimen regardless of the extent of identification, number of organisms isolated, and number of tests/procedures required for identification. Testing for allergens should be counted as one test per individual allergen. Cytology: each slide (not case) is counted as one test for both Pap smears and nongynecologic cytology. Histopathology: each block (not slide) is counted as one test. Autopsy services are not included. For those laboratories that perform special stains on histology slides, the test volume is determined by adding the number of special stains performed on slides to the total number of specimen blocks prepared by the laboratory. Histocompatibility: each HLA typing (including disease associated antigens), HLA antibody screen, and HLA crossmatch is counted as one test. Cytogenetics: the number of tests is determined by the number of specimen types processed on each patient, (i.e., a bone marrow and a venous blood specimen received on one patient is counted as two tests). College of American Pathologists Page 65 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Appendix C: Quality Improvement An Accreditation Viewpoint Analytic results that are useful in the diagnosis, management, and treatment of disease are achieved by organizing people, instruments, methodologies, and reagents into a semiautonomous system characterized by procedures and protocols. This system identifies sources of intralaboratory excellence and includes personnel training, performance standards, maintenance of equipment and consumables, calibration, quality control, proficiency testing, and documentation. One component of quality improvement is the attempt to identify all sources of preanalytic, analytic, and postanalytic variation that may have an impact upon the provision of high-quality patient care. This definition includes patient preparation, specimen procurement and handling, test and method selection, reporting formats, and turnaround time as well as the classical analytic safeguard customarily referred to as quality or process control. A second and more subtle aspect of quality improvement attempts to integrate the analytic and interpretive product of the laboratory with the overall clinical care of the patient and the ultimate clinical "outcome," realizing that the laboratory result is only a partial "outcome" in the overall course of patient care. A universally applicable distinction between quality control and quality improvement does not exist. Conventionally, quality control (QC) has come to be seen as a component of quality improvement (QI). QC and QI represent adjacent and, at times, overlapping domains and dimensions of the quest for the benchmarks of excellence in laboratory medicine: the provision of useful and correct information in a timely, convenient, and cost-effective manner. In pursuit of these goals, QC and QI may be contrasted. QC is concerned with process, procedures, means, and data, while QI is concerned with outcomes, results, ends, and information content. QI has always been an implicit component of the LAP process. The emphasis of the program, however, has been on structure and process "indicators" such as equipment, personnel qualifications, procedure manuals, quality control protocols, and proficiency testing. The LAP will increasingly attempt to identify "outcome" related issues. As of 1999, Laboratory General Checklist contains an expansion of previous material on QI, and there are now 13 questions: 1. Does the quality improvement (QI) program follow a documented operational plan? 2. Has the QI plan been implemented as designed? College of American Pathologists Page 66 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation 3. Does the QI program cover all aspects of the laboratory service? 4. Are key indicators of quality monitored and evaluated for improvement opportunities? 5. Are appropriate actions taken whenever opportunities for improvement are identified? 6. Do the QI indicators include measures of preanalytic variables? 7. Do the QI indicators include measures of postanalytic variables? 8. Are graphical tools (charts and graphs) used to effectively communicate quality findings? 9. Is there a systematic program to identify and correct problems that may interfere with patient care services? 10. Is a physician responsible for ensuring that the QI program is coordinated with others in the facility (medical, surgical, nursing services, etc.)? 11. Have the referring physicians' and patients' satisfaction with the laboratory service been measured within the past 2 years? 12. Is the QI program appraised at least annually for effectiveness? 13. Is there evidence that objective measures of the laboratory's quality have shown improvement in the preceding 2 years? The Q-PROBES and Q-TRACKS programs of the CAP may be used as important components of the laboratory’s QI program. Q-PROBES is a subscription program offering periodic "off-the-shelf" studies of outcome, process, and structure-oriented quality components of laboratory practice in the clinical laboratory and anatomic pathology. The program allows a laboratory to compare its performance with that of a peer group of laboratories. The Q-PROBE may be integrated into the institutional QI programs as a means to satisfy accreditation requirements of the College as well as the JCAHO. Q-TRACKS extends the boundaries of communication and quality improvement directly impacting patient care. Through a series of long-term monitors, Q-TRACKS examines the complete testing cycle, from physician order to diagnosis and treatment. Carefully selected and properly implemented QI programs will help to guarantee the continuing outstanding performance and dedication to excellence of clinical laboratories accredited by the CAP. College of American Pathologists Page 67 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Appendix D: Sample of Inspection Confirmation Letter to Laboratory Director This letter should be sent to Directors of all labs to be inspected during this inspection (e.g., separately accredited blood gas or special function labs). (A copy of the letter should be filed in the inspection packet.) Dear Doctor (...): This is to confirm our telephone conversation in which we arranged an inspection of your laboratory. I plan to arrive at your laboratory on (...) at about (...) and I anticipate that my inspection will last approximately (...). Assisting me in this inspection will be the following individuals and the areas they will inspect: (Insert as applicable e.g., Lab General (Name) Hematology: (Name) Chemistry: (Name), etc.) We would like to meet with you and your staff briefly at the beginning of the visit to review the general operation of the laboratory and to take a walking tour with the inspection team. Team members will then go back through each department to meet the respective supervisors and to inspect the departments one by one. If possible, please provide a work space in an office or conference room. (Insert for hospital laboratories) Please arrange for brief appointments of 15 minutes each with the hospital administrator and a representative of the medical staff. These meetings help determine whether the laboratory has established an effective working relationship with the administration and staff. Ideally, the time of these meetings would be about halfway through the inspection. The inspection will proceed more efficiently if the laboratory has those items of special interest readily available. As we go through the Checklists, we will review the following: 1. Laboratory general a. Organizational plan b. Personnel policies c. Quality Improvement plan and records d. Continuing education records e. Self-inspection records from last year f. A copy of those portions of the hospital nursing manual or doctor office directions that relate to specimen collection and to transfusion of blood 2. Each department a. Procedure manuals b. Instrument maintenance records c. Quality control and proficiency testing records College of American Pathologists Page 68 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation 3. 4. 5. 6. 7. d. Safety manual e. Examples of report forms Hematology Example slides of Romanowsky, reticulocyte stains, etc. Microbiology Example slides of Gram stain and other stains Chemistry Reference thermometers, reference weight standards, and volumetric glassware Anatomic Pathology Example slides of all routine and special stains offered Cytopathology Example slides, workload records, and rescreening documentation should be available. We want to complete the inspection by (...) at which time we would like to meet with you and your staff again for the summation conference. Please invite as many personnel from the laboratory to this meeting as you deem appropriate. We plan to adjourn by (...). If you have any suggestions for luncheon arrangements, lodging, travel directions, etc., please let me know. (Include as appropriate.) Sincerely, _______________________________________ College of American Pathologists Page 69 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Appendix E: Resources LAP Checklists See appropriate sections of the Laboratory Accreditation Manual that pertain to these items. The inspection checklists are available on the CAP Web page at www.cap.org. This location provides the opportunity to view and/or download the checklists currently in use as well as proposed editions approved by the CAP for future implementation. If you do not have access to the Web site, please call the Laboratory Accreditation Program at 800-323-4040, extension 6055 or 847-832-7000, extension 6055 to obtain a copy of the checklists. LAP Inspection Education Seminars and Self-Study Modules Live education seminars begin with a review of the accreditation process, then delve into practical material regarding the inspection itself. Included are interactive discipline specific break-out groups that address unique inspection needs of the individual laboratory sections. CME and CLME credit is given hour for hour for seminar attendance. For information regarding seminars near you, call the CAP inspector training coordinator at 800-323-4040, ext. 7207 or 847-832-7207. The Self-Study modules cover the same material as the live seminars and offer the same CME and CLME credit opportunities. The Basic Self-Study is available on the CAP’s Website: (www.cap.org) or you may obtain a hard copy of the Basic Self-Study or selected discipline specific modules of the Advanced Self-Study by mail from the inspector training coordinator, at 800-323-4040, ext. 7207 or 847-832-7207. CAP Surveys Program The CAP Surveys program started in the 1940s with distribution of a limited number of specimens to a few selected laboratories. Since then, it has been greatly expanded, refined, and updated annually to meet the ever-expanding needs of laboratory medicine. More than 23,000 laboratories are enrolled in the CAP Surveys Program. To assist laboratories in selecting CAP Surveys appropriate for their operations, the current CAP Surveys brochure presents the Surveys available according to laboratory sections as defined by the College's Laboratory Accreditation Program. Included in this brochure are: Index by analytes/procedures Descriptions of individual Surveys Reference Materials Guidelines for selection of Surveys How to complete the Survey order form Inquiries concerning CAP Surveys College of American Pathologists Page 70 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Proficiency Testing Proficiency testing is an integral part of the College’s Laboratory Accreditation Program (LAP) along with the on-site inspection and self-evaluation. To be accredited by the LAP, a laboratory must participate in a CAP-approved program appropriate in size and scope of the lab whenever such programs are available. Lists of approved programs are included in application and inspection packets and are also available by calling the proficiency testing specialist at (800) 3234040 extension 7580 or 847-832-7580. The EXCEL® Program The External Comparative Evaluation for Laboratories (EXCEL) program is designed specifically for use by physicians' office laboratories or other laboratories performing only limited and routine procedures. This program helps monitor the laboratory's internal quality control program by providing information on its performance and by providing comparison of the procedures with other laboratories using the same or similar methods. The flexible format allows subscribers to select EXCEL modules in chemistry, hematology, coagulation, urinalysis, microbiology, blood bank, and immunology. Specimens have been designed specifically for the scope of testing performed in office laboratories. Laboratory Accreditation Newsletter This newsletter, published several times each year by the College's Commission on Laboratory Accreditation, is distributed to LAP participants and inspectors to inform them of program changes and developments. It is incorporated into CAP TODAY and distributed to all CAP members. Clinical Laboratory Handbooks for Patient Preparation and Specimen Handling This series of handbooks provides a comprehensive reference source for patient preparation and specimen handling of all standard medical procedures, plus commentary on the optimal use of each test. Topics include special patient preparation, type of specimen preferred, preferred containers, preferred containers, preservatives, and anticoagulants, storage requirements, clinical use, and special comments. Tests are cross-referenced. Fascicle I: Diagnostic Immunology/Serology [CAP Pub. No. BC331] Fascicle II: Hematology [CAP Pub. No. BC344] Fascicle III: Microbiology [CAP Pub. No. BC351] Fascicle IV: Therapeutic Drug Monitoring/Toxicology [CAP Pub. No. BC374] Fascicle V: Endocrinology/Metabolism [CAP Pub. No. BC359] Fascicle VI: Chemistry/Clinical Microscopy [CAP Pub. No. BC361] Fascicle VII: Reference Guide for Diagnostic Molecular Pathology/Flow Cytometry [CAP Pub. No. BC365] College of American Pathologists Page 71 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Complete set [CAP Pub. No. BC373] Quality Improvement Manual in Anatomic Pathology [CAP Pub. No. BC3603] This publication contains a current compilation of ways pathologists can improve quality in various areas of anatomic pathology. It also provides guidelines for implementing quality improvement to surgical pathology practice in complying with guidelines of the CAP, JCAHO, and regulatory agencies. The 1996 manual was updated to address practice questions, particularly those with quality implications raised by pathologists since the 1988 edition. It features an extensively revised chapter on cytopathology. It contains many examples of forms for documenting quality assurance data. Autopsy Performance and Reporting [CAP Pub. No. BC205] The major sections of this book, written for pathologists performing autopsies on a regular basis, cover Administration and Preautopsy Considerations; Autopsy Performance; Autopsy Reporting; and Autopsy Utilization, Quality Assurance, and Reimbursement. Forensic Urine Drug Testing Accreditation Program [CAP Pub. No. BC210] The College of American Pathologists, in consultation with the American Association for Clinical Chemistry, developed an accreditation program designed specifically for laboratories engaged in urine drugs-of-abuse testing for nonmedical purposes. The Forensic Urine Drug Testing (FUDT) Accreditation Program is administered separately. Laboratories must enroll in and successfully complete three consecutive approved forensic urine drug testing proficiency testing surveys before receiving an invitation into the program. On-site inspections occur annually. Laboratories also are expected to perform an interim self-evaluation each year and to participate successfully in the AACC/CAP Forensic Urine Drug Testing Survey (UDC), or CAP approved equivalent, on an ongoing basis. Further information regarding the FUDT Accreditation Program may be obtained from the following sources: Standards for Accreditation of Forensic Urine Drug Testing Labs Forensic Urine Drug Testing Checklist Information regarding enrollment policies and fees may be obtained by contacting the College. Athletic Drug Testing Accreditation Program [CAP Pub. No. BC232] The CAP designed the Athletic Drug Testing (ADT) program for laboratories that perform tests on samples from collegiate and professional athletes. Steroids and other performance-enhancing drugs, beta-blockers, and stimulants, as well as drugs of abuse are screened for and confirmed Information regarding enrollment policies and fees may be obtained by contacting the College. College of American Pathologists Page 72 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Reproductive Laboratory Accreditation Program [CAP Pub. No. BC233] The College of American Pathologists and the American Society for Reproductive Medicine (ASRM), have collaborated to develop a national laboratory accreditation program for reproductive laboratories. This unique cooperative effort provides an opportunity for laboratory improvement through voluntary participation, professional peer review, education, and compliance with established performance standards. Laboratories performing embryology testing, and andrology laboratories that are performing 2,000 procedures per year with at least one high complexity test, not including semen analysis, but related to sperm processing, are eligible for the accreditation program. Inspections occur biannually, and laboratories are also expected to perform an interim selfevaluation each year. Further information regarding the Reproductive Laboratory Accreditation Program (RLAP) may be obtained from the following sources: Reproductive Laboratory Accreditation Program Standards for Accreditation Accreditation Checklist Standards and Checklist Questions Information regarding enrollment policies and fees may be obtained by contacting the College. Laboratory Instrument Evaluation, Verification, and Maintenance Manual, 1989 [CAP Pub. No. B236] This manual, currently under revision, provides basic information on instrument selection, operation, verification, and maintenance. It is also useful for preparing to meet accreditation standards for the CAP and Joint Commission on Accreditation of Healthcare Organizations (JCAHO). College of American Pathologists Page 73 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Appendix F: Site Coordinator’s Manual COLLEGE OF AMERICAN PATHOLOGISTS LABORATORY ACCREDITATION PROGRAM SITE COORDINATORS MANUAL INTRODUCTION CAP inspections at a large facility are complex. Team leaders have found that to have one local contact person with knowledge of all the laboratories is helpful. Many concerns must be addressed and decisions made before to the inspection. Careful planning and attention to details on site will make an inspection go smoothly. Considerations include the following: How will the team get from its hotel to the lab on time and ready to inspect? Do we know who the team members are and what sections each individual will inspect? Are there other laboratories on the same campus that the team will be reviewing on this trip, and how will those inspections be scheduled? Does the laboratory have satellite labs at other locations? How will the appropriate team members get there and return? Are there any special services the team will need that the lab can supply to make the experience easier and more efficient? Such questions cannot be addressed by the CAP Northfield office, or its travel agency, or perhaps not even by the team leadership. A local laboratory coordinator can be of immeasurable help in anticipating such issues and preventing complications or delays. This manual was developed for the Site Coordinator. No document of this type can anticipate every organizational arrangement. CAP teams are often assigned to clusters of laboratories in one location to minimize the travel costs of the program. Many small laboratories may be spread throughout the campus and some of them may reside in departments other than pathology. The central laboratory may support multiple satellite laboratories; any that are within 15 miles or 30 minutes driving distance will be assigned to the team. Sometimes entire groups of partnering hospitals may be inspected at the same time. The document is meant to be a guideline - a set of suggestions that the Site Coordinator can adapt to her or his local situation. College of American Pathologists Page 74 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation The Commission on Laboratory Accreditation would like to gratefully acknowledge the following individuals who have assisted in the production of this manual by providing resource information and participating in review of draft copies: Beverly Charlton, University of Pittsburgh, Pittsburgh, Pennsylvania Terry Jo Gile, Barnes-Jewish Hospital, St. Louis, Missouri Dottie Quinn, Kaiser-Permanente Laboratories, Portland, Oregon Joyce Wilson, University of Alabama, Birmingham, Alabama Their expertise and experience have made this manual possible. College of American Pathologists Page 75 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation WHAT IS A SITE COORDINATOR (SCO)? The site coordinator is the individual whom the director has appointed to work directly with the counterpart on the inspection team. Site Coordinator’s duties typically include scheduling meeting rooms, arranging key interviews and assisting the team with arranging for any special needs. WHAT IS THE ROLE OF THE SITE COORDINATOR? The role of Site Coordinator is not standardized. The tasks will be dictated by the campus arrangement and the team preferences. The best way to list the duties of a SCO is to answer the question, “If I were organizing the team that will inspect our laboratories, what arrangements would I need?” The SCO should be available to the team throughout the inspection. Even the best planned inspections may need last minute arrangements. Flexibility is essential, especially on big, multidisciplinary campuses. The SCO helps resolve unpredicted situations as they arise. Experience has shown that the only role the SCO should have during the inspection is to be present and available to answer the team’s questions. HOW IS A SITE COORDINATOR IS APPOINTED? Each laboratory’s reapplication packet is mailed 150 days before the laboratory's accreditation anniversary date. There is no requirement to have a SCO, but if the decision is made to do so, the SCO should be appointed as soon as the reapplication arrives, so that the person can begin planning the process. Usually the director of the central pathology laboratory appoints the SCO whether the complex of laboratories is administratively related, or laboratories are located in other departments. It is not the College’s intention to have the pathology department dominate the inspection but it is hoped that the entire inspection will proceed more successfully for everyone with one person in charge of coordination. Pathologists have reported that, by facilitating the inspection, they have enhanced their reputation for leadership on the campus. College of American Pathologists Page 76 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation WHEN DO THE SITE COORDINATOR’S RESPONSIBILITIES BEGIN? The SCO should begin work before the applications/reapplications are sent to the CAP Central Office, so that he/she knows the content of the paperwork. The first step is to draw up a list of all laboratories that will be included in the inspection. Questions regarding inspector assignment can be answered by the calling the Operations Associate at the Northfield office at (800) 3234040 extension 6055 or 847-832-7000, extension 6055. The SCO should realize that CAP’s list is only as accurate as the information available at the time that the call was placed. Applications from special function, satellite, and affiliated labs may be accepted up to 45 days before the main clinical laboratory’s accreditation anniversary date (or even later with the approval of the Regional Commissioner and team leader). Once the list is compiled, the SCO may identify acceptable dates for the inspection by contacting the directors of the other laboratories to determine their preferences. The inspection must occur in the 30 days before the accreditation anniversary date of the main laboratory. Offering more inspection date choices increases the likelihood that a mutually acceptable date will be selected. Potential conflicts such as vacation schedules, remodeling, and computer installations may be taken into consideration, but none of these can delay an inspection. The final selection of an inspection date will be at the convenience of the inspector. The Laboratory Accreditation Program (LAP) operates under the policy that a laboratory that is sending out results is always ready for an inspection. REPORTING RELATIONSHIPS Soon after appointment, the SCO should clarify her or his responsibilities to the facility for this inspection. Duties will vary by location, the number of labs, and their interrelationships. The chairman of the department of pathology should empower the SCO to handle as many of the details of the inspection as possible. Local arrangements can involve many telephone calls and some negotiation. There may be the need to make quick decisions during the inspection. COMMUNICATION Good communication is key to inspection planning. To be effective, the SCO should be knowledgeable about the team, the facility, and the schedule. Correspondence from the CAP office and the team leader will be addressed to the laboratory directors. The SCO should obtain copies of all pertinent correspondence. Any letters that the SCO sends to the CAP Northfield office or the inspection team should be copied to the appropriate laboratory directors. The SCO will need the names of each of the team members as well as their credentials and areas of expertise. The managers and supervisors want to know exactly who will be in their laboratories. In addition, the team members want to know which employees will be working with them during the inspection. The inspection packet includes personnel qualifications of the senior individuals in the lab, but often other laboratory personnel work directly with the inspectors. College of American Pathologists Page 77 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation The SCO should find out who will host the inspector in each special function laboratory. This person might even be “deputized” by the SCO as “special function laboratory coordinator”. This is not a formal title but rather a designation to facilitate point to point communication. The inspection team member can be escorted to the special function lab by this deputy coordinator and returned to the inspection team’s staging area. How these handoffs are managed can be coordinated between the SCO and this individual. LOGISTICS OF SATELLITE LABORATORY INSPECTIONS Satellite laboratories are off-site facilities that are administrative extensions of the main lab. Logistics of inspecting these laboratories include transportation for the team to and from the satellite lab, and the time allocated for this travel. There is no LAP requirement for the host laboratory to provide local ground transportation, but it is far simpler for the inspection team when the laboratory chooses to do so. In all cases, the inspection team needs to know in advance how it will get to and from each of the locations included in the inspection. When a pathology laboratory supports multiple satellites, centralization of records and standardization of procedures is common. The SCO should describe the arrangement to the team well before the inspection. If records are kept in a central location, copies of these records should be available to the inspection team at the satellite lab on inspection day. Records to be reviewed include personnel files, employee health records, proficiency test evaluation reports, and biomedical equipment maintenance records. HELPING WITH TRAVEL ARRANGEMENTS For the inspection team: The CAP central office can help the inspection team meet its travel needs. The travel agency at the College is Direct Travel at (800) 323-4040, extension 7800 or 847-832-7000, extension 7800. Airline tickets can be billed directly to the College. The 7-digit CAP number of the laboratory to be inspected must be given to the agent when booking travel. The College encourages early booking to be eligible for favorable rates. If a team member needs to change his/her ticketing for the return trip, Direct Travel should be contacted as soon as possible. The CAP can also facilitate hotel accommodations. The “CAP Large Inspection Team Hotel Accommodation Request Form” may be used for teams of ten or more. With 4-6 weeks notice, the meeting planning department at the College can negotiate a master account to cover the room rates and tax. College of American Pathologists Page 78 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation For the Site Coordinator: The SCO should suggest a list of nearby hotels. Team member costs for meals, ground transportation, and covered incidentals are reimbursed according to the standard CAP meeting policy. The SCO should advise the team on the best way to get from the airport to the hotel. Most “chain” hotels offer free shuttles or can recommend low cost shuttle service. The SCO should suggest transportation arrangements for the team between the hotel and the lab. There is, of course, no requirement that the laboratory provide busing, but any help the laboratory can offer the team will simplify the process and minimize its logistic decisions. With advance notice, the CAP Northfield office can help arrange direct-billed ground transportation. MEETINGS AND MEETING ROOMS Every inspection team needs a home base. The SCO should ensure that the team has a work area for their use. Team members inspecting large campuses will fan out towards their individual assignments. The home base is a place to which they can return, and where they can interact with other team members. There should be a spot in or near this team work area where the inspection team members can secure personal items such as coats, purses, laptops, and luggage. If practical, the home base should be near the location of the other meetings. Anyone can become disorientated in large, unfamiliar surroundings. A home base minimizes this affect. The SCO should provide the inspectors with a phone number to call if they become lost on campus or need to contact the team leader with a question. The SCO may consider using a beeper for this purpose. Introductions should be the first item of the day. The first meeting of the day is a chance for the hosting laboratory director to make welcoming remarks and for the inspector to introduce her/his team. Team members will pair up with the appropriate employees of their initial inspection assignments. The room for this initial meeting should be large enough to hold all of the principals and be in close proximity to the laboratory. Many times, a general tour of the laboratory follows the introductory meeting. Arrange a formal general tour only for the individual(s) responsible for the Laboratory General Checklist. Those team members who want to see the whole facility may do so by informal arrangement later in the day (time permitting). PRIVATE MEETINGS The inspection team leader is expected to meet with the Hospital Administrator (or representative) and with the Chief of Staff (or representative). These are brief interviews of about 15 minutes each. The SCO should schedule these appointments for the team leader and provide a schedule for this ahead of time. The best time to hold these meetings is usually near the midpoint of the inspection, after the inspector has started to acquire an impression of the laboratory. College of American Pathologists Page 79 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation THE SUMMATION CONFERENCE The Summation Conferences take place at the end of the day. The team will meet 30-60 minutes beforehand in private, for a team pre-summation meeting, to compare notes and prepare for the Summation Conference. This preliminary conference might be held in the team’s work area. The Summation Conference is usually held in a large classroom or auditorium. Many people will probably want to attend, and the team welcomes the participation of all interested parties. The Summation Conference typically will take 30-60 minutes but because the exact starting time may be unpredictable, the room should be reserved for as large a block of time as possible. Large inspections usually involve multiple laboratories. If for example, 10 laboratories are inspected by the team; covering the deficiencies in all of the labs at one big Summation Conference may be cumbersome. If the labs span more than one department or employer, a single-large group summation conference may not be appropriate. Before the inspection, the SCO should ask each satellite laboratory director if she or he would prefer to have a separate Summation Conference. Discuss these preferences with the inspector. One solution, that can work well, is to hold individual summation conferences “on the fly” (i.e., a private summation conference is held as the inspection of each small laboratory is completed). A group summation conference may still be organized to allow the discussion of common themes and to allow laboratorians to ask the questions, to clarify citations, and to challenge deficiency findings. The inspector for each must sign each individual Checklist page of the ISR for the sections he/she inspected. The team leader and laboratory director must sign the cover page of the report. A copy of part B must be left with the director of each laboratory. Remember to copy both sides of the ISR. Part B of the ISR is the official record of the inspection and laboratory's primary source of information for the deficiencies that need to be addressed. The laboratory director is required to respond to the deficiencies written on Part B of the ISR within 30 days of the inspection. No other report will be sent from the CAP. The laboratory is encouraged to download the checklists, explanatory text, and references from the CAP web page at www@cap.org. By using a computer word processing program, the exact wording of each checklist item can be retrieved from the download along with notes and literature references. The inspector must return the completed ISR, CME, Team Member, and Reimbursement forms in the prepaid mailer as soon as possible after the inspection. A United Parcel Service Authorized Return Service envelope for prepaid return is included in the inspection packet for this purpose. If paperwork is completed before the team is ready to leave, the SCO might offer to arrange for shipping of the sealed envelopes. The Checklists and other application materials are not returned after the inspection. The inspector may discard them. College of American Pathologists Page 80 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation MEALS FOR TEAM MEMBERS There is neither requirement nor expectation that the laboratory provide food and beverages for the inspection team. Most laboratories do provide modest fare. Elegant presentations are inappropriate, and sit-down banquets waste valuable time. The luncheon plans that the laboratory chooses to make for the team’s comfort should be communicated to the team ahead of time. Meals such as breakfast and dinner, are outside of the hours of the inspection, and should be handled by the team itself. (The SCO might provide a list of suggested restaurants.) The team would appreciate access to coffee or soft drinks at or near its home base in the laboratory. The most efficient lunches are cold buffet or box lunches. Team members will want to break away for lunch at a convenient point, which may vary with assignment. The luncheon room should be reserved for an extended period to allow individual team members to manage their time most effectively. Team members who are working off-site at a satellite locations should be offered similar hospitality or a list of nearby restaurants. SUPPLIES AND SERVICES The inspection team will need some supplies and services while on site. In order to help the inspection proceed more smoothly, work out with the inspection team, the mechanism for obtaining the following items before the inspection: 1. Photocopies The ISR Part B must be copied for the laboratory before the team leaves. Sometimes team members may ask for copies of procedures, worksheets, or reports. The SCO should inform the laboratory supervisors concerning the local “ground rules” for photocopying. The hospitality of even the most generous laboratory can be strained by excessive requests. It is quite appropriate to ask the inspection team leader to keep photocopying requests modest. 2. Telephone calls The Laboratory Accreditation Program office can be called during regular business hours, Monday through Friday 8:30 a.m. to 5:00 p.m. Central time, during the inspection via the College’s toll-free number (800)323-4040 (option 2 for LAP, then 2 for checklist question interpretation or 3 for inspections) or 847-832-7000, extension 6065. College of American Pathologists Page 81 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation 3. Personal protective equipment (PPE) The SCO should arrange for PPE, if possible, or request the team to bring any items. In most cases, the only PPE needed will be lab coats and gloves, but arrangements should be made for additional items as needed. For example, an inspector visiting an autopsy suite during a postmortem examination should be protected from splashes or spatters of biohazardous fluids with appropriate gown, gloves, shoe covers, and facial protection.) College of American Pathologists Page 82 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation SITE COORDINATOR’S CHECKLIST Preliminary tasks Determine functions the lab director has designated for the site coordinator. Request copies of correspondence from the inspection team for all areas. Make sure documentation of correction of deficiencies is complete * From the last on-site inspection. * From the self inspection. Call the LAP Northfield office for list of all laboratories to be included in the inspection. Contact the director of each special function laboratory on the campus. Offer to coordinate the inspection. List any special requests of the inspection team. Individual Summation Conference Preference Make a preliminary list of recommended dates for the inspection (must be within the 30 days before the anniversary date). Telephone call to Inspector Introduce yourself and describe your role as Site Coordinator. Determine who will coordinate the schedule for the team. (Will the Inspector appoint a Team Coordinator?) Suggest hotel accommodations. To be accomplished 6 weeks before the inspection Check again with CAP to determine whether there have been any late additions to the list of included laboratories. Request a list of team members, their credentials, assignments, and special needs from the team leader. Ensure that the team has appropriate transportation to and from its hotel. Remind the team leader, if appropriate, to complete the “Large Inspection Team Hotel Accommodations” form. In concert with the team coordinator, schedule interviews with * the hospital Administrator. * the Chief of Staff. College of American Pathologists Page 83 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Prepare the list of laboratory employees who will be working directly with the inspection team. Reserve the meeting rooms. * * * “Home base” or staging area for the team (all day) Introductory meeting (morning) Summation conference (afternoon) Discuss personal protective equipment (PPE) needs with team coordinator. Provide the team with a list of recommended local restaurants. To have ready for the inspection Know where the team will be staying and how they will be getting to and from the airport. Establish a mechanism to escort the team members to the individual laboratories For special function labs, determine how inspector will get to the lab and back For satellite labs, provide for ground transportation Provide a quiet room where centralized records will be available throughout the course of the inspection. Have PPE available as needed. Food and drink Arrange for box lunches or simple buffet for a working lunch. Have cold drinks or coffee available in or near staging area for the afternoon. Provide for prompt photocopying of the ISR Part B following the summation conference. Post-inspection tasks Construct and distribute (a) Checklist Commentary(ies) using the question numbers as listed on the ISR Part B. Remind everyone that the documented responses, based on the handwritten deficiencies, must be returned to the CAP Central Office within 30 days of the inspection. Coordinate the return of deficiency response materials to the CAP Northfield office. College of American Pathologists Page 84 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation TO THE LABORATORY DIRECTOR --Frequently asked questions-What is a “Site Coordinator”? Every large laboratory or medical center campus is a complex challenge for a CAP inspection team. Pre-inspection planning can spell the difference between an unsatisfactory or a stimulating inspection experience. The Site Coordinator works with the inspection team to convey their needs to the key people in the laboratory. The Site Coordinator makes sure the team is aware of any special requirements the lab might have. During the inspection, the Site Coordinator should be available to the team to meet any last-minute needs. Is a Site Coordinator needed? An inspection will benefit from a Site Coordinator if the answer is yes to any one of these questions: Does the inspection require a team of eight or more members? Will the inspection team travel from out-of-town and require overnight accommodations? Is there more than one location to be inspected? Are there two or more laboratories to be inspected at one location? Who should coordinate the inspection activities for the laboratory? The Site Coordinator can be anyone who is willing to work with the team and with the laboratories, in advance, to plan for a smooth inspection. It will take several telephone calls, many hours, and attention to detail. With the right coordination and planning, an efficient, productive inspection will result that will be a positive experience for both the lab and the inspection team. What about the other labs affiliated with the laboratory? If the inspection team will be inspecting other laboratories at the same location, such as a lab in a sister department, or if the team will travel to a satellite location, the Site Coordinator should help make the local arrangements. Working with the team leader, the Site Coordinator will help plan the schedule. The inspectors and the directors of the other laboratories will be grateful for the effort. How is the Site Coordinator appointed? The lab director should tell the inspection team leader who will coordinate the inspection. With the help of the accompanying manual, the Site Coordinator can take it from there. There is no CAP requirement for the appointment of a SCO, but many inspections have benefited from the services of a Site Coordinator. College of American Pathologists Page 85 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation Appendix G Retention of Laboratory Records and Materials The College of American Pathologists makes the following recommendations for the minimal requirements for the retention of laboratory records and materials. They meet or exceed the regulatory requirements specified in the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88). The College of American Pathologists urges laboratories to retain records and/or materials for a longer period of time than specified when such would be appropriate for educational or quality improvement needs. Laboratories are encouraged to retain materials for a longer period of time when patient care needs so warrant. In particular, laboratories should consider retaining paraffin blocks, tissue slides, and tissue pathology reports for the same period of time, and possibly longer than the times indicated. Some state regulations may require retention of records and/or materials for a longer time period than that specified in the CLIA-88 regulations; therefore any applicable state laws should be reviewed carefully when individual laboratories develop their record retention policies. MATERIAL/RECORD PERIOD OF RETENTION Surgical Pathology Wet tissue Paraffin blocks Slides Reports Accession log records Maintenance records 2 weeks after final report 5 years 10 years 10 years 2 years 2 years Cytology Slides (negative-unsatisfactory) Slides (suspicious-positive) Fine Needle Aspiration Slides Reports Accession log records Maintenance records 5 years 5 years 10 years 10 years 2 years 2 years Autopsy Records Wet tissue Paraffin blocks Slides Reports Accession log records Maintenance records College of American Pathologists 3 months after final report 5 years 10 years 10 years 2 years 2 years Page 86 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation MATERIAL/RECORD II. PERIOD OF RETENTION Clinical Pathology Records Patient test records 2 years Accession records Quality control records Instrument maintenance records Bone marrow reports 2 years 2 years 2 years 10 years III. Blood Bank* All donor and recipient records Records of employee signatures, initials, and identification codes Quality control records Records of permanently deferred donors Indefinitely Indefinitely 5 years Indefinitely *These guidelines meet or exceed AABB requirements IV. Specimens Serum/CSF/Body Fluids 24 hours Specimens from blood bank donors 7 days post transfusion (or 10 days post and recipients Peripheral blood smears/body fluids Bone marrow smears Permanently stained slides-microbiology (gram, trichrome, etc.) crossmatch) 7 days 10 years 7 days References: American Association of Blood Banks, 15th Edition of Standards, pg 28 and pp 39-41, Accreditation Manual for Pathology and Clinical Laboratory Services, Joint Commission on Accreditation of Health Care Organizations, Code of Federal Regulations, 42 CFR Part 405, et al. Revised 9/95 Appendix H: Glossary of Terms Accreditation Accreditation is the determination that a specific AU is meeting program-specific Standards for Accreditation as defined and published by the CAP. College of American Pathologists Page 87 Laboratory Accreditation Manual Accreditation Cycle An Accreditation Cycle is the period of time between accreditation decisions. This is a variable period of time dependent on the program (e.g. LAP, ADT) and the specific Accreditation Unit (AU). The LAP and RLAP are on a two year cycle. FUDT and ADT programs are on a one year cycle. Accreditation Packet An Accreditation Packet is sent to each AU following a decision to grant accreditation. The packet contains a Certificate of Accreditation, CAP Letter of Accreditation, Final List of Deficiencies, and press release. Accreditation Unit (AU) Accreditation Unit is defined as the laboratory, department or other organizational unit that is evaluated and can receive accreditation. While an AU is flexibly defined, it is basically a unique combination of a laboratory with a director and location and some unique combination of laboratory disciplines and sub-disciplines within a CAP program (LAP, FUDT, ADT, RLAP). Activity Menu, Master The Master Activity Menu is the list of all tests and non-test activities that could be performed by an AU. Activity Menu, AU-Specific An AU-Specific Activity Menu is the list of tests and non-test activities that are specific to an AU. ADT (see Athletic Drug Testing) Alternate Proficiency Testing (Alt PT) Alternate Proficiency Testing is proficiency testing provided by a provider other than the CAP. Alt PT (See Alternate Proficiency Testing) Accreditation End Date The date by which an inspection should occur. College of American Pathologists Page 88 Laboratory Accreditation Manual Application An Application is a form(s) that a laboratory completes out to initiate the CAP accreditation processes. Assigning Commissioner The assigning commissioner is the commissioner who appoints an inspection team leader and notifies the CAP of the person assigned. Athletic Drug Testing (ADT) ADT is a CAP program for laboratories that perform performance-enhancing drug testing. AU (See Accreditation Unit) AU Specific Activity Menu (Se Activity Menu, AU Specific) Change of Discipline Form The Change of Discipline Form is sent to an AU after it has indicated a change in services that add an additional discipline. The form is comprised of a list of activities pertinent to the added discipline. The AU indicates the activities in which it participates so that they may be added to the AU Specific Activity Menu. The AU also provides information on the volume of testing performed and supervision of the discipline so that the Regional Commissioner can evaluate whether the discipline can be added without a non-routine inspection. CLA (See Commission of Laboratory Accreditation) CLIA (Clinical Laboratory Improvement Act) Number A CLIA Number is an ID number assigned to a lab by HCFA. Commission on Laboratory Accreditation (CLA) The CLA is a group of CAP members appointed by the CAP president that determines accreditation policy. It consists of Regional Commissioners, Special Commissioners and the Chair. Commissioner A Commissioner is a member of the CLA who is responsible for accreditation activities. Titles include Regional, State, Deputy, Division, and Special Commissioners (Complaint, PT, Checklist, Toxicology, RLAP, Regulatory, and Education Denial Denial is the determination that a lab does not meet the CAP’s accreditation standards. College of American Pathologists Page 89 Laboratory Accreditation Manual Director A Director is an AU-appointed individual who is responsible for the laboratory. The accreditation of a laboratory is tied to both the lab itself and the director. Discipline A Discipline is a CAP term used to describe related activities that are evaluated for the purpose of accreditation. Document Management Document Management is a subsystem of the LAP system used for the tracking of documents sent to or received from an AU, inspector, commissioner or other individual or organization. EE (See Evaluating Entity) Expungement Expungement is the process of eliminating a deficiency because the deficiency should have never existed. Final List of Deficiencies The Final List of Deficiencies is a document included in the Accreditation Packet that lists deficiencies (if any) that were found during an AU’s accreditation inspection. The Final List of Deficiencies does not include any deficiencies that were expunged. Forensic Urine Drug Testing (FUDT) FUDT is a CAP program that accredits laboratories performing recreational drug testing. FUDT (See Forensic Urine Drug Testing) HCFA (See Health Care Financing Administration) Health Care Financing Administration (HCFA) HCFA is an agency within the U.S. Department of Health and Human Services (DHHS) which administers Medicaid, Medicare and Child Health Insurance programs and enforces the Clinical Laboratory Improvement Amendments of 1988 (CLIA 88). IE (See Inspection Event) II (See Inspection Instance) College of American Pathologists Page 90 Laboratory Accreditation Manual Immediate Review Criteria (IRC) Lab An IRC Lab is an AU whose deficiency percentage exceeds a pre-determined threshold as determined by the CLA. These labs will be given a higher priority throughout the accreditation review process. Inspection Deficiency An Inspection Deficiency is a specific area in which an AU is not meeting CAP standards based on a Checklist question. Deficiencies are currently classified as Phase I (i.e. minor deficiencies) and Phase II (i.e. severe deficiencies). Phase II deficiencies may be further classified as critical (i.e. extremely severe) in some programs. Inspection Deficiency Response For each deficiency cited, an AU is required to submit an Inspection Deficiency Response within 30 days of the inspection. For Phase I deficiencies, the AU needs to submit a plan of corrective action. For Phase II deficiencies, the AU needs to submit a plan of corrective action and supporting documentation showing that steps have been taken to correct the deficiency. Inspection Event (IE) An Inspection Event is an identifier used within the CAP to determine appropriate Checklists for inspections. For every AU cycle, there is one Inspection Event for every Section Unit. Inspection Instance (II) An Inspection Instance is a grouping of AUs and SUs for inspection purposes. These events are not necessarily related; however, they are grouped together for ease of inspection (usually a single campus or geographic area). This is subject to change for each AU cycle. Inspection Unit (IU) An Inspection Unit consists of one or more Accreditation Units for the purpose of inspection. For purposes of assigning inspectors, an IU consists of one or more AUs that are to be inspected at the same time by one or more teams. This grouping is more static than an II. An IU is used to ensure that AUs of similar characteristics inspect each other. An IU is also used to track that an AU has fulfilled its inspection obligation. Inspector’s Inspection Packet The Inspector’s Inspection Packet contains all of the materials necessary to facilitate an on-site inspection. Inspector’s Summation Report (ISR) An Inspector’s Summation Report is a form returned by the Team Leader containing the specific deficiencies cited during an inspection as well as the inspector’s comments. Inspector Training Self Study Module Materials used in a self-paced education program designed to familiarize an individual with the inspection process. College of American Pathologists Page 91 Laboratory Accreditation Manual IRC Algorithm (See Immediate Review Criteria Algorithm) IRC Lab (See Immediate Review Criteria Lab) JCAHO Joint Commission on Accreditation of Healthcare Organizations (JCAHO) JCAHO is an international accreditation organization that accredits healthcare organizations, including laboratories. Laboratory Inspection Packet The Inspection Packet is a packet of information sent to the laboratory prior to the on-site inspection that contains AU specific activity menu, response sheets and instructions on how and when to respond to deficiencies. List of Deficiencies A List of Deficiencies is a system-generated listing of the checklist questions (including intent) which were cited as deficiencies during an inspection of a specific AU. Master Activity Menu (See Activity Menu, Master) No Deficiency Lab A No Deficiency Lab is an AU for which no deficiencies (Phase I or Phase II) were cited during an inspection. Non-Routine Inspection A Non-Routine Inspection is any inspection that is done outside the two-year accreditation cycle. Non-routine inspections can be done for a variety of reasons, including a change of director or adding disciplines. Proficiency Testing Proficiency Testing is Proficiency testing is the process in which simulated patient specimens are analyzed by laboratories; it includes the statistical evaluation of the results from such testing in order to assess individual laboratory performance when compared with laboratories using similar methods and reagents or with expected results. Reapplication A Reapplication is a form that a laboratory completes prior to a routine inspection to continue participation in the accreditation program. Reproductive Lab Accreditation Program (RLAP) RLAP is the CAP program with the focus of accrediting laboratories that perform andrology and embryology lab services. College of American Pathologists Page 92 Laboratory Accreditation Manual Reviewing Commissioner The Reviewing Commissioner is the commissioner who reviews the Inspector’s Summation Report and decides if accreditation is given. RLAP (See Reproductive Lab Accreditation Program) Scientific Director A Scientific Director is a lab-appointed director associated with an AU (FUDT only). Section Unit (SU) A Section Unit is defined as an operational area, department, or other type of organizational unit within an AU. A Section Unit normally corresponds to a department within an AU (e.g. hematology, cytopathology, and immunology). One or more SUs comprise an AU. A supervisor is responsible for an SU. Specialty A Specialty is an Evaluating Entity-defined group of activities that are evaluated for purposes of certification or licensure. Each Evaluating Entity provides its own definition of specialties in terms of groups of activities. Staff Inspector A Staff Inspector is a CAP employee who conducts inspections. SU (See Section Unit) Subdiscipline A Subdiscipline is a CAP defined term used to describe related activities that reside under a particular discipline. In the LAP system, a subdiscipline is a subgroup. Subspecialty A Subspecialty is an Evaluating Entity-defined grouping of activities that resides under a particular specialty. Supervisor A Supervisor is a person responsible for the daily activities of a Section Unit. Target Inspection Date The date that signifies the end of the 30 day window during which the inspection should occur. College of American Pathologists Page 93 Laboratory Accreditation Manual Termination Termination refers to the process by which a laboratory’s accreditation is ended. The reasons for termination include: 1. Denial of an AU’s accreditation after an inspection. 2. Initiation of termination by the AU itself when it no longer wishes to participate in the Lab Accreditation Program. The AU is responsible for notifying the LAP Staff of its intention to discontinue coverage under the LAP. 3. Failure to return reapplication materials within a specified time frame. The termination will occur after reminder options (Additional Documentation) have been exhausted. Letters will be sent to the AU and the Regional Commissioner stating that the lab has been terminated because reapplication materials were not received. 4. Joining of two or more AUs which results in the accreditation of a single AU. The AUs that are no longer effective will be terminated and the other AU’s record will be updated to reflect all changes due to the merger. 5. Failure to meet the standards. Test A Test is an analysis of a human specimen, which typically yields a clinical result. Volunteer Inspector A Volunteer Inspector is a person who conducts inspections on a volunteer basis. Inspections may be on behalf of the Inspection Unit with which he/she is affiliated. College of American Pathologists Page 94 Laboratory Accreditation Manual CAP Commission on Laboratory Accreditation William B. Hamlin, MD 206-386-2730 Chair, Commission on Laboratory Accreditation 858-554-8166 Southwest Region Robert R. Rickert, MD 973-322-5763 Vice Chair and Overseas Commissioner Leonard I. Boral, MD 610-237-4057 Middle Atlantic Region EUROPE, FAR EAST DC, DE, MD, NJ Desiree Carlson, MD 508-941-7322 Northeast Region Edgar H. Pierce Jr., MD 423-559-6168 Mid Central Region CT, MA, ME, NH, RI, VT, QUEBEC, MARITIME PROVINCES IL, KY, TN Frank R. Rudy, MD 717-782-2677 Middle East Region Francis E. Sharkey, MD 210-567-4135 Mid-South Region NY, PA TX H. Thomas Norris, MD 352-816-3462 Southeast Region Gerald Hoeltge, MD 216-444-2830 Inter-Region CA, HI, NV NC, SC, VA, WV Thomas G. Puckett, MD 601-264-3856 Special Commissioner for State and Federal Legislative and Regulatory Issues Hans J. Peters, MD 706-327-8593 Gulf Region AL, FL, GA, CENTRAL AND SOUTH AMERICA, THE CARRIBBEAN, PUERTO RICO R. Bruce Williams, MD 318-621-8820 South Central Region Albert Rabinovitch, MD, PhD 973-283-0393 Checklist Commissioner Ronald B. Lepoff, MD 303-372-0336 Special Commissioner for Complaint Investigations, PTES Oversight, and Equivalency Determinations AR, LA, MS, MO, OK Thomas Ruhlen, MD 913-791-4362 West Central Region Thomas Merrick, MD 303-839-6825 Education Commissioner AZ, CO, KS, NM, UT, WY Loyd R. Wagner, MD 605-331-7878 North Central Region Wayne Markus, MD 402-731-4145 Toxicology Commissioner IA, MN, ND, NE, SD, WI, MANITOBA Aaron Lupovitch, MD 734-246-6922 Great Lakes Region IN, MI, OH, ONTARIO William Byrd, PhD 214-648-2376 Reproductive Laboratory Commissioner Richard G. Patton, MD 206-386-2730 Northwest Region P. Ridgway Gilmer, MD 713-432-1322 Editor, Laboratory Accreditation Program Newsletter AK, ID, MT, OR, WA, BRITISH COLUMBIA, ALBERTA, SASKATCHEWAN Robert M. Nakamura, MD College of American Pathologists Page 95 Laboratory Accreditation Manual