POC Leadership Forum Update on the Regulations CLIA, CAP, JCAHO and COLA Ronald H. Laessig, Ph.D. University of Wisconsin Madison, Wisconsin www.cms.hhs.gov/clia
Mar 27, 2015
POC Leadership Forum
Update on the Regulations
CLIA, CAP, JCAHO and COLA
Ronald H. Laessig, Ph.D.University of Wisconsin
Madison, Wisconsinwww.cms.hhs.gov/clia
Purpose of U.S. Lab Regulations
… quality standards for all laboratory testing to ensure
accuracy reliability timeliness
of patient test results regardless of where the test is performed…
www.cms.hhs.gov/clia
Series of six slides from Glamour Magazine
The latest information on test quality
Believe it or not
#1
www.cms.hhs.gov/clia
Series of six slides from Glamour Magazine
The latest information on test quality
Believe it or not
#2
www.cms.hhs.gov/clia
Series of six slides from Glamour Magazine
The latest information on test quality
Believe it or not
#3
www.cms.hhs.gov/clia
Series of six slides from Glamour Magazine
The latest information on test quality
Believe it or not
#4
www.cms.hhs.gov/clia
Series of six slides from Glamour Magazine
The latest information on test quality
Believe it or not
#5
www.cms.hhs.gov/clia
Series of six slides from Glamour Magazine
The latest information on test quality
Believe it or not
#6
www.cms.hhs.gov/clia
Quality POCT: What drives the system?
According to Glamour Magazine: ….(we always go right to the source)
If Regulations are not followed…...
...Human error followsJ. Yost, the “CLIA Lady”
Manufacturers’ Point of View
Evolution in Assured Quality•Reduction in size
•Operator ID / Patient ID
•Reagent viability
•Lock-out quality control
•Connectivity
•Data management
Roche Diagnostics
Regulator’s Point of View
U.S. Regulations = CLIA
C = ClinicalL = LaboratoryI = ImprovementA = Amendments
Regulates ~180,000 U.S. test siteshttp://www.cms.hhs.gov/clia/
Regulator’s Point of View
CLIA’88(February 28, 1992)
CLIA’03(January 24, 2003)
Linking Quality and Regulations
CLIA’s working premise:
CLIA’s mandated quality practices will improve quality of test results
CLIA Regulations and the Director
The laboratory director is responsible for the overall operation and administration of the laboratory … [the] testing systems … used [must] provide quality laboratory services for all aspects of test performance … including the pre-analytic, analytic, and post-analytic phases of testing
Quality POCT Challenge – March 2004
Dilemma for today:
With the manufacturer building-in/assuring quality,Where is the professional input from the
laboratory director?Does the director just buy the technology
and use it?
What do we know today about CLIA and Quality Requirements?
CLIA’03 takes a Quality Systems approach like ISO documents
The quality requirements follow the route of the specimen pre-analytical analytical post-analytical issues
CLIA and Quality Requirements? The old CLIA covered the analytical requirements in
one section and quality assurance in another.
The new CLIA groups the quality requirements under a new term “Quality Assessment”
Quality Assessment = Quality Control + Quality Assurance
CLIA wants to consider the testing process start to finish-hence “pre, post and analytical assessment”
CLIA ‘03 and QC?
Control procedures must (§493.1256): Monitor the accuracy and precision of the complete
analytical process
Detect immediate errors due to test system failure, adverse environmental conditions, and operator performance
Monitor over time precision and accuracy that may be influenced by changes in test system, environment and operator performance
CLIA’03 and QC?Control procedures must (§493.1256):
Monitor complete analytical process Detect immediate errors Monitor over time precision and accuracy
Conceptually, meeting the requirements sounds easy,
But ---
CLIA’03 and QC?Control procedures must (§493.1256):
Monitor complete analytical process Detect immediate errors Monitor over time precision and accuracy
Conceptually, meeting the requirements sounds easy,
But ---
CLIA ’03 and Q C
The Devil is in the Details
CLIA’03 – The details! What about
Electronic QC? Process controls? Internal controls?
Do thesea) evaluate complete analytical processb) detect immediate errorsc) monitor accuracy and precision over timed) none of the above
Details - 12 January 2004
http://www.cms.hhs.gov/clia/appendc.asp
NEW and MoreInterpretive Guidelines for CLIA – 300+ pages
New Concept for QC?
EQC
Equivalent Quality Control
New Concept for QC?
EQC =
Electronic Quality Control
What is Equivalent QC (EQC)?
For instruments with procedural/internal controls, test sites can choose to:
Analyze 2 external, liquid controls per day
OR Qualify the procedural/internal controls as one
of three EQC options
EQC Option #1
Test Systems with internal/procedural control(s) that monitor the entire analytic process Test site may use EQC, if test system’s stability is demonstrated
EQC #1 - Evaluation of Stability
Along with internal/ process controls, run 2 external QC daily for 10 consecutive days (why 10?)
If internal/process and external control results are acceptable (what is acceptable?) reduce external QC from daily to once / month unless
manufacturer requires more
Lab must perform/monitor the internal control(s) in accordance with manufacturer instructions
Option #1
Instrument with manufacturer supplied on board controls, run
automatically.
EQC Option #2
Test Systems with internal/procedural control(s) that monitor a portion of the analytic process
Test site may use EQC, if test system’s stability is demonstrated
Option #2 - Evaluation of Stability
Along with internal process controls, run 2 external QC daily for 30 consecutive days (why 30?)
If internal and external control results are acceptable (what is acceptable?) reduce external QC from daily to once / week unless
manufacturer requires more
Lab must perform/monitor the internal control(s)
in accordance with manufacturer instructions
Option #2
Hand held instrument currently advertized as having on board,
electronic controls.
EQC #3 Test Systems without Internal/Procedural
Control(s) Advancements in technology have produced
systems– Capable of maintaining stable performance
specifications over time
– Minimally influenced by adverse environmental conditions and operator variance.
Test site may use EQC, if test system’s stability is demonstrated
Option #3 - Evaluation of Stability
Along with internal process controls, run 2 external QC daily for 60 consecutive days (why 60?)
If internal and external control results are acceptable (what is acceptable?) reduce testing external QC from daily to once / week
unless manufacturer requires more
Lab must perform/monitor the internal control(s) in accordance with manufacturer instructions
Option #3?
What belongs in this picture?
Option #3?
Prove stability for 60 days, run external QC once per week
Every Instrument!
Vitros
Hitachi
aca, SMAC,
etc.
CLIA – “Equivalent” QC (EQC)
“The director must consider the laboratory’s clinical and legal responsibility for
providing accurate and reliable patient test results versus the cost implications of reducing the QC testing frequency.”
EQC is a choice!
Uncle Sam
Has Uncle Sam gone Crazy?
Uncle Sam
Has Uncle Sam gone Crazy?
Maybe or Maybe Not!
March 2004
Does EQC and the U.S. regulations open a new era for new technologies
or does EQC just cause confusion?
Quality POCT: What Drives the System?
To me, CLIA QC regulations say –Continue the “old” way – 2 external
QC/dayQualify the test system under EQC
options and reduce frequency of external QC
Quality POCT: What Drives the System?
To me, CLIA QC regulations say – Continue the “old” way – 2 external QC/day Qualify the test system under EQC options
and reduce frequency of external QC
EQC Option #3 ( for a test system with no internal/process controls) Do you want your testing done on a system
that qualifies under this option?
The Devil is in the details EQC Qualified System – External QC
analyzed once per month or once per week.
EQC-1 EQC-2&3
“The Devil is in the Details”
§493.1282 Standard: Corrective actions
…[if] external QC [results]…fail to meet the laboratory's established criteria for acceptability, all patient test results obtained…since the last acceptable test run must be evaluated to determine if patient test results have been adversely affected…
Quality POCT: Drivers?
Manufacturers – Building the perfect instrument to meet the needs of the testing environment
CLIA’s new QC/EQC Requirements
Have a two-year phase in Inspection Citations NO punitive activities
Manufacturers have “EQ”Options #1, 2, & 3
To be competitive in the marketplace, options #2 and #3 DON’T count
The bottom line…..the “Regs”
We are in a two year phase in We are all trying to figure out what they
mean At the end of the day, the laboratory
director must make the call -- QC or EQC (1,2,or 3)
We are after all in the patient care business
Legally, Morally, ethically, technically, the patients (must) always come first.
CLIA Regulations and the Director
The laboratory director is responsible for the overall operation and administration of the laboratory … [the] testing systems … used [must] provide quality laboratory services for all aspects of test performance … including the pre-analytic, analytic, and post-analytic phases of testing
…..and
Speaking of Lab Directors,
Heerrrrrs Fritz !!!!!