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Proficiency Testing

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Technical Consultant:<br />

State Laboratory Director:<br />

S<br />

4/18/06<br />

4/18/06<br />

Site Co-Director :<br />

________________________________________<br />

Sign & Date<br />

Procedure approved for initial implementation on ________________<br />

Date<br />

( ) Reviewed ( ) Revised: _______________________________<br />

TC,Director, & Co- Director Initial & Date<br />

( ) Reviewed ( ) Revised: _______________________________<br />

TC,Director, & Co- Director Initial & Date<br />

( ) Reviewed ( ) Revised: _______________________________<br />

TC,Director, & Co- Director Initial & Date<br />

( ) Reviewed ( ) Revised: _______________________________<br />

TC,Director, & Co- Director Initial & Date<br />

( ) Reviewed ( ) Revised: _______________________________<br />

TC,Director, & Co- Director Initial & Date<br />

Local Public Health Laboratories of Kentucky<br />

<strong>Proficiency</strong> <strong>Testing</strong>- PPM<br />

I. Purpose and Principle<br />

<strong>Proficiency</strong> testing is a method of externally validating the accuracy of laboratory<br />

performance by testing samples and comparing results of all participating<br />

laboratories. A proficiency testing provider sends samples to participants who have<br />

enrolled in the program. The participants analyze the samples as they do patient<br />

samples and return the results to the PT provider. The results are tabulated and<br />

evaluated and scored reports are sent back to the laboratory.<br />

A subcategory of the Moderate Complexity level was added after the original CLIA<br />

publication. It was first described as Physician Performed Microscopy and is now<br />

called Provider Performed Microscopy (PPM). The criteria for classifying these tests<br />

include:<br />

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• The examination must be performed by a physician or a mid-level practitioner<br />

(i.e., nurse practitioners, nurse midwives and physician assistants) during the<br />

patient visit on a specimen obtained from the provider's patient or a patient of the<br />

group practice.<br />

• The procedure must be in the moderately complex category.<br />

• The primary instrument for the test must be a microscope.<br />

• The specimen must be labile or a delay in testing could compromise the accuracy<br />

of the test.<br />

• Control materials are not available to monitor the entire testing process.<br />

• Limited specimen handling is required.<br />

The 42 CFR 493 - October 2001 indicates that PPM laboratories are subject to<br />

Subparts H (<strong>Proficiency</strong> <strong>Testing</strong>), J (Patient test Management), K (Quality Control),<br />

M (Personnel), and P (Quality Assurance). Because the PPM tests are considered<br />

"non-regulated," proficiency testing is not specifically required, but a laboratory is<br />

responsible for documenting quality assurance. In other words, at a minimum, two<br />

split samples for each PPM test should be done yearly. Since split sampling would<br />

not be feasible for most sites, the Local PHLOK is directed to perform proficiency<br />

testing sent twice a year from the State Public Health Laboratory Technical<br />

Consultant.<br />

II.<br />

Procedural Instructions<br />

<strong>Proficiency</strong> <strong>Testing</strong> Procedure<br />

1. Each site performing PPM testing will receive twice a year, proficiency testing<br />

material from the State Technical Consultant. This material is in the form of<br />

photomicrographs obtained from the Wisconsin State Laboratory of Hygiene<br />

<strong>Proficiency</strong> <strong>Testing</strong>.<br />

2. View the images and identify the structures that the arrows are pointing to.<br />

Beginning April 2006, the State Laboratory will begin sending 5 challenges with<br />

each mailing instead of 4 for KOH/Wet Preps. Use the information provided in<br />

the case histories to aid identification.<br />

3. Record your test results on the Provider Performed Microscopy (PM) Result<br />

Form. Use the “Microscopic Glossary” provide on the Provider Performed<br />

Microscopy (PM)/Urine Sediment (SU) Instructions form to obtain code numbers<br />

for the urine sediment and wet prep challenges. Select the appropriate response<br />

codes from the glossary and enter them on the result form. For all other<br />

microscopic procedures, mark an appropriate response circle on the result form. If<br />

you do not perform a particular procedure, fill in the “Test not performed” circle.<br />

4. Sites performing any of the Microscopic Procedures listed on the Provider<br />

Performed Microscopy (PM) Result Form need to complete the <strong>Proficiency</strong><br />

<strong>Testing</strong> for those tests.<br />

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5. Obtain signature of Co-Director and testing personnel and complete the<br />

Attestation Statement Form.<br />

6. Mail results back to the State Public Health Laboratory within 5 days in the<br />

provided envelope.<br />

7. The State Technical Consultant will mail back to your site a copy of your results<br />

and the expected results along with an event specific information data form<br />

complied by Wisconsin State Hygiene Laboratory from all sites that submit<br />

testing results.<br />

8. If your site receives a score less than 80%, remedial action must be taken,<br />

documented and documentation sent to the State Lab Technical Consultant.<br />

CLIA Regulations to Support <strong>Proficiency</strong> testing<br />

493.801<br />

Subpart H<br />

<strong>Testing</strong> of <strong>Proficiency</strong> Specimen<br />

1. The laboratory must examine or test, as applicable, the proficiency testing<br />

samples it receives from the proficiency testing program in the same manner as<br />

it tests patient specimens.<br />

2. The samples must be examined or tested with the laboratory's<br />

regular patient workload by personnel who routinely perform the testing in the<br />

laboratory, using the laboratory's routine methods. The individual testing or<br />

examining the samples and the laboratory director must attest to the routine<br />

integration of the samples into the patient workload using the laboratory's routine<br />

methods.<br />

3. Laboratories that perform tests on proficiency testing samples must not engage in<br />

any inter-laboratory communications pertaining to the results of proficiency<br />

testing sample(s) until after the date by which the laboratory must report<br />

proficiency testing results to the program for the testing event in which the<br />

samples were sent. Laboratories with multiple testing sites or separate locations<br />

must not participate in any communications or discussions across sites/locations<br />

concerning proficiency testing sample results until after the date by which<br />

the laboratory must report proficiency testing results to the program.<br />

4. The laboratory must document the handling, preparation, processing,<br />

examination, and each step in the testing and reporting of results for all<br />

proficiency testing samples. The laboratory must maintain a copy of all records,<br />

including a copy of the proficiency testing program report forms used by the<br />

laboratory to record proficiency testing results including the attestation statement<br />

provided by the PT program, signed by the analyst and the laboratory<br />

director, documenting that proficiency testing samples were tested in the<br />

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same manner as patient specimens, for a minimum of two years from the date<br />

of the proficiency testing event.<br />

493.803<br />

Subpart H<br />

Failure to Participate<br />

1. Each laboratory performing nonwaived testing must successfully participate in a<br />

proficiency testing program approved by CMS, if applicable, as described in subpart I<br />

of this part for each specialty, subspecialty, and analyte or test in which the laboratory<br />

is certified under CLIA. Except as specified in paragraph (c) of this section, if<br />

a laboratory fails to participate successfully in proficiency testing for a given<br />

specialty, subspecialty, analyte or test, as defined in this section, or fails to take<br />

remedial action when an individual fails gynecologic cytology, CMS imposes<br />

sanctions, as specified in subpart R of this part.<br />

2. If a laboratory fails to perform successfully in a CMS-approved proficiency testing<br />

program, for the initial unsuccessful performance, CMS may direct the laboratory to<br />

undertake training of its personnel or to obtain technical assistance, or both, rather<br />

than imposing alternative or principle sanctions except when one or more of<br />

the following conditions exists:<br />

(1) There is immediate jeopardy to patient health and safety.<br />

(2) The laboratory fails to provide CMS or a CMS agent with<br />

satisfactory evidence that it has taken steps to correct the<br />

problem identified by the unsuccessful proficiency testing performance.<br />

(3) The laboratory has a poor compliance history.<br />

493.825<br />

Subpart H<br />

Unsatisfactory performance and remedial actions<br />

1. Failure to attain an overall testing event score of at least 80 percent is<br />

unsatisfactory performance.<br />

2. Failure to participate in a testing event is unsatisfactory performance and results<br />

in a score of 0 for the testing event.<br />

3. Failure to return proficiency testing results to the proficiency testing program<br />

within the time frame specified by the program is unsatisfactory performance and<br />

results in a score of 0 for the testing event.<br />

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4. For any unsatisfactory testing event for reasons other than a failure to participate,<br />

the laboratory must undertake appropriate training and employ the technical<br />

assistance necessary to correct problems associated with a proficiency testing<br />

failure.<br />

5. Remedial action must be taken and documented, and the documentation must be<br />

maintained by the laboratory for two years from the date of participation in the<br />

proficiency testing event.<br />

6. Failure to achieve an overall testing event score of satisfactory performance for<br />

two consecutive testing events or two out of three consecutive testing events is<br />

unsuccessful performance. The site must then demonstrate sustained satisfactory<br />

performance on two consecutive proficiency testing events, one of which may be<br />

on site. Failure to resolve remedial action will be under special review by the<br />

Director.<br />

Investigating an Unacceptable PT Result<br />

1. All documentation should be reviewed.<br />

2. Personnel who processed or tested the specimen, and who transcribed results<br />

should be interviewed. The investigation should include:<br />

• Checks for clerical errors<br />

• Review of records of quality control, calibration status and instrument<br />

function checks<br />

• Repeat analysis and calculations when possible<br />

• Evaluation of the laboratory’s historical performance for that analyte<br />

3. The laboratory should review patient data from the time of the unacceptable PT<br />

result, to determine whether the problem could have affected patient care. If so,<br />

appropriate follow-up action should be documented.<br />

4. The laboratory should make every effort to find the cause(s) of an unacceptable<br />

result. In instances where the laboratory can identify an underlying system<br />

problem that contributed to the unacceptable result, actions to improve laboratory<br />

systems will minimize the risk of recurrence and potentially improve the quality<br />

of patient results.<br />

5. The investigation, conclusions, and corrective action should be thoroughly<br />

documented. For standardized form for reporting the results of every unacceptable<br />

PT investigation, use the Corrective Action/Incident Reporting form found in<br />

Section 7.<br />

III. References<br />

Appendix C, Survey Procedures and Interpretive Guidelines for Laboratories and<br />

Laboratory Services, CMS Website, http://www.phppo.cdc.gov/clia/regs/toc.aspx,<br />

accessed April 2006<br />

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Using <strong>Proficiency</strong> <strong>Testing</strong> (PT) to Improve the Clinical Laboratory; Approved Guideline,<br />

NCCLS GP27-A, Vol. 19, No, 15, 940 West Valley Road, Wayne, PA, 19087, 1999<br />

Provider-Performed Microscopy <strong>Testing</strong>; Approved Guideline, NCCLS HS2-A, Vol. 20<br />

No.3, 940 West Valley Road, Wayne, PA, 19087, 2003<br />

Wisconsin State Hygiene Laboratory <strong>Proficiency</strong> <strong>Testing</strong> Program,<br />

http://www.slh.wisc.edu/pt/, 465 Henry Mall: Room 402,<br />

Madison WI 53706-1578, accessed April 2006<br />

American Academy of Family Physicians <strong>Proficiency</strong> <strong>Testing</strong>, P.O. Box 11210<br />

Shawnee Mission, KS 66207-1210, http://www.aafp.org/x2255.xml, accessed April 2006<br />

IV. Author<br />

Linda Dailey, MT (ASCP) April 2006<br />

V. Procedure Policy, Approval and Review Process<br />

1. The official copy of each procedure will be placed in the Technical and<br />

Administrative Branch Manager’s copy of the Local Public Health Laboratory of<br />

Kentucky Standard Operating Procedures Manual. A copy of the procedure to be<br />

placed in the SOPM at each PHLOK approved site.<br />

2. Each procedure will be initially reviewed and approved with signature by the<br />

Technical Consultant, State Director and Co-Director prior to implementation.<br />

3. Each procedure will be reviewed annually and as needed for necessary revision. Any<br />

modification will be reviewed and approved as stated in #2 above.<br />

4. Implementation of new or revised procedures must be communicated to all testing<br />

personnel prior to the implementation date. The Co-Director must document that<br />

each of the testing personnel (by individual name) have been made aware of the<br />

procedure changes, revision implementation date and been trained as necessary.<br />

5. Any associated logs, specimen collection instructions or other documents related to<br />

the procedure change must be initiated.<br />

6. Each procedure must have a master file, stored at the State Lab, that contains the<br />

current and all previous versions. The master file serves as the documented history of<br />

the procedure, showing all revisions and the dates used and discontinued or retired.<br />

The master file must be maintained for a least two (2) years from last date used.<br />

VI. Appendix<br />

Copy of Provider Performed Microscopy (PM)/ Urine Sediment (SU) Instructions<br />

Copy of Provider Performed Microscopy (PM) Result Form<br />

Copy of Urinalysis & Microscopy Attestation/Comments Page<br />

Copy of Provider Performed Microscopy (PM) photomicrographs<br />

Copy of Performance Evaluation by Site<br />

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