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Laboratory Compliance

Laboratory compliance is the ongoing effort of clinical labs to meet certain standards of practice set by various government agencies. Most prominent of these are the Clinical Laboratory Improvement Amendments (CLIA), which establish Quality Assurance (QA) standards for all laboratory testing to ensure the accuracy, reliability and timeliness of patient test results regardless of where the test was performed.

CLIA requires clinical laboratories to be certified by their state as well as the Center for Medicare and Medicaid Services (CMS) before they can accept human samples for diagnostic testing. Laboratories can obtain multiple types of CLIA certificates, based on the kinds of diagnostic tests they conduct.

Certification is also required to receive reimbursements from Medicare or Medicaid.

CLIA 88 requires Quality Assurance assessment of all labs for these QA standards:

  • Patient test management
  • Quality control
  • Proficiency testing
  • Test comparisons
  • Relate results to clinical data
  • Personnel
  • Communications
  • Complaints
  • Staff review
  • Records

These QA standards for laboratory compliance encompass a range of activities that enable laboratories to achieve and maintain high levels of accuracy and proficiency despite changes in test methods and the volume of specimens tested. According to the CDC, good QA system achieves these four things:

  • Establishes standard operating procedures (SOPs) for each step of the laboratory testing process, ranging from specimen handling to instrument performance validation
  • Defines administrative requirements, such as mandatory recordkeeping, data evaluation, and internal audits to monitor adherence to SOPs
  • Specifies corrective actions, documentation, and the persons responsible for carrying out corrective actions when problems are identified
  • Sustains high-quality employee performance

Three federal agencies are responsible for CLIA and laboratory compliance: The Food and Drug Administration (FDA), Center for Medicaid Services (CMS) and the Center for Disease Control (CDC). Each agency has a unique role in assuring quality laboratory testing.

FDA

  • Categorizes tests based on complexity
  • Reviews requests for Waiver by Application
  • Develops rules/guidance for CLIA complexity categorization

CMS

  • Issues laboratory certificates
  • Collects user fees
  • Conducts inspections and enforces regulatory compliance
  • Approves private accreditation organizations for performing inspections, and approves state exemptions
  • Monitors laboratory performance on Proficiency Testing (PT) and approves PT programs
  • Publishes CLIA rules and regulations

CDC

  • Provides analysis, research, and technical assistance
  • Develops technical standards and laboratory practice guidelines, including standards and guidelines for cytology
  • Conducts laboratory quality improvement studies
  • Monitors proficiency testing practices
  • Develops and distributes professional information and educational resources
  • Manages the Clinical Laboratory Improvement Advisory Committee (CLIAC)

Proposed Electronic Signature Rule Has Compliance Risks

CEO SUMMARY: Proposed HHS rule aims to define and standardize physician electronic signatures. For clinical laboratories, this is important because lab test claims require a signed requisition form. Given …

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UHC’s Z-Code Requirement to Commence on Aug. 1

CEO SUMMARY: In what may be an alarming development for certain clinical laboratories, as of Aug. 1, UnitedHealthcare will require Z-codes for molecular test claims filed under its co…

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UnitedHealthcare Policy Change Requires NPI Numbers on Medicare Advantage Claims

ANOTHER NEW POLICY RECENTLY ANNOUNCED by UnitedHealthcare (UHC) sets a deadline for June 1, 2023, requiring clinical laboratories and other ancillary providers to include the …

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CLIA Lab Accreditors Reveal Most Frequent Deficiencies

CEO SUMMARY: CAP, The Joint Commission, COLA, and A2LA took the stage at the recent Executive War College to detail their respective lists of the 10 most often-cited standards during…

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CMS Ends Remote Reading of Pathology Glass Slides

CEO SUMMARY: On the day the federal government ended the public health emergency for SARS-CoV-2, CMS issued an updated FAQ that ended the allowance for remote reviews of glass slides…

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Elizabeth Holmes Still Wants ‘To Contribute’ in Healthcare

CLINICL LABORATORY AND ANATOMIC PATHOLOGY PROFESSIONALS have another reason to shake …

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Lab Execs Allegedly Lied to FDA about Faulty Tests

CEO SUMMARY: Three former executives of a lab testing company face criminal charges. Federal prosecutors claim that the three plaintiffs who previously worked at Magellan Diagnostics flagrantly hid…

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Draft Rule Standardizes Electronic Signatures

CEO SUMMARY: Every year, payers refuse laboratory test claims on grounds that the ordering provider’s signature is missing or illegible—a situation that costs clinical labs million of dollars in…

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OIG’s Issues New Opinion on Use of Gift Cards for Lab Specimens

CEO SUMMARY: This new Advisory Opinion from the Office of Inspector General (OIG) outlines a narrow situation in which it may be allowable for clinical laboratories to use gift cards to encourage pa…

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Elizabeth Holmes’ Appeal Questions Competence of CLIA Lab Director

TANTALIZING DETAILS ABOUT FORMER THERANOS CEO ELIZABETH HOLMES’ purchase of a one-way plane ticket to Mexico prior to her conviction grabbed headlines following the filing of a motion to appeal her conviction.  However, for clinical labo…

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