Procedures across multiple CLIA sites
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For those of you with multiple CLIA sites, how do you handle the balance of standardizing your policies/procedures and also catering to the differences of workflows between all of them?
Do you have a single draft of p/p that is unwaveringly applied to all sites?
Is there a primary site that makes the master procedure then each site gets to make edits to the master procedure that caters to that specific location? What is the approval process for this, only the site LD on the license needs to approve?
Do you have a single draft of p/p that is unwaveringly applied to all sites?
Is there a primary site that makes the master procedure then each site gets to make edits to the master procedure that caters to that specific location? What is the approval process for this, only the site LD on the license needs to approve?
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In my experience with inpatient and outpatient testing sites, waived and nonwaived complexity testing, I find inpatient testing sites far easier to 'apply as a one size fits all' standardization of P&Ps. And workflows. Plus it's typically one CLIA# covering all those testing sites within one hospital/inpatient setting.
Outpatient challenges for me in sticking to a strict work flow includes: literally the size of the clinic and is there a dedicated POC Station/room/space? the layout of the clinic with many times shared space (shared for different service lines, different staff, different needs for a work flow although could be sharing the same POC test device/kit).
For me/our testing sites, I would not say a struggle for us is using the same P&P and IFU/package insert across all testing sites for the POCT. The tediousness for us seems to be the collection (ex swab or urine specimen) process, where the testing can take place (nursing station vs dedicated POC 'room' such as a utility room, collecting in patient exam room then carrying out the sample - that kind of issue related to work flow. Recent example? antigen test where IFU stated 'do not put the swab back in the packaging sleeve to carry it out of the collection station'. Oh boy - seems easy/simple but the work flows are different between clinics and urgent care space/how patients flow through.
Also kicking into workflow is 'environment of care' and 'infectious disease/epidemiology' stuff like how one can and cannot carry specimens in a hallway and the PPE required. Cover that as able in the P&Ps to be standardized.
I guess bottom line for us is: we have one SOP which is dictated by the IFU although the POC Director could make it more strict. We work on the SOP until there is one that workflows can carry out. And I personally work whatever time it takes with the NM or operators so the workflow is adapted up front to be able to carry out the standard SOP.
Hope this helps a bit. It's never been easy and I go through this with each new testing site and existing SOPs.
The difficulty for us is always the competency piece of having the same SOP at different CLIA#s so we ARE, in my opinion, repeating a competency for the sake of 'it's a different CLIA#' but nothing is different in the process/performance of the POC test.
Peggy