Novel ideas for Direct Observation of staff at multiple locations

I would not say our ideas are novel by any stretch of the sense, but we have a similar setup where OR and MRI staff float between sites that are absolutely identical.  

At their initial, we send a calendar notification (to staff and educator) at the beginning of their 5th month giving them their absolute last date that they can complete/will expire.  We also use core trainers (NPD Educators) and we put that responsibility on the educator to ensure that this testing is complete.  If not, they get locked out and have to restart.  If any patient testing happens, there is a safety event which is escalated through their leadership and medical leadership as well as the educator's leadership.

However, we have a "way" around this so to speak which we utilize for our temp staff.  :)  Beginning of precepting, they will complete their training and initial.  End of their precepting, they complete their semi-annual.  It may be 3 weeks later, it may be 4 months later, but always prior to 7th month.  The beauty of the regulation is that it does not state that an initial and a semi-annual cannot even be on the same day (wouldn't advise that).  We were constantly getting in a rough spot because we were trying to do these in the 6th month and then either missing them or not able to catch both sites.  Tying it to the precepting tasks for our nursing folks (APN, RN, CNA, etc) was a great way to remind them that this also needs completing and we have had great success so far (just started this year, but going well).

Essentially, you can put it on the scheduler of the department to ensure the next time they rotate through that particular site, they are completing their semi-annual with your core person/people or POCC, whichever is easiest.  The scheduler can even be the one to set the calendar notification if that's within the wheelhouse!

I don't have the answer to multiple sites, that is a pain point I wouldn't know how to get around until there is a regulation change (wouldn't that be nice!). I'm curious how you get away with doing a 6 month competency early? At my last CAP inspection (done by inspectors from CAP, not a fellow laboratory) I was told that if she found an actual person that I had done the 6 month competency at 3 months, she would cite me. Luckily one of those wasn't found, but she insisted that we can call it semi-annual, but it can't be done BEFORE 6 months. She did not state that 6 month and annual couldn't be closer together, but she was sure on the 6 month minimum. She also added that an employee who had been with the facility longer than 1 year, then started performing moderate complexity testing did not need the 6 month requirement because by virtue of retaining their job for at least 1 year they have demonstrated their ability to retain knowledge (mind blown!). I have not opted to test that statement, but her interpretation of the standards changed our assessment timelines. I'll say again, she was from CAP, so I assume she knows the interpretation of the standards better than most of us who just take the inspector training from CAP to be able to inspect other laboratories. 
Anyone else run into this?

Amy, 
I'd like that inspector to show me where POC.06915 states a minimum length of time for the semi-annual assessment. I don't see how this inspector thinks any of us could possibly get the semiannual assessment done no less than 6 months and no more than 7 months from the start of testing.  That's just not feasible.

Amy, 
As an inspector, I usually look at your policy.  If your policy states you do this at "6 months" then yes, you can be cited.  However, if you keep it general and broad (as my department likes to do!) then there is no way that the citation would stand.

GEN.55505 and POC.06915 - "The competency of personnel performing nonwaived testing is assessed at the required frequency at the laboratory (CAP/CLIA number) where testing is performed." with a note stating "At least semiannually (first assessment within seven months from initiation of testing and second assessment no later than 12 months from the start of testing) during the first year an individual tests patient specimens (new employee)".

So - again, I would review your policy for competency assessment and take out any verbiage that it is AT 6 months.  Setting yourself up for failure, but kudos for not failing at all!!!

previous renditions of the same CAP standard read differently, but now designate "by the 7th month".  previously POC.06910 stated "During the first year of an individual's duties, competency must be assessed at least semiannually; * After an individual has performed his/her duties for one year, competency must be assessed at least annually;"

As for your other topic - I would not interpret that by virtue they just know what they're doing and that's that.  Other CAP inspectors may have a few other thoughts on that.  GEN.54400, GEN.54750, GEN.55450, POC.06800, POC.06850 and POC.06915 :)