Managing Point of Care Competency Across Multiple CLIA Licenses
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Hello everyone! This is my first time posting here and I'm so grateful a place like this exists.
I'm curious how you manage competency for hospital staff that are performing waived point of care testing across multiple CLIA licenses. Our hospital system has been growing recently. We now have 4 hospitals and many smaller satellite clinics. Our nurses are increasingly working in any combination of these locations, sometimes performing the exact same waived tests at each site. We are currently requiring that initial training and documentation of competency take place each time they begin testing on a new license, but we are getting some pushback about the repetitive trainings and the burden of tracking excessive paperwork/competency deadlines.
My questions boil down to:
I'm curious how you manage competency for hospital staff that are performing waived point of care testing across multiple CLIA licenses. Our hospital system has been growing recently. We now have 4 hospitals and many smaller satellite clinics. Our nurses are increasingly working in any combination of these locations, sometimes performing the exact same waived tests at each site. We are currently requiring that initial training and documentation of competency take place each time they begin testing on a new license, but we are getting some pushback about the repetitive trainings and the burden of tracking excessive paperwork/competency deadlines.
My questions boil down to:
- If you have encountered a similar situation, how have you managed to streamline it?
- Are there relevant CLIA regs about where training has to take place? i.e. Can training take place in a centralized location or does it need to be on site where the trainee will be performing testing?
- Does it matter if each location has the exact same devices, procedures and lab director?
- If you use middleware to manage competency (RALS in our case) how are you recording and tracking competency for the same end user at different testing sites?
I appreciate any insights you may have.
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For CLIA, Accreditations TJC and CAP follow it, training is allowed in a central location. Training does not need to be CLIA # specific, the way competency assessment may need to be.
It would be helpful for those who would like to help, if you identified if all the staff working multiple locations/hospitals (assuming you mean multiple CLIA #s) were performing only waived testing or if also performing non-waived complexity?
Competency requirements can change for waived complexity depending on Accreditation related to multiple CLIA#s).
Thanks.
Peggy: The staff in question are only performing waived testing. Generally speaking they are performing the exact same waived tests with the same enterprise-wide procedure at each CLIA licensed location they move between.
Kari: We are accredited by The Joint Commission as well. I appreciate you outlining your current process - it sounds a lot like what we are hoping to implement. I asked TJC for clarification on this topic and I am still waiting on their reply. Was it an inspector that told you training/competency didn't have to occur at each CLIA site? I'm hoping to be able to show my receipts when we overhaul our competency system.
Agata: I'm glad to hear we are not the only ones dealing with this. Your struggles sound very familiar. Fortunately, our policies and training documents are already uniform across all sites. We are still struggling with how to efficiently record competency information in RALS and how often we are required to capture competency as staff move around. Like you, I'm hoping to pilot a centralized training model in the very near future.
I would clarify with TJC that they are referring to waived testing. CMS's only requirements for a waived certificate are to enroll in the CLIA program, pay the applicable fee and follow manufacturers' instructions. In that response, it sounds like they are talking about requirements for non-waived testing.