Training vs. Competency with POC

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Within the lab, we are very aware that new employees must have a training document separate from their competency verification. However, for POC, we have always had a combined sign off form for both training and verification. During our recent TJC inspection, they stated this is not sufficient and the POC operators must be treated like the lab staff and have two separate documents. 

Does anyone have any advice or documents they would be willing to share to show how this can be done without being too intensive for the nursing and respiratory staff? 

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Hi Amanda!  We use a combined training/competency document.  It is called "Training & Competency Assessment Checklist".  At the top you have to circle either Initial Training, 6-month, 12-month, Annual, or Remedial.  I don't see why this would need to be a different form if you can demonstrate that it was being used for training by circling "Initial Training".

Hi Amanda! We have a training document that includes acknowledgement of some important policies and a quiz to demonstrate and prove their ability to use the device. For waived testing, we do not require observed competencies. It is tracked and monitored through our middleware. For non-waived testing competency, we have a separate document that we affix printouts to and have the associates sign when they complete in-person testing.

There is no reason why you need 2 separate documents. The important thing is you document initial training (before testing), then 6 month competency and annual competency. Part of the initial training is staff demonstration of knowledge/skill so can use direct observation, return demo, written test (your choice basically).

As a waived POCT instrument you don't even have to demonstrate you check the typical 6 elements of competency required by CLIA.

Hi Amanda,
For POC we have (always) used the same document for 'training' and for 'comp assessment' although where possibly TJC surveyor is coming from may be the form must be clear on how the form is being used (the practice/process of training and comp assessment program).

Who was asked to speak about the training/competency program including 'the form' (was it a POCC or was it a testing site supervisor or was it testing personnel)?

Same as Angie, we have check boxes at the top which declares the purpose of 'that form' for that operator. Each form once filled out and signed off by the operator and the trainer/validator/assessor is attached to the transcript or certificate with the date the online quiz was completed/passed.

If you are using one form for each operator which includes both training and comp assessment for an operator (a 'cumulative' form), even if there are 'fill in to sign off' lines at the bottom to have participants and trainers and assessors sign off & date for both training and for comp assessment, I'm wondering if that is what the inspector is referring to as 'need separate forms'. 

TJC also has an HR requirement for employee orientation; maybe that is what was considered missing? It would be separate from the training/competency checklist. I recently had a conversation with a TJC person, and she stated that training, for TJC, also includes competency, which is different from CAP who considers training and competency as 2 separate things. She compared it to driving a car--you wouldn't sign someone off to drive unless they showed that they could drive the car. We do have a return demonstration as part of our training; I consider that to be like an initial "competency". I did ask if one form was ok if it indicated whether it was for training or 6-month/initial competency, and she said that it was. I understand that the regulations are for patient safety and accurate testing, but sometimes it seems that they just look for ways to complicate things!

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Amanda Burgess
7 months ago
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