Behnke 4
Behnke 4
Behnke 4
Checklist
Lab General
Evidence of Compliance:
✓ Listing of quality indicators that include the following:
indicators for pre-analytic, analytic, and post-analytic phases AND
indicators to address the scope of testing and laboratory services AND
frequency for monitoring each indicator AND
defined benchmarks for the performance of each indicator AND
✓ Quality management data and reports for quality indicator
monitoring and evaluation, including comparison against benchmark
data, and corrective action when targets are not met
Quality Management
GEN.20325 Employee and Patient Quality Communication Phase II
The laboratory has a procedure for employees and patients to
communicate concerns about quality and safety to management.
NOTE: The investigation and analysis of employee and patient complaints and
suggestions, with corrective or preventive action as appropriate, should be a
part of the laboratory quality management program and be specifically
addressed in laboratory quality management records.
Evidence of Compliance:
✓ Records of employee and patient complaints (if any) with appropriate follow
up
Quality Management
GEN.20325 Employee and Patient Quality Communication Phase II
The laboratory has a procedure for employees and patients to communicate
concerns about quality and safety to management.
NOTE: The investigation and analysis of employee and patient complaints and
suggestions, with corrective or preventive action as appropriate, should be a part
of the laboratory quality management program and be specifically addressed in
laboratory quality management records.
Evidence of Compliance:
✓ Records of employee and patient complaints (if any) with appropriate follow up
Ask lab staff if they are aware of an employee complaint procedure and if they
would feel comfortable lodging a complaint
Alert staff to the CAP sign and contact information
Quality Management
GEN.20330 CAP Sign Phase II
The laboratory posts the official CAP sign regarding reporting of quality
concerns.
NOTE: The laboratory must prominently post the official CAP sign regarding
the reporting of quality concerns to CAP. While personnel should report
concerns to laboratory management, the laboratory must ensure that all
personnel know that they may communicate with CAP directly if they have a
concern not addressed by laboratory management, and that CAP holds such
communications in strict confidence.
In addition, the laboratory must have a policy prohibiting harassment or
punitive action against an employee in response to a complaint or concern
made to CAP or other regulatory organization regarding laboratory quality or
safety.
Quality Management
**REVISED** 07/28/2015
GEN.20335 Customer Satisfaction Phase I
The laboratory has measured the satisfaction of healthcare providers or
patients with laboratory services within the past two years.
NOTE: Satisfaction metrics are important for understanding the needs of clients
(physicians, patients, referring laboratories, nurses, etc.) to improve laboratory
services. Experience has shown that surveys are more informative if they are
conducted anonymously and allow for open ended comments. The sample size
should be adequate. A numeric satisfaction scale allows for calculation of
statistics.
Evidence of Compliance:
✓ Records of the design and results of satisfaction surveys
Quality Management
GEN.20340 Notifications From Vendors Phase II
The laboratory manages notifications from vendors of defects or issues with
supplies or software that may affect patient care.
NOTE: Notifications may take the form of product recalls, market withdrawals, or
software patches and upgrades. The laboratory should take action on those that
have the potential to affect testing results or laboratory services.
Evidence of Compliance:
✓ Records of manufacturer's recalls received AND
✓ Records of follow-up
Quality Management
GEN.20351 Adverse Patient Event Reporting Phase II
The laboratory has a procedure for reporting device-related adverse patient events, as
required by the FDA.
NOTE: When information reasonably suggests that any laboratory instrument, reagent or other
device (including all instruments and accessory devices used for phlebotomy or specimen
collection) has or may have caused or contributed to a patient death or serious patient injury, the
FDA requires hospitals and outpatient diagnostic facilities, including independent laboratories, to
report the event. If the event is death, the report must be made both to the FDA and the device
manufacturer. If the event is serious patient injury, the report may be to the manufacturer only,
unless the manufacturer is unknown, in which case the report must be submitted to the FDA.
Reports must be submitted on the FDA Form 3500A (or an electronic equivalent) as soon as
practical but no later than 10 days from the time medical personnel become aware of the event.
The FDA defines “serious patient injury” as one that is life threatening; or results in permanent
impairment of a body function or permanent damage to a body structure; or necessitates medical
or surgical intervention to preclude permanent impairment of a body function or permanent
damage to a body structure. Device malfunctions or problems that are reportable may relate to
any aspect of a test, including hardware, labeling*, reagents or calibration; or to user error (since
the latter may be related to faulty instrument instructions or design). An adverse patient event that
may have resulted from inherent limitations in an analytic system (e.g. limitations of sensitivity,
specificity, accuracy, and precision) is not reportable.
Quality Management
**NEW** 07/28/2015
GEN.20361 CLIA Certificate Type Phase II
For laboratories subject to US regulations performing patient testing subject to
CLIA, the laboratory has registered with the Centers for Medicare and
Medicaid Services (CMS) and obtained a CLIA certificate that corresponds to
the complexity of testing performed, as applicable.
NOTE: This requirement does not apply to laboratories that are part of the
Department of Defense. Laboratories located in CLIA exempt states, such as
Washington and New York, must be able to show that they have obtained a CLIA
number, when appropriate.
The CLIA regulations define a laboratory as a facility that performs testing on
materials derived from the human body for the purpose of providing information
for the diagnosis, prevention, or treatment of any disease or impairment of, or the
assessment of the health of, human beings.
Quality Management
GEN.20374 Federal/State/Local Regulations Phase I
The laboratory has a policy for ensuring compliance with applicable federal,
state and local laws and regulations.
NOTE: Applicable federal, state and local requirements may include but are not
limited to the following areas: handling radioactive materials, shipping infectious or
diagnostic materials, personnel qualifications, retention of specimens and records,
hazardous waste disposal, fire codes, medical examiner or coroner jurisdiction,
legal testing, acceptance of specimens only from authorized personnel, handling
controlled substances, patient consent for testing, confidentiality of test results, and
donation of blood. The checklists contain specific requirements on these areas.
The laboratory may obtain information on applicable federal, state and local laws
and regulations from multiple sources, including hospital management, state
medical societies and state departments of health.
Quality Management
**REVISED** 07/28/2015
GEN.20375 Document Control Phase II
The laboratory has a document control system to manage policies,
procedures, and forms that are subject to CAP accreditation.
NOTE: This includes documents relating directly to laboratory testing, as well as
others, such as quality management, safety, specimen collection, personnel, and
laboratory information systems. The document control system must ensure that only
current policies, procedures (including derivative documents such as card files and
summary charts), and forms are in use and that records for approval, review, and
discontinuance are available.
It is recommended that the laboratory maintain a control log listing all current
policies, procedures, and forms with the locations of copies. The control log may
contain other information as appropriate, such as dates when policies and
procedures were placed in service, schedule of review, identity of reviewer(s), and
dates when policies and procedures were discontinued and/or superseded.
Quality Management
**REVISED** 08/17/2016
GEN.20377 Record/Specimen Retention Phase II
Laboratory records and materials are retained for an appropriate
time.
NOTE: Policies for retention of records and materials must comply with
federal, state and local laws and regulations and with the retention
periods listed below, whichever is most stringent. For testing on minors
(under the age of 21), stricter state regulations may apply.
More specific requirements for certain laboratory records are found in
the Reproductive Laboratory Medicine Checklist
Quality Management
Two year retention:
Specimen requisitions (including the patient chart or medical record if used as the
requisition)
Accession records
Quality management records
Proficiency testing records
Quality control records
Instrument maintenance and function check records
(Laboratories may wish to retain instrument maintenance records for longer than the two-
year requirement (e.g. for the life of the instrument), to facilitate trouble-shooting)
Instrument printouts and worksheets
For data directly transmitted from instruments to the laboratory computer system via an
interface (on-line system), it is not necessary to retain paper worksheets, printouts, etc., so
long as the computer retains the data for at least two years.
Quality Management
Two year retention (continued):
Personnel Records
Competency assessment records
Training records
Patient test results and reports, including original and corrected reports,
and referral laboratory reports
Evidence of Compliance:
✓ Written policy for retention of records, specimens and slides
Quality Management
GEN.20425 Record Retention Phase II
The laboratory has a policy to ensure that all records, slides, blocks, and tissues
are retained and available for appropriate times should the laboratory cease
operation.
**NEW** 08/17/2016
GEN.20450 Correction of Laboratory Records Phase II
The laboratory follows a written policy for the management and correction of
laboratory records, including quality control data, temperature logs, and
intermediate test results or worksheets.
NOTE: Laboratory records and changes to such records must be legible and indelible.
Original (erroneous) entries must be visible (i.e. erasures, white and correction fluid are
unacceptable) or accessible (e.g. audit trail for electronic records). Corrected data,
including the identity of the person changing the record and when the record was
changed, must be accessible to audit.
Quality Management
GEN.23584 Interim Self-Inspection Phase II
The laboratory conducts an interim self-inspection and records efforts to correct
deficiencies identified during that process.
NOTE: The interim self-inspection is an important aspect of continuing education and
laboratory improvement. The use of a variety of mechanisms for self-inspection
(residents, technologists or others trained to perform inspections) is strongly endorsed.
Self inspection by personnel familiar with, but not directly involved in, the routine
operation of the laboratory section to be inspected is a best practice. Records of
performance of the interim self-inspection with correction of deficiencies is a
requirement for maintaining accreditation. The laboratory must have a record to
demonstrate that personnel responsible for each laboratory section have reviewed
the findings of the interim self-inspection.
Evidence of Compliance:
✓ Written evidence of self-inspection findings with records of corrective action
Quality Management
**REVISED** 07/28/2015
GEN.26791 Terms of Accreditation Phase II
The laboratory has a policy that addresses compliance with the CAP terms of accreditation.
NOTE: The CAP terms of accreditation are listed in the laboratory's official notification of
accreditation. The policy must include notification of CAP regarding the following:
1. Investigation of the laboratory by a government entity or other oversight agency, or adverse
media attention related to laboratory performance; notification must occur no later than two
working days after the laboratory learns of an investigation or adverse media attention. For
laboratories subject to US regulations, this notification must include any complaint investigations
conducted or warning letters issued by any oversight agency (e.g. CMS, State Department of Health,
The Joint Commission, FDA, OSHA).
2. A facility must notify the CAP as soon as it finds itself to be the subject of a validation inspection
3. Discovery of actions by laboratory personnel that violate national, state or local regulations
4. Change in laboratory test menu prior to beginning that testing or the laboratory permanently or
temporarily discontinues some or all testing
5. Change in laboratory directorship, location, ownership, name, insolvency, or bankruptcy;
notification must occur no later than 30 days prior to the change(s); or, in the case of unexpected
changes, no later than two working days afterwards. Laboratories subject to US regulations must also
notify the US Department of Health and Human Services.
Quality Management
GEN.26791 Terms of Accreditation
In addition, the policy must address:
6. Provision of a trained inspection team comparable in size and scope
if requested by CAP at least once every two-year accreditation period
7. Cooperation with CAP and HHS when the laboratory is subject to a
CAP or HHS complaint investigation or validation inspection
8. Adherence to the Terms of Use for the CAP Certification Mark of
accreditation
9. For laboratories subject to US regulations, availability, on a
reasonable basis of the laboratory's annual proficiency testing results
upon request of any person
Evidence of Compliance:
✓ Records of notification, if applicable
Quality Management
GEN.30000 Monitoring Analytic Performance Phase II
There is a written quality control program that clearly defines policies and
procedures for monitoring analytic performance.
NOTE: There must be a written overall quality control program for the entire
laboratory. It must include general policies and assignment of responsibilities.
There must be clearly defined, written procedures for ongoing monitoring of
analytic performance, including
(1) number and frequency of controls;
(2) establishment of tolerance limits for control testing; and
(3) corrective actions based on quality control data.
Quality control records should be well-organized with a system to permit
regular review by appropriate supervisory personnel (laboratory director,
supervisor or laboratory quality control coordinator).
Specimen Collection, Handling,
and Reporting
Follow a patient specimen beginning with test ordering through
patient identification, collection, labeling, transport, receipt and
processing, delivery to test area, analysis, result review, and
reporting. Determine if practice matches related policies and
procedures.
Specimen Collection, Handling,
and Reporting
**REVISED** 07/28/2015
GEN.40016 Specimen Collection Procedure Review Phase II
There are records of review of the specimen collection/handling procedures by
the current laboratory director or designee at least every two years.
**REVISED** 07/28/2015
GEN.40032 New Specimen Collection Procedure Review Phase II
The laboratory director reviews and approves all new specimen collection
and handling procedures, as well as substantial changes to existing
procedures before implementation.
NOTE: Current practice must match written procedures.
Specimen Collection, Handling,
and Reporting
GEN.40050 Distribution of Manuals Phase I
The specimen collection manual is distributed to all specimen-
collecting areas within the hospital (nursing stations, operating room,
emergency room, out-patient areas) AND to areas outside the main
laboratory (such as physicians' offices or other laboratories).
NOTE: It is acceptable for this information to be electronically available
to users rather than in book format; there is no requirement for a paper-
based specimen collection manual. Indeed, electronic manuals have
the advantage of more accurately reflecting current requirements.
Specimen Collection, Handling,
and Reporting
GEN.40100 Specimen Collection Manual Elements Phase II
The specimen collection manual includes instructions for all of the following
elements, as applicable.
1. Preparation of the patient
2. Type of collection container and amount of specimen to be collected
3. Need for special timing for collection (e.g. creatinine clearance)
4. Types and amounts of preservatives or anticoagulants
5. Need for special handling between time of collection and time received by the
laboratory (e.g. refrigeration, immediate delivery)
6. Proper specimen labeling
7. Need for appropriate clinical data, when indicated
Specimen Collection, Handling,
and Reporting
**REVISED** 07/28/2015
GEN.40125 Handling of Referred Specimens Phase II
For specimens sent to referral laboratories, the referring laboratory
properly follows all requisition, collection and handling specifications
of the referral laboratory.
NOTE: Pre-analytic variables must be closely controlled to maintain
specimen integrity. These include specimen temperature, transport time.
Evidence of Compliance:
✓ Written procedure for submission of specimens to referral laboratories,
consistent with thereferral laboratory collection and handling requirements
Specimen Collection, Handling,
and Reporting
But we don’t use referral labs….
PGS/PGD
Andrology testing
SCSA / SDFA
Sperm /Hamster Egg Penetration Assay
Specimen Collection And Labeling
**REVISED** 08/17/2016
GEN.40490 Patient Identification Phase II
The individual collecting the specimen positively identifies the patient before
collecting a specimen and labels the specimen in the presence of the patient.
NOTE: Personnel must confirm the patient's identity by checking at least two identifiers
before collecting a specimen. For example, an outpatient's name and birth date may
be used. The patient's identity should be verified by asking thepatient to identify him-
or herself, when it is practical to do so. For example, verbal verification is not necessary
if obtaining the services of a translator would delay specimen collection. The intent of
this requirement is to ensure a written, consistently followed system for correct patient
and specimen identification at the point of collection.
Evidence of Compliance:
✓ Written collection procedure, including criteria for patient identification
Specimen Collection And Labeling
**REVISED** 08/17/2016
GEN.40491 Primary Specimen Container Labeling Phase II
All primary specimen containers are labeled with at least two
patient-specific identifiers.
NOTE: A primary specimen container is the innermost container that
holds the original specimen prior to processing and testing. This may be
in the form of a specimen collection tube, cup, syringe, swab, slide or
other form of specimen storage
Examples of acceptable identifiers include but are not limited to:
patient name, date of birth, medical records number, social security
number, requisition number, accession number, unique random
number.
Identifiers may be in a machine readable format, such as a barcode.
Specimen Collection And Labeling
**REVISED** 07/28/2015
GEN.40492 Specimen Label Correction Phase II
The laboratory has a written policy regarding correction of information on
specimen labels.
NOTE: If laboratory personnel become aware of a potential error in patient
identification or other information (e.g. initials of individual collecting the specimen,
date/time of collection) on a specimen label, best practice is to recollect the
specimen. However, there may be circumstances when recollection is not possible
or practical.
The laboratory should define the circumstances under which correction of the
information on specimen labels is permitted. A record of all such corrections should
be maintained. The laboratory should investigate errors in specimen labeling, and
develop corrective action as appropriate, including education of personnel who
label the specimens.
Evidence of Compliance:
✓ Records of corrections to specimen labels and corrective action
Specimen Collection and Labelling
Evidence of Compliance:
✓ Written instructions to phlebotomists AND
✓ Training records
Specimen Transport And Tracking
**REVISED** 07/28/2015
GEN.40515 Transport Personnel Training Phase II
Transport personnel are trained in appropriate safety and packaging
procedures suitable to specimen type and distances transported, including
training for personnel involved in packaging and shipping infectious
substances. It is the laboratory's responsibility to determine whether specimens
that are to be shipped are subject to the regulations, or are exempt.
Requisitions And Specimen
Receipt/Handling/Processing
GEN.40700 Requisitions Phase II
All specimens are accompanied by an adequate requisition.
NOTE: In computerized settings, there may not be a paper requisition that is physically
attached to the specimen container.
Evidence of Compliance:
✓ Records of verification of operating speeds at least annually
Requisitions And Specimen
Receipt/Handling/Processing
**REVISED** 08/17/2016
GEN.41042 Refrigerator/Freezer Temperatures Phase II
Refrigerator/freezer temperatures are checked and recorded daily using a
calibrated thermometer.
NOTE: This checklist requirement applies to refrigerators/freezers containing reagents
or patient/ client specimens.
“Daily” means every day (7 days per week, 52 weeks per year).
The laboratory must define the acceptable temperature ranges for these units. If
temperature(s) are found to be outside of the acceptable range, the laboratory
must record appropriate corrective action, which may include evaluation of
contents for adverse effects.
Results Reporting And Referral Of
Testing
**REVISED** 07/28/2015
GEN.41303 Patient Confidentiality Phase II
The laboratory ensures that internal and external storage and
transfer of data maintains patient confidentiality and security.
NOTE: Written procedures must address patient confidentially during
transfer of data to external referral laboratories or other service
providers. This must include cloud based computing (e.g. for storage of
confidential data), as appropriate
The laboratory must audit compliance with the procedures at least
annually.
Evidence of Compliance:
✓ Records of patient privacy audit for compliance with the Health Insurance
Portability and Accountability Act (HIPAA)
Results Reporting And Referral Of
Testing
**REVISED** 07/28/2015
GEN.41096 Report Elements Phase II
The paper or electronic report includes the following elements.
1. Name and address of testing laboratory (see note below)
2. Patient name and identification number, or unique patient identifier
3. Name of physician of record, or legally authorized person ordering test, as appropriate
4. Date of specimen collection, and if appropriate, time of collection
5. Date of release of report (if not on the report, this information should be readily accessible)
6. Time of release of report, if applicable (if not on the report, this information should be readily
accessible)
7. Specimen source, when applicable
8. Test result(s) (and units of measurement, when applicable)
9. Reference intervals, as applicable
10. Conditions of specimen that may limit adequacy of testing
Results Reporting And Referral Of
Testing
GEN.41067 Content/Format Report Review Phase I
An individual meeting CAP laboratory director qualifications reviews
and approves thecontent and format of paper and electronic
patient reports at least every two years.
Evidence of Compliance:
✓ Records of report error notification and corrected report
Results Reporting And Referral Of
Testing
**REVISED** 08/17/2016
GEN.41310 Corrected Report Phase II
All corrected reports of previously reported, incorrect patient results are identified as
corrected, and both the corrected and original data are clearly identified as such.
NOTE: As clinical decisions or actions may have been based on the previous report, it is
important to replicate previous information (test results, interpretations, reference intervals)
for comparison with the corrected information. The previous information and the corrected
information must be identified as such, and the original data must be present in the
corrected report (for paper reports), or linked electronically or logically to the corrected
information (in electronic reports).
Displays in an electronic medical record (EMR) downstream from the laboratory should
include the original report as well as the corrected report. The report elements listed in
GEN.41096 should be included in the EMR.
The correction should add explanatory language if an explanation would be helpful to the
user. For example, a comment about transport or sample storage conditions uncovered
post-analysis can help frame an original, invalid result.
Results Reporting And Referral Of
Testing
GEN.41312 Multiple Corrections Phase II
When there are multiple sequential corrections of a single test result, all
corrections are referenced in sequential order on subsequent reports.
**REVISED** 07/28/2015
GEN.43033 Custom LIS Phase I
Customized software, and modifications to that software, are
appropriately documented and records allow for tracking to
identify persons that have added or modified that software.
**NEW** 07/28/2015
GEN.43040 LIS Policy and Procedure Approval Phase II
The laboratory director or designee reviews and approves all new
LIS policies and procedures, as well as substantial changes to
existing documents before implementation.
Laboratory Computer Services
**REVISED** 07/28/2015
GEN.43055 Computer System Training Phase II
There are records for training of all users of the computer system
initially, after system modification, and after installation of a new
system.
**REVISED** 07/28/2015
GEN.43325 Public Network Security Phase II
If the facility uses a public network, such as the Internet as a data
exchange medium, there are network security measures in place to
ensure confidentiality of patient data.
Evidence of Compliance:
✓ Written policy defining mechanism for data protection
Laboratory Computer Services
Evidence of Compliance:
✓ Records of validation of calculated test results
Laboratory Computer Services