ISO

October 20, 2008

DNV Healthcare and Labs - a correction

By Sten Westgard, MS

In an earlier post about DNV Healthcare and Laboratory accreditation, I inadvertently implied that only CAP or COLA accreditation would be accepted by DNV. I should have been more precise in my listing of possible accreditation agencies for laboratories; that was a mistake on my part. I didn't intend to imply that only those two accreditations would be accepted by DNV. My apologies for my imprecise statement.

The important point is that DNV currently will not accredit labs. If you move to DNV Healthcare to accredit your hospital, you will need to have another agency accredit your laboratory.

Again, I am sorry to have given the wrong impression. Thanks to Margaret Peck of Joint Commission for alerting me to the problem. The original post has been corrected as well.

Sten

October 06, 2008

DNV Healthcare - Hospitals now, Labs later?

After some follow-up, we need to note that DNV Healthcare has only been deemed by CMS for accrediting hospitals. They did not get deemed status for laboratory accreditation.

In other words, they cannot inspect or accredit laboratories. Any hospital that switches to DNV Healthcare will need still need to to accredit their lab by some other agency. [In an earlier version of this post, I inadvertently implied that only CAP or COLA accreditation would be accepted by DNV. That was a mistake on my part. I didn't intend to imply that only those two accreditations would be accepted by DNV. My apologies for my imprecise statement. The important point is that DNV currently will not accredit labs. ]

Whether deemed status for laboratory accreditation is in the future for DNV Healthcare is anyone's guess. It took years of battling for DNV to achieve the hospital deeming authority. Getting to laboratory deeming authority may require years more.

Still, this reality may make it less attractive for JC accredited hospitals to switch. If you currently use JC for both your laboratory and hospital accreditation, switching to DNV will require you to switch to COLA or CAP as well. Two switches for the price of one?

CAP may be a better fit with DNV's hospital accreditation, since CAP offers an ISO 15189 approach and DNV is going to stress ISO 9001 as part of the accreditation. But COLA has also been using a lot of ISO terminology and quality systems approach in their accreditation.

October 03, 2008

The New Kid on the Block

Sten Westgard, MS

The game of accreditation agencies hasn't changed much over the last 40 years: Joint Commission, CAP, COLA. Laboratories didn't have many other choices.

Now there's a new kid on the block.

CMS recently approved DNV Healthcare as a new hospital accreditation organization. DNV's hospital accreditation program has met all the CMS requirements to deem hospitals in compliance with the Medicare Conditions of Participation. The DNV program is called NIAHOSM (National Integrated Accreditation for Healthcare Organizations). [ DNV stands for Det Norske Veritas which is a Norwegian-based company that provides accreditation, certification, risk management and other services to many industries. What is it about Scandinavians, quality, and regulations?]

What's more interesting than just the entry of a new player into the accreditation market is their approach. NIAHO is not another compliance-oriented program - participation in this accreditation program requires the hospital to seek and achieve ISO 9001 certification. So hospitals will have to be accredited by NIAHO and certified in ISO 9001.

Here's the schedule DNV proposes for accreditation and certification:

  • Year One: NIAHO Accreditation Survey and ISO 9001 Pre-assessment Survey
  • Year Two: NIAHO Accreditation Survey and ISO 9001 compliance or Certification Survey
  • Year Three: NIAHO Accreditation Survey and ISO 9001 Periodic Survey
  • Year Four: NIAHO Accreditation Survey and ISO 9001 Periodic Survey
  • Year Five: NIAHO Accreditation Survey and ISO 9001 compliance or Re-Certification Survey
  • Year 6 through Year 8 and Beyond: Continue to repeat Year 3 through Year 5.

DNV will conduct annual unannounced surveys on hospitals. That's a significant change right there.

DNV's NIAHO is different than CAP's nascent ISO 15189 program. CAP is offering an ISO certification on top of the usual certification. That is, you have to do the usual CLIA-based certification, but you can add ISO 15189 on top of it. If you choose DNV Healthcare, you'll have to seek ISO 9001 certification as part of the process. Compliance alone is not a DNV option.

We have yet to see what kind of specific laboratory rules DNV Healthcare will provide. As with a lot of the ISO standards, specifics are often hard to find. Many ISO standards provide broad goals without technical specifics, leaving it up to the managers to adapt and apply the rules. Will there be Checklists? Tracers? Something else? So far, we don't know.

Obviously, whatever DNV Healthcare applies will have to be in compliance with CLIA regulations. But how will ISO 9001 and CLIA minimums mix? Will DNV require more from hospitals and laboratories than JC or CAP?

The even bigger question is - will DNV Healthcare compete on cost, quality or another feature? The cynic in us wonders if more competition will drive down prices and possibly sacrifice quality. The optimist in us thinks it would be interesting to see an accreditation body make excellence, instead of compliance, its competitive strategy.

Stay tuned.

February 05, 2007

An Open Letter: Mitigating the Future Risk of Poor Quality Laboratory Tests

Originally posted April 21st, 2006
To:
    Those who will influence the future quality of laboratory testing
CLSI Area Committee on Evaluation Protocols
CLSI Subcommittee on Establishment of Manufacturer’s QC Recommendations
CLSI Subcommitee on Laboratory Quality Control Procedures

I want to call your attention to an article on “The Quality of Laboratory Testing Today” that was published in the American Journal of Clinical Pathology in March 2006 (v125:pp343-354). This article was prepared for the “QC for the Future” workshop, which was held in March 2005 in Baltimore. Because you attended this conference and/or are involved in the ongoing project work to develop QC for the Future, I hope you will have some interest in the results of this study.

I take the unusual step of calling your attention to this study to ensure that the CLSI committees charged with the responsibility for future QC practices are challenged to consider the current analytical quality of laboratory tests in quantitative and measurable terms. Emerging laboratory quality indicators, such as being proposed by IQLM, focus mainly on pre-analytic and post-analytic variables and pay little attention to analytical quality. The results of this study indicate that the analytical quality of laboratory tests is still a serious problem that requires ongoing improvements in analytical methodology and laboratory QC.

In considering QC for the Future, CLSI seems to be driven by the ISO guideline for manufacturers (ISO 15198: Validation of manufacturer’s recommended procedures for quality control) which recommends a risk analysis approach to identify sources of variability that ideally should be eliminated by careful design of the analytic system. In Section 4 on “Quality control recommendations,” the following guidance is given to manufacturers:

  • Section 4.1: “Residual risks should be minimized by the manufacturers’ recommended quality control procedures. The quality control procedures shall include a method of detection (e.g., quality control material, electronic monitoring system, or on-board chemical control) and acceptability criteria that will determine when a critical failure occurs or a means to determine the acceptability criteria. Limitations of the quality control procedure shall be identified and described in the instructions for use.”

While that guidance is fine and good for manufacturers, I want to remind you of ISO 15189 document (Medical laboratories – Particular requirements for quality and competence), which provides guidance to laboratories. In discussing examination procedures (i.e., measurement procedures), laboratories are given the following specific guidance:

 

  • Section 5.5.4: “Performance specifications for each procedure used in an examination shall relate to the intended use of that procedure.”

  • Section 5.6.1: “The laboratory shall design internal quality control systems that verify the attainment of the intended quality of results.”

Note first the need to define the “intended use” or “intended quality” in order to implement examination procedures with appropriate precisian and accuracy, as well as the appropriate QC design.

Note first the need to define the “intended use” or “intended quality” in order to implement examination procedures with appropriate precision and accuracy, as well as the appropriate QC design. Second, the guidance for internal QC design doesn’t say mitigate or reduce or minimize the risk of not attaining the intended quality of results - it says to verify the attainment of the intended quality of results. The laboratory is responsible for verifying that the intended quality is achieved, not just minimizing the risk of poor quality.

This objective of verifying the attainment of intended quality of results can be achieved by designing a statistical QC procedure to account for the quality required for the test and the precision and accuracy observed for the measurement procedure, as described in CLSI document C24-A3 (Statistical Quality Control for Quantitative Measurement Procedures: Principles and Definitions). Note that the ISO guidance to manufacturers identifies statistical QC as an example “method of detection,” thus statistical QC is an appropriate way to monitor residual risks, as well as to verify the attainment of the intended quality of test results.

As you develop recommendations for QC for the Future, please keep in mind that statistical QC is still a valuable tool to verify the attainment of the intended quality of test results. There seems to be a predisposition today to try to avoid the application of statistical QC in laboratories, or reduce the amount of QC performed, as evidenced by the original CMS proposal for “equivalent QC procedures.” It is important to set the objective as performing the right amount of QC to detect medically important errors, which depend on the quality required for the test and the precision and accuracy observed for the measurement procedure. In any approach you recommend, make sure you can account for intended quality and verify its attainment in routine laboratory operations. Otherwise, we run the risk that the quality of laboratory testing in the future will be worse than it is today.

 

Reference:  Westgard JO, Westgard SA. The Quality of Laboratory Testing Today: An assessment of Sigma metrics for analytic quality using performance data from proficiency testing surveys and the CLIA criteria for acceptable performance. Am J Clin Pathol 2006;125:343-354.

We invite your comments on this open letter. (Please note that we will moderate all submissions to ensure that commentary is substantive).

            
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