Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System
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Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System
Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 1 of 26 Quality Assessment Manual for Rapid HIV Antibody Tests A. Introduction and Background 1. Purpose This document provides guidance on quality assessment (QA) practices for sites using or planning to use rapid test kits to detect antibodies to the human immunodeficiency virus (HIV) waived under the Clinical Laboratory Improvement Amendments of 1988 (CLIA) regulations. Quality Assessment is a series of planned, step-by-step activities that ensure testing is being carried out correctly, results are accurate, and mistakes are found and corrected in a timely fashion to avoid adverse outcomes. These activities must be followed during the entire testing process, from the time a person agrees to be tested until after the test results are reported. 2. B. Elements of a QA program a. Organization of the QA program b. Testing personnel 1) Training 2) Competency c. Process control 1) Before testing 2) During testing 3) After testing d. Proficiency Testing e. Documents and records f. QA evaluation and troubleshooting Organization of the QA Program 1. Site Coordinator Each organization must appoint a site coordinator responsible for providing oversight of the rapid HIV testing program and ensuring that the necessary personnel and supplies are available. This individual is responsible for the following activities: a. Verify the accuracy of the testing process by reviewing QC logs on a monthly basis. b. Ensure that procedures (step-by-step instructions) are downloaded from the Michigan Regional Laboratory website and placed into a procedures manual. c. Ensure that all procedures are reviewed annually by the laboratory director and made available to all personnel involved in testing. d. Ensure that all personnel know how to perform each procedure. e. Create mechanisms for communication so that personnel are ` informed about problems when they are identified. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 2 of 26 f. g. Have a CLIA Certificate of Waiver if performing only waived rapid HIV antibody or other waived tests, or be included under an organization with a CLIA exception for limited public health or mobile testing. Implement mechanisms developed by the Michigan Regional Laboratory system to ensure that the site meets all applicable Federal, State, and other regulatory requirements. This includes requirements for biohazard and chemical safety. 2. Verification of the testing process Before offering the test to clients, each site must ensure that the entire testing process works as planned. The laboratory must ensure that: a. Personnel have been trained and are able (competent) to perform their assigned tasks, b. Test kits work as expected (e.g., give accurate results for a referenced panel of nonreactive, weakly reactive, and reactive specimens), c. Logistics are in place for providing confirmatory testing of preliminary positive test results and handling biohazardous waste. 3. Written testing instructions Testing personnel must follow instructions for each test. Step-by-step written instructions must be made available to all personnel performing testing. Procedures must be downloaded from the Michigan Regional Laboratory website, signed by the laboratory director, placed into a procedures manual by the site coordinator, and reviewed by staff on an annual basis. Test procedures must include the following information: a. The manner how clinic staff provide required pretest information to test subject. b. Instructions for maintenance of sufficient supplies of unexpired test and control kits and adherence to manufacturer’s temperature ranges for storage and testing areas. c. Specimen collection instructions, test performance, interpretation criteria, reporting test results, and resolution of problems (troubleshoot) before reporting results. d. Quality control criteria such as the requirement to check performance of new test kit lots and shipments, frequency of routine QC testing, and actions to take if controls do not work. 4. Site-specific written procedures Written site-specific procedures describing other operations must be made available to help ensure personnel know how to perform additional QA tasks: a. Personnel training and competency procedures that describe how to train and assess competency of employees. Competency Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 3 of 26 b. c. d. e. assessments of all testing personnel are to be performed in the following timeframe: 1) Initial competency upon completion of initial training. 2) Competency performed six (6) months after initial training. 3) Competency performed twelve (12) months after initial training and annually thereafter. Safety procedures that describe how to use gloves and other personal protective equipment (PPE); safely dispose of biohazard waste, including used lancets or other sharps used for blood collection. Reporting criteria that describe how to report results including confirmatory results, if applicable. Confirmatory testing criteria that describe how to refer specimens or test subjects for confirmatory testing; manage test results. Documentation criteria that describe how to keep records and timelines for review and destruction when outdated. 5. Testing Personnel Qualifications There are no Federal requirements for who can perform waived tests; however, it is recommended that certain qualities be considered when selecting personnel to perform rapid HIV antibody testing. The following list of desirable qualities is based on practical considerations and expert opinion: a. Sincerity and commitment – A dedication to performing testing accurately, according to defined procedures. b. Literacy – The ability to read instructions and record results is critical. c. Organizational skills – The level of skill necessary will depend on the number and complexity of tasks an individual performs in the testing process. If test volume is high and the individual performing testing is doing several tests or managing several other tasks simultaneously, organizational skills can be critical. d. Decision-making skills – Testing personnel should be able to interpret results and be able to recognize and handle problems that might arise. e. Communication skills – If the person performing the test also is the one who shares results or other information with the person being tested, being able to communicate clearly is important. 6. Components of Training Personnel must be fully trained on how to perform their assigned tasks and responsibilities. Training must be documented for each individual; using training checklists available on the regional laboratory website (www.michigan.gov/mdchlab). The key components to include in a training program are: Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 4 of 26 a. b. c. d. 7. The importance of QA and the elements of the site’s QA program How testing is integrated into the overall program Steps to perform the entire test procedure from specimen collection to reporting of results. 1) Read the instructions for performing the test. 2) Watch someone perform the test or view a video of someone performing the test. 3) Practice performing the test with positive and negative control materials. 4) Practice performing the venipuncture, finger-stick and/or oral fluid collection procedure. 5) Review the procedures and forms on how to document testing. The use and importance of blood and body fluid precautions and biohazard safety. (See Biohazard Safety/Universal [Standard] Precautions.) Competency assessment a. Frequency of competency assessments. 1) Initial Comptency: Before a trainee is permitted to perform testing unsupervised for the first time, his or her ability to conduct the test should be demonstrated and documented. 2) Six Month Competency: This assessment must be carried out six months after initial training. 3) Annual Competency: This assessment must be carried out 12 months after initial training and annually thereafter. b. Competency assessment must include direct observation of all steps of the testing process. The laboratory director, site coordinator, or other testing personnel trained in the procedure must perform the assessment. c. To assess competency, personnel must be directly observed as they perform the following steps: 1) Check and record the temperatures of the testing and storage areas. 2) Set up the testing area, label the test device and prepare control and test results log sheets. 3) Run the external controls and record results. 4) Perform specimen collection and handling. 5) Perform the test procedure on a client/patient. If such observation will interfere with the actual client-provider interactions, test performance may be observed on a volunteer. 6) Evaluate the use of Standard (Universal) Precautions and procedures for biohazard and sharps (e.g., lancets, needles) waste disposal. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 5 of 26 7) 8) 9) 10) 11) C. Appraise the individual’s ability to interpret results. This might include using previously used test devices or pictures of devices that show nonreactive, weakly reactive, reactive, and invalid results. Review test records and quality control results for proper documentation. Observe oral reporting of results to a test subject (if trainee’s responsibility). If confirmatory test specimens are collected on-site, observe the collection and handling of venous blood and/or oral fluid specimens for referral. If the frequency of reactive rapid test results is low, the trainee should be observed collecting blood and/or oral fluid from a volunteer staff member and demonstrate how it is processed for confirmatory testing. Verify that confidentiality is maintained. Process Control Process control refers to the activities and techniques that are carried out to ensure that the testing procedures are performed correctly, the environment is suitable, and the test kit works as expected to produce accurate and reliable results. 1. Before Testing: The laboratory must ensure that the conditions at which the test kits and controls are stored and tests are performed are suitable, the test area and the test subject are prepared, and the test is working appropriately. a. Check storage and room temperatures daily 1) Test and control kits storage: Test kits and controls must be stored within the temperature ranges specified by the manufacturer. These ranges vary with different test kits. Place thermometers in refrigerators and monitor areas where kits are stored. Check and record temperatures of the storage area on a log sheet each day testing is performed. NOTE: “Min-Max” thermometers maintain a record of the highest and lowest temperature recorded during the observation period and can be very helpful to monitor storage conditions. 2) Temperature control - testing area: The temperature in the area where the test will be performed must be within the range specified by the manufacturer. For testing carried out in the field (not onsite), monitor the temperature of the test and control kits in their portable storage containers and check the temperature where testing will be performed if it appears to be outside the specified range. 3) When temperatures are out of range: If the temperature falls outside of the specified range, take action as needed to Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 6 of 26 b. c. d. e. adjust the temperature. If there are doubts about the testing area temperature or whether test kits have stayed within the appropriate temperature range, run external controls as described in the QC section to ensure that test devices are in satisfactory condition. Check inventory and test kit lots, as needed Inventory control: The laboratory must establish procedures to ensure adequate supplies of unexpired test kits, controls, and other materials. These steps must include: 1) Rotating inventory to ensure the oldest kits are used first. 2) Adhering to shelf life limitations defined by the manufacturer. a) Test or control kits should never be used beyond their expiration dates. b) Discard any test kits that are past their expiration date. c) Once control vials are opened, their shelf life is reduced. The laboratory must record on the control vial the date it is opened and the date after which the opened control expires. NOTE: It is useful to document on a log sheet when test and control kits are received, their lot numbers and their expiration dates. Receive request for testing Provide HIV/AIDS test information to the test subject Manufacturers of rapid HIV tests provide a subject information pamphlet that must be given to each person prior to performing the HIV rapid test, in accordance with FDA sales restrictions. Each site may provide additional information. For further details, see the CDC website http://www.cdc.gov/hiv/pubs/rt-counseling.htm and applicable State or local rules. Set up test area and label test device. 1) Setting up the testing area: The testing area must be prepared according to the specific site procedure, which includes directions for: a) Setting up the workspace and organizing supplies, b) Ensuring lighting is adequate to interpret rapid HIV test results. As a rule of thumb, lighting is sufficient if standard newsprint held next to the test device can be read without difficulty. c) Preparing the test kit components and controls, d) Completing report forms. NOTE: Test kits, test devices, and controls should be brought to room temperature before performing the test. 2) Specimen identification and labeling the test device Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 7 of 26 f. The laboratory must correctly identify each person to be tested and to ensure that proper identification of the specimen is maintained throughout the testing process. Label components of the test (e.g., vials of developer solution, test device, and test result logs) with the name or identifying number of the person being tested after collecting the specimen. Perform external QC according to the manufacture’s and the site’s instructions 1) Waived rapid HIV tests include two types of QC. a) Internal controls are controls built into each testing device and verify that the specimen was adequate and the solution flowed through the device as intended. b) External controls are known reactive and nonreactive liquid samples (controls) that are either provided in each test kit or purchased separately from the manufacturer. External controls are surrogate samples used to evaluate the integrity of the test system and verify that the person conducting the test has performed it correctly. 2) External quality control To verify that test devices accurately detect antibodies to HIV, external positive and negative controls must be tested on a weekly basis. The test kit manufacturer provides external controls containing HIV antibody-negative (nonreactive) and positive (reactive) human plasma compatible with its test system. Before using external controls from a different source, contact the test manufacturer to verify they are compatible with the specific test system being used and evaluate them in the testing site. Controls may be ordered separately from the test kit depending on the manufacturer. 3) Run external controls according to the manufacturer’s instructions Follow the manufacturer’s instructions for proper use of negative and positive controls. External controls must be run under the following circumstances: a) Each week of testing (Monday – Friday/Saturday) before any client samples are tested. b) By each new operator prior to performing testing on clients/patients for the first time. c) When opening a new test kit lot (a test kit lot is defined as boxes of test devices that have the same lot number label on the outside of the box). Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 8 of 26 d) 2. Whenever a new shipment of test kits is received (even if it is the same kit lot number in current use). e) If the temperature of the testing area falls outside of the range specified by the manufacturer. 4) Incorrect control results: troubleshooting If external controls do not give the correct result, steps must be taken to determine the source of error by following the external control kit troubleshooting instructions. Troubleshooting steps help determine if the source of error is the test kit, the external controls, or operator technique. When necessary, contact the manufacturer for assistance and/or to report defective test system components. Document all steps take to resolve the problem using Michigan Regional Laboratory System form RLF-20 (Continuous Quality Improvement Form). During Testing: This phase of the testing process involves running the test and interpreting the results. Activities during testing include collecting the specimen, performing the test, interpreting the internal control and client/patient test results, and following biohazard safety guidelines a. Follow biohazard safety precautions b Collect the blood or oral fluid specimen Follow the written procedure for whole blood or oral fluid specimen collection, labeling, and handling. Further information on collecting blood by skin puncture can be found in Procedures and Devices for the collection of Diagnostic Capillary Blood Specimens; Approved Standard – Fifth Edition.5 c. Perform the test and interpret the results Follow the manufacturer’s step-by-step instructions for performing the test and interpreting the results. Interpreting rapid HIV tests requires good eyesight and adequate lighting. The test should be read from a comfortable distance without manipulating the test device. If supplemental lighting, such as a flashlight, is necessary, care should be taken to avoid shadows or reflections that might lead to an incorrect interpretation of the test. (A flashlight should never be used to shine light through the test device to accentuate the test result.) Test results can be one of the following: 1) Nonreactive (report as negative) 2) Reactive (report as preliminary positive) 3) Invalid (the test result is inconclusive and cannot be interpreted) d. Internal controls Each rapid test device includes a built-in (internal) control. Internal controls in test devices vary among test manufacturers, therefore, it is important to read and understand the manufacturer’s explanation Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 9 of 26 e. f. g. 3. of the location and functioning of internal controls for the test being used. Evaluating internal control results Internal control results are evaluated with every test. If the internal control does not produce the expected result, the test result for the client is invalid, cannot be reported, and the test must be repeated. If a second invalid result occurs, external controls should be evaluated as described below before repeating the test a third time. Running external controls to troubleshoot invalid or suspicious results If repeatedly invalid test results or an unexpectedly high number of reactive results are obtained during testing sessions, external controls should be run to help find out if problems are due to faulty test kits, improper testing procedures, or something to do with the patient specimen. It is important to run the positive and negative controls whenever two consecutive invalid test results are obtained on a person being tested. If the external control results are valid, the problem may be due to interfering substances in the client’s specimen. Biohazard safety/Universal (Standard) precautions All specimens and materials contacting specimens must be handled as if they are capable of transmitting an infectious organism. Each site must ensure that the Occupational Safety and Health Administration (OSHA) bloodborne pathogens standards are met. Persons doing the testing must know how to safely handle potentially infectious specimens. Also, according to Universal Precautions, all human blood and certain body fluids should be treated as if know to be infectious for HIV, hepatitis B virus, hepatitis C virus, and other bloodborne pathogens. Sites must have available, and follow procedures for, biohazard safety to include instructions for the use of gloves, hand washing, sharps and biohazardous waste disposal, spill containment and disinfection. A different pair of gloves should be worn for collecting a specimen from each person being tested. Used gloves should be handled as biohazardous waste. For further details on these precautions see the manufacturer’s package insert, OSHA regulations and guidelines on Universal and Standard Precautions.2,6,7,8 After Testing a. Document results b. Report results to test subject: Reporting procedures must describe how results are provided to the person being tested (verbal and/or written results) and how results are documented in the person’s chart and in the test result logs. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 10 of 26 c. d. e. Collect, process, and transport confirmatory test specimens or refer clients for followup. Whenever a rapid HIV test result is reactive (preliminary positive), follow-up testing must be performed to confirm that the person being tested is infected with HIV. Therefore, each site must have established procedures for referral of either test specimens or persons being tested for confirmatory testing when rapid test results are reactive. Collecting confirmatory specimens on-site may improve follow-up, since some clients may not go elsewhere for the testing or to obtain results. However, if the site is not able to collect confirmatory test specimens, a procedure must be in place for referring clients to another site to obtain this testing. NOTE: If the client refuses confirmatory testing, this should be documented in the test results log. Clean up and dispose of biohazardous waste Manage confirmatory test results 1) If specimens are collected on-site, the site must establish procedures describing: a) How to collect, label, process, store, and document specimen transfer. Note: It must be indicated on the referral laboratory test requisition that the specimen is from an individual who has had a reactive rapid HIV test result. b) Transportation of the confirmatory test specimens to the site where they will be tested. c) How confirmatory results are obtained to give to the client/patient. d) How to report confirmed positive HIV results to your state health department, as required. 2) Confirmatory testing protocols for a reactive rapid HIV test a) All reactive (preliminary positive) rapid test results must be followed up with an approved supplemental test, such as a Western blot, an immunofluorescent assay (IFA) or an RNA 9,10 test, for confirmation. b) Confirmatory testing can be done on blood (plasma, serum, or dried blood spots) or oral fluid specimens, though blood specimens have higher accuracy than oral fluid specimens. Urine should not be used for confirmatory testing because of its lower sensitivity. Performing an enzyme immunoassay (EIA) screening test prior to a confirmatory test is optional. Even if the EIA is nonreactive, the specimen must proceed to confirmatory testing with a Western blot, IFA, or RNA. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 11 of 26 3) 4) 5) D. Follow-up testing for a negative confirmatory result A negative confirmatory test result indicates one of three possibilities: specimen mix-up, early seroconversion (too early for antibody detection by Western blot or IFA), or false positive rapid test result. If the initial confirmatory test is negative, it is recommended that: a) For blood specimens, a repeat confirmatory test with a new blood specimen should be done to rule out specimen mix-up or early infection. b) For oral fluid specimens, a repeat confirmatory test with a blood specimen should be done because the Western Blot test is less accurate with oral fluid than it is with blood. Follow-up testing for an indeterminate confirmatory test result a) If the initial confirmatory test was conducted on blood, the person should be advised to return for repeat confirmatory testing in one month or a test for HIV RNA may be performed. � If the initial confirmatory test was conducted on oral fluid, a repeat confirmatory test (Western blot, IFA, or RNA) should be conducted using a blood specimen. See CDC’s Revised Guidelines for HIV Counseling, Testing and Referral found at http://www.cdc.gov/mmwr/preview/mmwrhtml/rr50 19a1.htm Handling confirmatory test result discrepancies Procedures should describe how to handle result discrepancies when the rapid test result was reactive and the confirmatory test was negative or indeterminate. If the laboratory providing confirmatory testing performed an EIA test only and reported a nonreactive or negative result, the testing site should contact the confirmatory testing laboratory and request a Western blot, IFA, or RNA test. If the original specimen is not available, a new specimen will need to be collected to be used for confirmatory testing. External Proficiency Testing External Proficiency Testing (PT), an evaluation of the testing process by an impartial outside source, is a way to evaluate how well testing is being performed and whether it is being performed reliably. PT can help to identify existing or potential problems. Moreover, information gathered can provide an educational tool to improve performance. The laboratory must participating in a proficiency testing (PT) program. An overall score 80% is required for successful performance. Any incorrect PT results must be investigated and the source of the Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 12 of 26 error must be determined. The investigation must be documented using forms available on the Michigan Regional Laboratory System website (RLF-7, Continuous Quality Improvement-Investigation of Unsatisfactory PT Performance or RLF -13 – Continuous Quality Improvement-Investigation of Ungraded Proficiency Testing). E. Documents and Records 1. Overview One of the hallmarks of an adequate QA program is comprehensive documentation. Sites using waived rapid HIV tests must have policies and procedures describing what QA records are required and how and when they are reviewed, stored, and destroyed. The site coordinator must review QA records on a quarterly basis. QA records must be retained for two years. QA records include the following documentation (these forms are available on the Michigan Regional Laboratory website–see Appendix 1). a) Training documentation b) Temperature logs: these must include a daily record of the refrigerator and/or room temperature where test kits and external controls are stored and the temperature of the testing area. Thermometers must be placed in each location. Laboratory grade thermometers, which can be purchased from medical or laboratory supply houses, are recommended and their accuracy checked periodically (e.g., every six months) by comparison with another thermometer. c) External control result logs: these must include the date and time of control testing, lot number and expiration date of the test kit, lot number and expiration date of the controls, control results, and corrective action taken if control results are unacceptable. Control records must be kept in the order in which they were completed so they can be easily compared with the test records. This will help find answers if there are questions about testing performed within a specific time frame. d) Test result logs: these must include the date and time of testing, an identifier for the person being tested, a test kit lot number and expiration date, test result, action taken if the result was invalid, identification of the person who performed the test, whether confirmatory testing was requested, including the type of specimen sent for confirmation (e.g., oral fluid, blood), and the confirmatory test results when they are available. If more than one person is conducting testing, there should be a mechanism to chronologically link the test record log sheets to detect problems, such as invalid results occurring repeatedly with the same test kit lot number. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 13 of 26 e) F. Specimen transfer logs: these must be used to track the transfer of specimens for confirmatory testing and the document when confirmatory test results are received. QA Monitoring and Troubleshooting 1. Overview Each site must establish protocols to identify key QA measures that are routinely monitored and evaluated and have corresponding troubleshooting procedures to resolve problems that may occur. Significant problems, especially those concerning the accuracy of the rapid HIV test in use should be immediately reported to the site coordinator and the laboratory director. The local or state HIV test coordinator and the manufacturer should be notified when appropriate. 2. QA monitoring Site coordinators must routinely monitor and evaluate QA measures. Some suggested measures include the following: a. Number of tests or external control materials that expired before use or occurrences of expired tests used for diagnostic or QC purposes b. Number of days tests or QC materials were stored or used outside of temperature specifications c. Frequency of external QC testing compared with test site procedure d. Frequency of invalid or incorrect results for external control testing or client testing e. Proportion of negative and preliminary positive patient/client results f. Proportion of reactive rapid test results confirmed positive of all reactive rapid test results 3. Troubleshooting Troubleshooting procedures must be available to all testing personnel and include the following: a. When to discontinue testing, for example, when the external control results are unacceptable as described in the package insert b. How to take corrective action, or an action taken in response to a problem, such as contacting the manufacturer when the external control results are unacceptable and following the advice provided c. How to document problems and actions taken, such as a logbook where problems and corrective actions can be recorded d. How to verify the corrective actions taken addressed the problem 4. Expired tests or QC materials On a monthly basis, the site coordinator must verify that test kits and external controls are used before they reach the expiration date specified by the manufacturer. If it is determined that expired test kits or controls have been used and client results have been reported, the laboratory Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 14 of 26 5. 6. director will be notified. The following actions will be taken by the site coordinator if it is determined that expired test kits or external controls expire have been used for testing: a. Inventory management, ordering procedures, and storage procedures will be reviewed to ensure that all materials currently in stock have a reasonable shelf life b. Instruct staff that the use of expired test kits and control materials is not permitted under any circumstances. c. If needed, adjust ordering procedures, revise QA protocols, or retrain staff. Tests or QC materials stored or used when temperatures are outside of specifications stated by the manufacturer On a monthly basis, the site coordinator will verify that test kits and external controls are used and stored within of the manufacturer’s temperature specifications. When it is verified that test kits and/or controls are stored outside these temperature limits, the laboratory director will be notified and the following actions taken: a. Determine the cause for out-of-range temperature(s) and ensure corrective measures have been taken. b. Confirm whether tests were used in out-of-range temperatures, if procedures were followed, and if testing personnel were aware of temperature conditions. c. Determine whether external QC tests were performed to verify the test could be performed and correctly interpreted. d. If needed, modify procedures and retrain staff on temperature control specifications. Incorrect or invalid QC test results On a monthly basis, the site coordinator will evaluate the accuracy of quality control results. The site coordinator will ensure that only unexpired controls are used for testing, all external and internal controls yield the expected results, and testing personnel are properly evaluating QC results before client samples are tested. The laboratory director will review all QC results on a quarterly basis. The laboratory director should take the following steps when incorrect or invalid QC test results are observed: a. Evaluate procedures for testing external controls and review records of control results. b. Perform troubleshooting procedures in accordance with the manufacturer’s control kit instructions to determine the source of the incorrect or invalid result. c. If test devices used with valid external control materials provide invalid or incorrect results, discontinue testing and contact the manufacturer. d. Resume testing only after tests on external control materials provide correct results and document corrective actions. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 15 of 26 e 7. 8. If needed, modify the QA protocol and/or retrain staff on appropriate testing of external controls. Invalid patient/client test results On a quarterly basis, the site coordinator will determine the validity of client test results by comparing the results of the rapid HIV test to the results of confirmatory testing. A minimum of ten (10) client charts will be evaluated. The laboratory director must review the results of this audit. The laboratory director should consider the following actions when invalid client test results are observed: a. If possible, observe specimen collection, testing, and result interpretation to confirm test procedures are performed correctly. b. Confirm the test device(s) used had not expired. c. Review documentation of testing to ensure procedures are being followed. d. Determine whether external controls were tested after the second invalid test result and if troubleshooting procedures were followed. If not, perform external QC testing using test devices from the same kit or lot to determine proper functioning of the test device. e. Perform troubleshooting procedures according to the manufacturer’s instructions. f. If test results using valid external control materials provide invalid results, testing should be discontinued. g. If the test kit/lot is determined to be faulty, notify the manufacturer. h. Resume testing only after tests on external controls provide correct results and document corrective actions. l. If needed, retrain staff on appropriate testing procedures. m if appropriate, notify local or state health department HIV test manager. Excessive false positive patient/client test results On a quarterly basis, the site coordinator will compare the total number of reactive rapid test results with the number of confirmed positive results. The results of this audit will be conveyed to the laboratory director. If the resulting ratio of false-positive rapid test results suggests the test is not performing according to manufacturer specifications (refer to the product insert for population prevalence and performance data), the laboratory director should consider the following actions: a. Evaluate the expiration dates of test kits and temperatures of the storage and testing areas for test kit lots that produced, and did not produce, false positive test results. b. Review records of external control testing for test devices of the same lot and subjected to the same temperature conditions. c. Perform additional troubleshooting procedures in accordance with manufacturer instructions. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 16 of 26 d e. Evaluate facility testing procedures and, if appropriate, modify the QA protocol and/or retrain staff on appropriate testing procedures. If necessary, inform the manufacturer and appropriate local or state health department HIV test managers. If appropriate, consider discontinuation of testing or changing to another waived test vendor. References 1. Clinical Laboratory Improvement Amendments of 1988, 42 U.S.C. 263a PL100578 (1988). 2. CLSI document HS1-A2. A quality system model for health care; Approved guideline – Second edition. CLSI, Wayne, PA, 2004. 3. CDC. Good Laboratory Practices for Waived Testing Sites. MMWR Recommendations and Reports. 2005; RR-54:13. 4. CLSI document GP21-A2.Training and competence assessment; Approved guideline – Second edition. CLSI, Wayne, PA, 2004. 5. CLSI document H4-A5. Procedures and devices for the collection of diagnostic capillary blood specimens, Approved standard guideline. CLSI, Wayne, PA, 2004. 6. Occupational Safety and Health Administration regulations, 29CFR Part 1910. Available from http://www.osha.gov/SLTC/bloodbornepathogens/index.html 7. CDC. Perspectives in disease prevention and health promotion update: Universal precautions for prevention of transmission of human immunodeficiency virus, hepatitis B virus, and other bloodborne pathogens in health-care settings. MMWR 1988; 37(24):377-88. 8. Garner JS, Hospital Infection Control Practices Advisory Committee. Guideline for isolation precautions in hospitals. Infect Control Hosp Epidemiology 1996;17:53-80, and Am J Infect Control 1996;24:24-52. 9. CDC. CDC Revised Guidelines for HIV Counseling, Testing, and Referral. MMWR Recommendations and Reports. 2001; RR-19:50. 10. APTIMA® HIV-1 RNA Qualitative Assay package insert. Gen-Probe®, San Diego, CA 92121, 2006. 11. Uni-Gold™ Recombigen® HIV package insert. Trinity biotech USA, St. Louis, MO 63114, 2004. 12. OraQuick® ADVANCE Rapid HIV-1/2 Antibody Test package insert. OraSure Technologies, Inc., Bethlehem, PA 18015, 2005. 13. HIV-1/2 STAT-PAKTM Assay package insert. Chembio Diagnostic Systems, Inc., Medford, NY 11763, 2006. NOTE: This manual was adopted for use in the Michigan Regional Laboratory System from Quality Assurance Guidelines for Testing Using Rapid HIV Antibody Tests Waived Under the Clinical Laboratory Improvement Amendments of 1988, U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, 2007 Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 17 of 26 Appendix 1: Procedures and forms on the Michigan Regional Laboratory website FORMS: HIV RAPID TEST COMPARISON STUDY Comparison Study Data Log Staff Questionnaire ClearView Daily Client Log UniGold Daily Client Log Consent form for HIV Testing Universal Precautions PowerPoint - Judy Smith HIV Quality Assurance PowerPoint - Dr. John Dyke Quality Control PowerPoint - Barbara Weberman ClearView PowerPoint UniGold PowerPoint UniGold Training Guide FORMS: HIV TESTING RLF.01.02 RLF.02 RLF.03 RLF.04 RLF.05 RLF.08 RLF.09 RLF.10 RLF.11 RLF.12 Organization Structure Waived Test Sites - updated 1/11/2007 Log Sheet - Lab Directors Visits Waived Testing Personnel Report Form Initial Training Checklist for the OraQuick Advance Competency Checklist for the OraQuick Advance Log Sheet - Quality Control - OraQuick Advance Log Sheet - Client Daily - OraQuick Advance - updated 5/31/2006 OraQuick Advance Inventory Sheet Discordant Results Report #1 Discordant Results Report #2 FORMS: CONTINUOUS QUALITY IMPROVEMENT RLF.07 RLF.13 RLF.20 Corrective Action Form for Unacceptable Proficiency Test Corrective Action Form for Ungraded Proficiency Test Corrective Action Form - General Purpose PROCEDURES: RAPID HIV RL.03.03 HIV-1 and 2 Rapid Test OraQuick Advance - updated 1/26/2007 RL.07.01 Flow Diagram for Rapid HIV OraQuick Advance - Blood RL.08.01 Flow Diagram for Rapid HIV OraQuick Advance - Oral Fluid RL.09.01 OraQuick Advance Test Algorithm - Blood RL.10.01 OraQuick Advance Test Algorithm - Oral Fluid RL.11.02 Uni-Gold Recombigen HIV-1 - updated 1/11/2007 RL.53.01 Clearview HIV 1/2 Stat-Pak - updated 2/12/2008 Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 18 of 26 Summary: Quality Assessment The following is a summary of the Quality Assessment Plan of this agency. All personnel involved in the testing process are required to be familiar with the entire plan and to refer to it whenever additional information is required. All site coordinators are also encouraged to refer to the Michigan Regional laboratory System website at www.michigan.gov/mdchlab to download forms which are designed to document the QA activities summarized in this document. Quality Policy: The primary goal of each clinic performing testing is to provide high quality results that accurately reflect the clinical status of the client. Each clinic must have a plan that monitors each test on a daily basis. The goal of this plan is to ensure that testing is performed accurately each and every day. Personnel, Training and Competency: All personnel performing testing must be thoroughly trained in each laboratory procedure assigned to them before they start testing client samples and on an ongoing basis. The ability of each individual to accurately perform each step of testing (i.e., their competency) must be evaluated annually. Laboratory Facility and Safety Precautions: • Each clinic must have sufficient space for all necessary tests being performed. • Staff must be familiar with all safety precautions required for proper handling of chemicals and have annual training in chemical safety. • Staff must be familiar with all safety precautions required for biohazardous material and bloodborne pathogens and have annual bloodborne pathogen training. Laboratory Instrumentation • All instruments must be kept in good working order • All instruments must be cleaned as required by either laboratory policy or manufacturer recommendations (some instruments require cleaning each day testing is performed, other instruments require weekly or monthly cleaning). • Document all problems and repairs. Laboratory Reagents • No testing is permitted if reagents have exceeded their expiration date. • Label each reagent with the date it was opened or prepared and initial. • Some reagents will have a new expiration date after being opened (e.g. 30 days after opening. Write both the date opened and the new expiration date on the vial and initial. • Write the date of receipt into the clinic on the outside of each box of reagents. • Monitor conditions where reagents are stored (e.g., temperature). • Discard expired reagents as soon as possible. Laboratory Procedure Manual: • Everyone performing testing must follow each procedure exactly as written. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 19 of 26 • • No modifications are permitted – there are no exceptions. All procedures must be approved by the laboratory director. The signature of the clinical consultant or medical director or other agency manager does not supersede or replace the approval of the laboratory director. Proficiency Testing • Proficiency testing programs are intended to determine if the test site can produce the correct result. • PT samples are tested in the same exact manner as client samples • Document PT results on daily test logs AND the score sheet supplied with the samples. • Rotate PT among all personnel performing testing. • PT results are due within the time frame required by the PT agency (usually 10 working days after receipt of the sample). • Staff may not consult with others in the clinic unless this is part of the normal testing process. • The individual who tests the PT sample and the site coordinator must sign a statement which acknowledges that testing was performed in the same manner by which they normally test client samples. • After results have been submitted, left over PT samples may be used to assess competency. NOTE: Proficiency testing is not the same as competency evaluations or training. • Corrective action is required whenever an incorrect result is obtained on a PT sample. • All testing personnel need to review the PT scoring and sign an acknowledgement of review. Quality Control • QC verifies that test results are valid by assessing the reliability of three aspects of the testing process: - The reliability of test reagents - The integrity of instrumentation - The ability of the tester to perform the test accurately • The frequency for running controls for each test procedure is specified in the QA plan. • QC must be acceptable before testing and/or reporting of results is permitted. Any results obtained when QC is unacceptable or not performed are invalid and must be repeated. There are no exceptions. • The person performing testing must evaluate QC results and make a determination of pass or fail before client samples may be tested. • Some tests (e.g., strep A, urine pregnancy, hemoccult) have an internal procedural control. Results of the internal control must be documented for each control and client tested. • QC logs must include lot number and expiration date of all reagents used in the test. • QC logs must include the lot number, expiration date, and acceptable ranges of all controls. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 20 of 26 • • Corrective action must be taken whenever controls fail to give expected results. Do not repeat QC testing until an acceptable result is generated. Unacceptable QC results indicate a problem with the test system. Determine the nature of the problem before proceeding. New Test Introduction: The clinic must validate the accuracy and reliability of each new instrument or new test procedure before testing is permitted. The laboratory director will provide specific requirements of the validation study. Laboratory Records • All test results must be accurately and legibly written on daily test logs • All test results must be accurately and legibly transcribed from daily test logs to client charts. • All test results written in client charts must follow the reporting criteria contained in the procedure manual. • Whenever transcriptional errors are made: draw a single line through the incorrect entry and write the correct entry next to it. Initial and date the change. Do not use “White Out” or totally obscure the incorrect entry. • All laboratory records are kept for two years and then discarded. Documentation of Complaints and Communications: The clinic must document all communications or complaints from individuals outside the clinic which deal with laboratory results. Data Review and Internal Chart Audits: The site coordinator must perform a review of test records and client charts on a quarterly basis to ensure that laboratory results are accurately transcribed into client charts. Corrective Action: Whenever a laboratory test fails to give the expected result (e.g., QC out-of-control, proficiency testing, etc,) laboratory staff must: • Identify the problem • Investigate what went wrong and try to identify the cause • Implement a plan to correct the problem and prevent it from happening again • Identify someone who will monitor laboratory results to ensure the problem doesn’t happen again • Document each step of the investigation on the appropriate form (RLF-20) 2.0 General Overview This section is an overview of the requirements of a written Quality Assessment (QA) Plan and how it is to be utilized within the Michigan Regional Laboratory System. The Clinical Laboratory Improvement Amendments (CLIA) classifies laboratory tests as either waived or non-waived. Non-waived tests are further divided as either moderately complex or highly complex. Most tests performed with the Regional Laboratory System are classified as waived. The notable exception is wet mount analysis, which is a non- Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 21 of 26 waived, moderately complex test. While not strictly required by CLIA for waived category tests, the QC protocols utilized by the regional laboratory system are more stringent those required by the CLIA regulations. Dual level (low/high for quantitative assays and positive/negative for qualitative) controls are required for all tests at an interval based on the perceived stability of the test. This is based on standard laboratory procedures for good laboratory practice. Quality assessment activities are based upon the three phases of laboratory testing – preanalytical, analytical, and post-analytical. 1. The pre-analytical phase involves the steps taken before testing starts. 2. The analytical phase includes the actual testing process. 3. The post-analytical phase includes the recording and reporting of test results. The documentation tools contained in this QA plan will allow testing personnel to evaluate each phase of testing. There are two broad categories of laboratory tests: quantitative and qualitative. 1. Quantitative tests are used to determine the actual concentration of a material (“how much” or “how little”) is present in the test sample. A numeric value is produced. Cholesterol is a typical quantitative test. 2. Qualitative tests attempt to determine whether or not a specific condition exists (“positive” or “negative”). Urine pregnancy is a typical qualitative test. Qualitative and quantitative tests have separate requirements for quality control. 1. Quantitative tests should be challenged with controls that evaluate both the high and low range of the test methodology. a. Most compounds in the blood have a normal range which is typically seen in healthy individuals. Test results which fall above or below the normal value are considered to be clinically significant. b. Control materials are chosen which will fall at the low end and the high end of the test methodology. This ensures that the laboratory is capable of detecting abnormal results in client samples. 2. Control materials for qualitative tests utilize material which will yield a positive or a negative result. This depends on whether the target is present or absent in the control material Some test kits have “internal QC indicators”, e.g. most pregnancy tests. The results of the internal indicators of both QC and patient test should be documented since this certifies that the test result is valid. While internal controls demonstrate that each individual test is performing as required, they do not take the place of challenging the test with known positive and negative controls. Similarly, some instruments are equipped with a calibration cuvette or check strip which tests the electrical components of the instrument. This electronic control mechanism does not verify the accuracy of the reagents used in the testing process. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 22 of 26 Standardized QC materials can be obtained from a commercial manufacturer for most tests. Certain tests, most notably fecal occult blood (e.g., hemoccult or hemawipe) do not have external quality controls. Instead, the internal quality control results must be observed and documented for all client samples. Laboratory staff must be able to recognize whenever a test fails to perform as expected. This is accomplished by complying with the following requirements. 1. The entire testing process must be continually monitored to ensure that laboratory errors are promptly identified and corrected before a laboratory result is reported and entered into the client’s clinical history. 2. Staff members must demonstrate competence in all steps of all procedures to which they have been assigned. 3. Documentation must be available at each site where testing is performed which shows that each individual performing testing has been properly trained and states they are capable of performing the procedure according to written instructions. 4. Staff must be monitored on an ongoing basis to demonstrate that they are competent to perform each test for which they have been trained. 5. Written procedures must be reviewed and signed by the laboratory director on an annual basis and placed in a lab manual available to staff at each testing site. 6. The procedure must adhere to all requirements specified by the manufacturer of the test kit or control. 7. All test materials (controls, reagents, and supplies) must be stored in accordance with the conditions specified in the procedure. 8. Staff members may not exchange reagents from one kit with another. Likewise, do not use expired materials for patient testing. 9. No test will ever be performed on clinical specimens if the QC test(s) has not been performed or is unacceptable. 10. Staff must initiate and document corrective action whenever a quality control result is out-of-range or whenever a test fails to give expected results. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 23 of 26 This page left intentionally blank *********************************************************************************** This material reviewed and approved for use without modification: Review Date/Signature: ______________________________________________________________ Review Date/Signature: ______________________________________________________________ Review Date/Signature: ______________________________________________________________ Review Date/Signature: ______________________________________________________________ Review Date/Signature: ______________________________________________________________ Review Date/Signature: ______________________________________________________________ RL.01.05 Quality Assurance Guidelines – HIV Rev. 11/2008 Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 24 of 26 Quality Control Corrective Action Flow Sheet Site Coordinator reviews all QC records prior to forwarding to lab director/tech. consultant. Errors on QC logs will require corrective action by the site coordinator. Specific activity will depend upon the nature of the error. Follow this flow chart to determine the appropriate corrective action to be taken. Was the correct form used? AND was it the most recent version? Yes Was all required QC information documented? (i.e., expiration date, lot #, control ranges?) Yes Were all results for optic check, high/low controls, internal controls, etc. recorded? Yes Were the reagents within allowable dates AND were ALL QC results acceptable (i.e., within range)? Was a correct determination of QC acceptability made? No Incorrect Form 1. Identify the testing personnel who used the out of date form. 2. Instruct the testing person in question to use the correct form. 3. Supply them with the correct form. 4. Remove older versions of the form. 5. Document your corrective actions & save the documentation. continue No continue No Incomplete Record 1. Identify the testing personnel who failed to document all data. 2. Instruct the testing person in question to include all data. 3. Document your corrective actions & save the documentation. 4. If the expiration dates are wrong or not written down, then assume that expired reagents were used and all client results are invalid. Corrective actio required (see below). Incomplete Record 1. Identify the testing person who failed to document QC results. 2. Instruct the testing person in question to include all data. 3. Document your corrective actions & save the documentation. 4. If observed results are not recorded, then assume that controls were not tested and all client results are invalid. Corrective action required (see below continue QC FAILURE! No 1. Identify testing personnel who filled out the form. 2. Retrain testing person in question on criteria for pass/fail determination fo QC results. 3. Retrain testing person in question on proper handling and correct usage of QC material and test reagents. Give particular emphasis on documentation o correct expiration and review of QC results. 4. Written corrective action required. Yes Were any patients tested while reagents were expired, not recorded, or out of control? No further action required No 1. Client status not affected. 2. State that no clients were tested in the corrective action report. 3. Send to lab director for review and signature Yes 1. Any patient testing done must be considered invalid. 2. Pull all client charts for those tested with expired of out-of-control QC. Co form RLF-73. 3. Recall and retest clients 4. Alternatively, medical director should compare test results to clinical statu Retest any clients whose test results are inconsistent with clinical status. 5. Document the process and send to lab director for review and signature. If either the test reagents or the quality control reagents are out of date or fail to perform within specifications, then the result is INVALID and must not be used for client management. Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 25 of 26 Quality Control Troubleshooting Flow Sheet Page 1 1. Start on Page 1 if Instrument Function check required(Optic Check, Calibration Check, etc.) 2. Start on Page 2 if no instrument function checks are required. Did the instrument function check yield the expected results? Yes The instrument is functioning as expected. 1. Document results of optic check, calibration check, etc. on test records. 2. Proceed to testing controls No The instrument is NOT functioning as expected. 1. Document results of optic check, calibration check, etc on test records. 2. Do not test controls yet. 3. Check expiration date of optic check or calibration strip. Not expired Expired Yes Clean instrument & repeat testing. Did the instrument function check yield expected results on retest? Bad News! 1. Order new supplies at once. 2. Do not use this instrument until new shipment is received. 3. Start at the beginning when new supplies received No Proceed to TESTING CONTROL REAGENTS (continued on next page) Bad News! 1. Document results of optic check, calibration check, etc. on test records 2. Document what was done to try to correct the problem. 3. Call technical support 4. DO NOT USE THIS INSTRUMENT UNTIL THE PROBLEM IS CORRECTED. 5. Complete a corrective action report and contact your technical consultant or laboratory director Quality Assessment Manual for Rapid HIV Testing RQA.01.05 Michigan Regional Laboratory System Effective Date: November 14, 2008 <Insert name of the local health department> Page 26 of 26 Quality Control Troubleshooting Flow Sheet Page 2 1. Start on Page 2 once the Instrument Function check is successful 2. Start on Page 2 if no instrument function checks are required. 1. Document results of controls on the QC log 2. Compare actual results to expected values 3. Make a determination of PASS/FAIL on the QC log 4. Do the results for BOTH controls fall within the expected range? Testing Control Reagents 1. Test high (abnormal) controls 2. Test low (normal) controls How many controls were out of range? YES NO Two One 1. Re-test the control using the SAME vial of control and the SAME lot number of test kit (e.g, cuvettes, cassettes, etc.). 2. Document results 1. Re-test both controls using a DIFFERENT pair of controls and the SAME lot number of test kit (e.g, same cuvettes, cassettes, etc. 2. Document results Does the repeat test fall within the expected range? Does the repeat test fall within the expected range? Yes Problem may be pipetting error. Review your technique. Record corrective action in QC log. QC is ACCEPTABLE. OK to start testing No No Yes Retest using a NEW LOT NUMBER of CONTROL REAGENT. Retest using a NEW LOT NUMBER of TEST Kit or REAGENT Does the repeat test fall within the expected range? Does the repeat test fall within the expected range? Yes No No EQUIPMENT FAILURE! 1. Contact technical support for repairs. 2. DO NOT USE this instrument for clinical testing. 3. Document corrective action in QC log 4. Notify lab director immediately. Yes Initial test kits or reagents may be bad. Discard them. Retest. Initial controls are bad. Discard them.