CMS Offers EP23 as Risk-Based Option for Clinical QC Plans

By Carle, A.B. | Publication

In two memoranda dated November 4, 2011 and March 9, 2012 the US Centers for Medicare and Medicaid Services (CMS) have informed laboratories of their intention to provide a new optional basis for laboratory quality control plans.  Guidance on this option is available as a revised standard, titled “Laboratory Quality Control Based on Risk Management” which was developed in collaboration between CMS and the Clinical Laboratory Standards Institute (CLIS).  This standard, designated EP23-A, was approved in October 2011 and is available for purchase at the CLSI website.

Over the next several years clinical laboratories will have the opportunity to develop risk-based quality control procedures.  Laboratories which choose to not follow EP23 can continue to meet the traditional QC requirements of 42 CRF 493.1256(d)(3), along with the manufacturer’s requirements as detailed in package inserts.

It should be noted that EP23 does not specify one particular method of risk analysis, and laboratory directors who are considering EP-23 should be aware of the both the potential benefits and pitfalls of risk analysis methods.  An interesting recent article by Westgard titled “Is Risk Analysis Reliable?” points to research findings on some of the ways that Failure Mode and Effects Analysis (FMEA) can itself fail.

CLSI has been promoting EP23-A through a series web-based and in-person seminars.  Artel’s Senior Scientific Manager, Dr. George Rodrigues will join me as we attend the CLSI training course in Boston and we will let you know what we learn.


About the Author

A. Bjoern Carle, PhD, is the PCS Product Manager at Artel, where he supports product development, scientific marketing, and technical training efforts. Dr. Carle earned his Vordiplom (B.S.) in Chemistry at the University of Stuttgart (Stuttgart, Germany), his M.S. and PhD in Organic Chemistry at the University of Cincinnati (Cincinnati, OH), and performed post-doctoral research at Harvard Medical School / Massachusetts General Hospital (Boston, MA).