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1.
Clin Chem Lab Med ; 61(4): 608-626, 2023 03 28.
Article in English | MEDLINE | ID: mdl-36716120

ABSTRACT

The EU In-Vitro Diagnostic Device Regulation (IVDR) aims for transparent risk-and purpose-based validation of diagnostic devices, traceability of results to uniquely identified devices, and post-market surveillance. The IVDR regulates design, manufacture and putting into use of devices, but not medical services using these devices. In the absence of suitable commercial devices, the laboratory can resort to laboratory-developed tests (LDT) for in-house use. Documentary obligations (IVDR Art 5.5), the performance and safety specifications of ANNEX I, and development and manufacture under an ISO 15189-equivalent quality system apply. LDTs serve specific clinical needs, often for low volume niche applications, or correspond to the translational phase of new tests and treatments, often extremely relevant for patient care. As some commercial tests may disappear with the IVDR roll-out, many will require urgent LDT replacement. The workload will also depend on which modifications to commercial tests turns them into an LDT, and on how national legislators and competent authorities (CA) will handle new competences and responsibilities. We discuss appropriate interpretation of ISO 15189 to cover IVDR requirements. Selected cases illustrate LDT implementation covering medical needs with commensurate management of risk emanating from intended use and/or design of devices. Unintended collateral damage of the IVDR comprises loss of non-profitable niche applications, increases of costs and wasted resources, and migration of innovative research to more cost-efficient environments. Taking into account local specifics, the legislative framework should reduce the burden on and associated opportunity costs for the health care system, by making diligent use of existing frameworks.


Subject(s)
Clinical Laboratory Services , Reagent Kits, Diagnostic , Humans , Reagent Kits, Diagnostic/standards , European Union , Clinical Laboratory Services/legislation & jurisprudence
2.
Curr Opin Infect Dis ; 33(4): 304-311, 2020 08.
Article in English | MEDLINE | ID: mdl-32657967

ABSTRACT

PURPOSE OF THE REVIEW: Laboratory-developed tests (LDTs) are essential for the clinical care of immunocompromised individuals. These patients often require specialized testing not available from commercial manufacturers and are therefore dependent on the laboratory to create, validate, and perform these assays. Recent paradigm-shifting legislation could alter the way that LDTs are operationalized and regulated. RECENT FINDINGS: On March 5th, 2020 the Verifying Accurate and Leading-Edge In-Vitro Clinical Tests Development Act (VALID) was introduced in the US Congress. This statute would overhaul existing regulatory framework by unifying the oversight of LDTs and commercial in-vitro diagnostic tests (IVDs) through the FDA. If enacted, LDTs would be subject to regulatory requirements like those found in commercial submissions for market review. Stakeholders continue to discuss the details and scope of the proposed legislation in the setting of the Severe Acute Respiratory Syndrome Coronavirus 2 pandemic, where LDTs are integral to the national COVID-19 response. SUMMARY: Congressional lawmakers have introduced legislation to alter the regulatory framework governing LDTs. Moving forward, a balance must be struck to ensure the availability of safe and accurate testing without delays or overregulation that could be harmful to patients. The downstream implications of how VALID and other legislation will impact laboratories, clinicians, and patients warrant close examination.


Subject(s)
Clinical Laboratory Services/legislation & jurisprudence , Clinical Laboratory Techniques , Coronavirus Infections/diagnosis , Immunocompromised Host , Laboratories, Hospital/legislation & jurisprudence , Pneumonia, Viral/diagnosis , Uncertainty , United States Food and Drug Administration/legislation & jurisprudence , Betacoronavirus/pathogenicity , COVID-19 , COVID-19 Testing , Congresses as Topic , Health Services Research/legislation & jurisprudence , Humans , Pandemics , Quality Assurance, Health Care , SARS-CoV-2 , United States
3.
Lancet ; 391(10133): 1953-1964, 2018 05 12.
Article in English | MEDLINE | ID: mdl-29550030

ABSTRACT

Modern, affordable pathology and laboratory medicine (PALM) systems are essential to achieve the 2030 Sustainable Development Goals for health in low-income and middle-income countries (LMICs). In this last in a Series of three papers about PALM in LMICs, we discuss the policy environment and emphasise three crucial high-level actions that are needed to deliver universal health coverage. First, nations need national strategic laboratory plans; second, these plans require adequate financing for implementation; and last, pathologists themselves need to take on leadership roles to advocate for the centrality of PALM to achieve the Sustainable Development Goals for health. The national strategic laboratory plan should deliver a tiered, networked laboratory system as a central element. Appropriate financing should be provided, at a level of at least 4% of health expenditure. Financing of new technologies such as molecular diagnostics is challenging for LMICs, even though many of these tests are cost-effective. Point-of-care testing can substantially reduce test-reporting time, but this benefit must be balanced with higher costs. Our research analysis highlights a considerable deficiency in advocacy for PALM; pathologists have been invisible in national and international health discourse and leadership. Embedding PALM in LMICs can only be achieved if pathologists advocate for these services, and undertake leadership roles, both nationally and internationally. We articulate eight key recommendations to address the current barriers identified in this Series and issue a call to action for all stakeholders to come together in a global alliance to ensure the effective provision of PALM services in resource-limited settings.


Subject(s)
Clinical Laboratory Services/standards , Health Services Needs and Demand/legislation & jurisprudence , Point-of-Care Systems/economics , Quality of Health Care/standards , Clinical Laboratory Services/legislation & jurisprudence , Developing Countries , Health Education , Health Expenditures , Health Policy , Humans , Pathologists , Poverty , Public Health , Quality of Health Care/legislation & jurisprudence
4.
J Clin Microbiol ; 57(6)2019 06.
Article in English | MEDLINE | ID: mdl-30971460

ABSTRACT

The Clinical and Laboratory Standards Institute (CLSI) has revised several breakpoints since 2010 for bacteria that grow aerobically. In 2019, these revisions include changes to the ciprofloxacin and levofloxacin breakpoints for the Enterobacteriaceae and Pseudomonas aeruginosa, daptomycin breakpoints for Enterococcus spp., and ceftaroline breakpoints for Staphylococcus aureus Implementation of the revisions is a challenge for all laboratories, as not all systems have FDA clearance for the revised (current) breakpoints, compounded by the need for laboratories to perform validation studies and to make updates to laboratory information system/electronic medical record builds in the setting of limited information technology infrastructure. This minireview describes the breakpoint revisions in the M100 supplement since 2010 and strategies for the laboratory on how to best adopt these in clinical testing.


Subject(s)
Microbial Sensitivity Tests/methods , Microbial Sensitivity Tests/standards , Anti-Bacterial Agents/pharmacology , Bacteria/drug effects , Clinical Laboratory Services/legislation & jurisprudence , Clinical Laboratory Services/standards , Health Policy , Humans , United States , United States Food and Drug Administration
5.
J Clin Microbiol ; 57(7)2019 07.
Article in English | MEDLINE | ID: mdl-31092593

ABSTRACT

In 2019, the Clinical and Laboratory Standards Institute revised the daptomycin breakpoints for Enterococcus spp. twice in rapid succession. Analyses leading to these revisions included review of testing issues, murine and human in vivo pharmacodynamics, safety of off-label doses, and treatment outcomes. The data review brought up a dilemma that is encountered with increasing frequency: a breakpoint supported by pharmacokinetic/pharmacodynamic modeling that bisected the wild-type Enterococcus faecium MIC distribution. In such instances, not only does the probability of pharmacokinetic/pharmacodynamic targets need to be taken into account but also the probability that the laboratory can generate an accurate MIC that is reproducible within one interpretive category.


Subject(s)
Anti-Bacterial Agents/pharmacology , Daptomycin/pharmacology , Enterococcus/drug effects , Microbial Sensitivity Tests/standards , Animals , Anti-Bacterial Agents/pharmacokinetics , Clinical Laboratory Services/legislation & jurisprudence , Clinical Laboratory Services/organization & administration , Clinical Laboratory Services/standards , Daptomycin/pharmacokinetics , Enterococcus faecium/drug effects , Humans
6.
Clin Chem ; 63(10): 1575-1584, 2017 Oct.
Article in English | MEDLINE | ID: mdl-28687634

ABSTRACT

BACKGROUND: Twenty-five years ago, the Food and Drug Administration (FDA) asserted in a draft document that "home brew" tests-now commonly referred to as laboratory-developed tests (LDTs)-are subject to the same regulatory oversight as other in vitro diagnostics (IVDs)4. In 2010, the FDA began work on developing a proposed framework for future LDT oversight. Released in 2014, the draft guidance sparked an intense debate over potential LDT regulation. While the proposed guidance has not been implemented, many questions regarding LDT oversight remain unresolved. CONTENT: This review provides an overview of federal statutes and regulations related to IVDs and clinical laboratory operations, with a focus on those potentially applicable to LDTs and proposed regulatory efforts. Sources reviewed include the Code of Federal Regulations, the Federal Register, congressional hearings, guidance and policy documents, position statements, published literature, and websites. SUMMARY: Federal statutes regarding IVDs were passed without substantive evidence of congressional consideration toward the concept of LDTs. The FDA has clear oversight authority over IVD reagents introduced into interstate commerce. A 16-year delay in publicly asserting FDA authority over LDTs, the pursuit of a draft guidance approach toward oversight, and establishment of regulations under the Clinical Laboratory Improvement Amendments of 1988 (CLIA'88) applicable to LDTs contributed to community uncertainty toward LDT oversight. Future regulatory and/or legislative efforts may be required to resolve this uncertainty.


Subject(s)
Clinical Laboratory Services/legislation & jurisprudence , Clinical Laboratory Techniques , Laboratories/legislation & jurisprudence , Medical Device Legislation , Genetic Testing/legislation & jurisprudence , Humans , United States , United States Food and Drug Administration
7.
Fed Regist ; 82(202): 48770-3, 2017 Oct 20.
Article in English | MEDLINE | ID: mdl-29090890

ABSTRACT

This final rule amends the Clinical Laboratory Improvement Amendments of 1988 (CLIA) regulations to clarify that the waived test categorization applies only to non-automated fecal occult blood tests.


Subject(s)
Certification/legislation & jurisprudence , Clinical Laboratory Services/legislation & jurisprudence , Clinical Laboratory Techniques/instrumentation , Feces/chemistry , Occult Blood , Autoanalysis/instrumentation , Humans , United States
9.
Int J Health Care Finance Econ ; 14(2): 95-108, 2014 Jun.
Article in English | MEDLINE | ID: mdl-24366366

ABSTRACT

The traditional Medicare fee-for-service program may be able to purchase clinical laboratory test services at a lower cost through competitive bidding. Demonstrations of competitive bidding for clinical laboratory tests have been twice mandated or authorized by Congress but never implemented. This article provides a summary and review of the final design of the laboratory competitive bidding demonstration mandated by the Medicare Modernization Act of 2003. The design was analogous to a sealed bid (first price), clearing price auction. Design elements presented include covered laboratory tests and beneficiaries, laboratory bidding and payment status under the demonstration, composite bids, determining bidding winners and the demonstration fee schedule, and quality under the demonstration. Expanded use of competitive bidding in Medicare, including specifically for clinical laboratory tests, has been recommended in some proposals for Medicare reform. The presented design may be a useful point of departure if Medicare clinical laboratory competitive bidding is revived in the future.


Subject(s)
Clinical Laboratory Services/economics , Competitive Bidding/economics , Health Care Costs/trends , Medicare Part B/economics , Reimbursement Mechanisms/economics , Clinical Laboratory Services/legislation & jurisprudence , Competitive Bidding/legislation & jurisprudence , Competitive Bidding/methods , Cost Control/legislation & jurisprudence , Cost Control/methods , Fee Schedules/economics , Fee Schedules/legislation & jurisprudence , Fee Schedules/trends , Health Care Costs/legislation & jurisprudence , Humans , Medicare Part B/legislation & jurisprudence , Reimbursement Mechanisms/legislation & jurisprudence , Reimbursement Mechanisms/trends , United States
10.
Fed Regist ; 79(25): 7289-316, 2014 Feb 06.
Article in English | MEDLINE | ID: mdl-24605389

ABSTRACT

This final rule amends the Clinical Laboratory Improvement Amendments of 1988 (CLIA) regulations to specify that, upon the request of a patient (or the patient's personal representative), laboratories subject to CLIA may provide the patient, the patient's personal representative, or a person designated by the patient, as applicable, with copies of completed test reports that, using the laboratory's authentication process, can be identified as belonging to that patient. Subject to conforming amendments, the final rule retains the existing provisions that require release of test reports only to authorized persons and, if applicable, to the persons responsible for using the test reports and to the laboratory that initially requested the test. In addition, this final rule amends the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule to provide individuals (or their personal representatives) with the right to access test reports directly from laboratories subject to HIPAA (and to direct that copies of those test reports be transmitted to persons or entities designated by the individual) by removing the exceptions for CLIA-certified laboratories and CLIA-exempt laboratories from the provision that provides individuals with the right of access to their protected health information. These changes to the CLIA regulations and the HIPAA Privacy Rule provide individuals with a greater ability to access their health information, empowering them to take a more active role in managing their health and health care.


Subject(s)
Access to Information/legislation & jurisprudence , Clinical Laboratory Services/legislation & jurisprudence , Health Insurance Portability and Accountability Act , Privacy/legislation & jurisprudence , Clinical Laboratory Services/standards , Humans , Medical Informatics/legislation & jurisprudence , Medical Informatics/standards , United States
11.
Semin Cutan Med Surg ; 32(4): 185-94, 2013 Dec.
Article in English | MEDLINE | ID: mdl-24800424

ABSTRACT

Purchased service arrangements, establishing in-house professional pathology services, conducting technical component histology within a dermatology practice, and electronic medical records technology donations are ways that dermatology practices are responding to the current health care delivery and payment changes. This article will provide a general framework for navigating the compliance risks and structure considerations associated with these relationships between dermatologists and pathologists.


Subject(s)
Dermatology/legislation & jurisprudence , Electronic Health Records/legislation & jurisprudence , Malpractice/legislation & jurisprudence , Outsourced Services/legislation & jurisprudence , Pathology/legislation & jurisprudence , Certification , Clinical Laboratory Services/legislation & jurisprudence , Clinical Laboratory Services/organization & administration , Costs and Cost Analysis/legislation & jurisprudence , Dermatology/economics , Dermatology/organization & administration , Fraud/legislation & jurisprudence , Humans , Licensure , Medicaid/legislation & jurisprudence , Medicare , Pathology/economics , Pathology/organization & administration , Practice Management, Medical , United States
18.
Fertil Steril ; 116(1): 4-12, 2021 07.
Article in English | MEDLINE | ID: mdl-34148588

ABSTRACT

The aim of this article is to gather 9 thought leaders and their team members to present their ideas about the future of in vitro fertilization and the andrology laboratory. Although we have seen much progress and innovation in the laboratory over the years, there is still much to come, and this article looks at what these leaders think will be important in the future development of technology and processes in the laboratory.


Subject(s)
Andrology/trends , Clinical Laboratory Services/trends , Fertilization in Vitro/trends , Infertility/therapy , Reproductive Medicine/trends , Andrology/legislation & jurisprudence , Automation, Laboratory , Clinical Laboratory Services/legislation & jurisprudence , Diffusion of Innovation , Female , Fertilization in Vitro/legislation & jurisprudence , Forecasting , History, 21st Century , Humans , Infertility/diagnosis , Infertility/physiopathology , Male , Policy Making , Pregnancy , Reproductive Medicine/legislation & jurisprudence
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