We were sited by a CLIA inspection for not doing direct observation competency assessment. The inspector told us that we had to assess the 'major' procedures/processes annually. In Blood Bank, at least, you can incorporate a lot of 'major' procedures/processes into one observation exercise - one crossmatch w/ antibody can include blood type, antibody dectection, antibody ID, antigen typing, crossmatching immediate spin and AHG, correct donor selection process, tagging, and checkout, equipment (centrifuge, cell washer, ProVue or Echo or whatever, etc) -takes a long time but covers a lot of ground.