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Emergency Released RBC

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Do you keep the emergency release form that was issued as an emergency, but then the blood was never transfused and the form was never signed by the physician and returned to the Blood Bank?

Thank you,

Simret G

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It would behoove you to keep it. Reason being, a unit in your care was issued before all required testing was performed. Even if the blood was returned, you need to keep the documentation as to why it was released from your electronic inventory record.

Now, say you issue a cooler full of an MTP pack and as the nurse is walking away, they cancel the MTP. The nurse returns the cooler, it doesn’t even make it to the floor, and you haven’t sent the slip for the physician’s signature yet. In that case, it could be a little redundant to make them sign a form for a nonexistent MTP, so I would just leave documentation of a variance from SOP document in the event of inspection with the documentation that an emergency release was initiated at the request of the physician and was canceled so you did not send a form.

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19 hours ago, Oniononorion said:

It would behoove you to keep it. Reason being, a unit in your care was issued before all required testing was performed. Even if the blood was returned, you need to keep the documentation as to why it was released from your electronic inventory record.

Now, say you issue a cooler full of an MTP pack and as the nurse is walking away, they cancel the MTP. The nurse returns the cooler, it doesn’t even make it to the floor, and you haven’t sent the slip for the physician’s signature yet. In that case, it could be a little redundant to make them sign a form for a nonexistent MTP, so I would just leave documentation of a variance from SOP document in the event of inspection with the documentation that an emergency release was initiated at the request of the physician and was canceled so you did not send a form.

Exactly!

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Thank you all for sharing your thoughts. Much appreciated!

Simret G.

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21CFR606.151(e) states "Standard operating procedures for compatibility testing shall include the following: Procedures to expedite transfusion in life-threatening emergencies. Records of all such incidents shall be maintained, including complete documentation justifying the emergency action, which shall be signed by a physician."

We keep them regardless of whether or not the units are transfused.

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Does anyone utilize the physician notes that mention the need for blood and are electronically signed in the EMR to satisfy the documentation required for emergency release of units?

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Posted (edited)

They certainly do in many hospitals within the UK where Biomedical Scientists have been empowered to so do.

I should point out that blood is never withheld in an emergency situation, there will most certainly be an investigation after the event.

Edited by Malcolm Needs

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We require a signature on an Emergency Release document, but we don't require that signature prior to the release of product, just a verbal. If the ED provider requested the release he/she is usually available to sign once the patient has been turned over to the surgeon/transferred/admitted. In some cases the form may get mailed to the surgeon's office the next day for signature or wait a few days until the ED provider is on duty again.

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Our issue is that the ED providers find a paper form archaic and say that the patients electronically signed EMR note should give enough indication for the product need prior to compatibility testing.

No...blood is never withheld in an emergency situation. This EMR review would be retrospecitve.

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21 hours ago, rosi0017 said:

Our issue is that the ED providers find a paper form archaic and say that the patients electronically signed EMR note should give enough indication for the product need prior to compatibility testing.

No...blood is never withheld in an emergency situation. This EMR review would be retrospecitve.

The amount of times that I have encountered a doctor that refused to transcribe critical information to a Blood Bank paper record is astronomical

We usually send a form with the emergency pack and if it's not signed when its returned, we send it back to them and someone signs it. 

It would be easier to get rid of the whole paper signing business, but it serves as a downtime record in and of itself if you cannot issue the units or cannot pull the care team that ordered the emergency. Just a thought.

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That’s a really good point Ward_X.
 

Emergent events documented in the EMR should be enough to justify our actions in the case of unXM’d blood. I have never thought of the possibility that that would suffice as documentation for this purpose but requiring docs to sign papers really does seem a little archaic after thinking of it in terms of all the information that is available to us in the EMR to prove who requested it, but we in the blood bank are so used to having >complete documentation of everything. But this also can never be assumed as not everyone is so meticulous....

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On 6/7/2020 at 1:37 AM, Oniononorion said:

That’s a really good point Ward_X.
 

Emergent events documented in the EMR should be enough to justify our actions in the case of unXM’d blood. I have never thought of the possibility that that would suffice as documentation for this purpose but requiring docs to sign papers really does seem a little archaic after thinking of it in terms of all the information that is available to us in the EMR to prove who requested it, but we in the blood bank are so used to having >complete documentation of everything. But this also can never be assumed as not everyone is so meticulous....

What programmers should really add to systems like EPIC and the like is signature capabilities under an emergency release record. If a record can say the units were EI and it's already in the patient's file, how convenient would it be if a doctor could sign the consent off that? 

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On 6/7/2020 at 12:37 AM, Oniononorion said:

That’s a really good point Ward_X.
 

Emergent events documented in the EMR should be enough to justify our actions in the case of unXM’d blood. I have never thought of the possibility that that would suffice as documentation for this purpose but requiring docs to sign papers really does seem a little archaic after thinking of it in terms of all the information that is available to us in the EMR to prove who requested it, but we in the blood bank are so used to having >complete documentation of everything. But this also can never be assumed as not everyone is so meticulous....

I think there is a good point made here regarding the assumption that the request for uncrossmatched blood has been documented in the EMR by the provider who requested it. In my experience with chart reviews for patients who've received emergency release and/or uncrossmatched blood products, I've seen multiple examples of notes by nurses regarding emergency release w/o a corresponding note by the provider. We do not have a specific order set for uncrossmatched blood products in the HIS (though I wish we did). All our orders are received verbally and the products are released from our BB LIS using the emergency release functionality, which pushes the information over to the HIS. If we don't get the signed document, it's quite possible that we would have no documentation that the provider requested the release. If you have an order set specific for uncrossmatched products that the provider enters into the HIS, I would think that that's a different story. The order has captured an electronic signature. I would think that a brief statement could be added to the 'uncrossmatched' or 'emergency release' order set (thinking in terms of Epic here) that states that the provider is aware of the risk, etc. etc. I would think that would cover what needs to be covered...BUT then I'm not a lawyer. :paranoid:

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1 hour ago, AMcCord said:

All our orders are received verbally and the products are released from our BB LIS using the emergency release functionality, which pushes the information over to the HIS. If we don't get the signed document, it's quite possible that we would have no documentation that the provider requested the release. If you have an order set specific for uncrossmatched products that the provider enters into the HIS, I would think that that's a different story. The order has captured an electronic signature.

That's a great point, and my lab operates the same way with our software. I did notice we actually have an order for an MTP that will crossover to us from them, but doctors seldom use it. The few times I have seen it, they verbally order and then file it electronically ex post facto. The mere fact this exists means that hopefully there can be a way to adapt it in the future or stress to use it more.

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We have added the AABB attestation statement regarding the release of uncrossmatched, emergency released blood to an Epic order that is electronically signed.  We still send a form but it is more of a back-up now for those instances where the MD did not sign the form from the OR and once the patient has been transferred, it is virtually impossible to find someone willing to sign the form after the fact.

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