Therapeutic Phlebotomy Competency??

[jshepherd]

Hey everyone!

We have just a visit from JC, who cited us because our nursing staff who perform therapeutic phlebotomy are not competencied in this procedure. Per the state's guidelines, nurses must be competencied in venipuncture, and they are, but there is not specific call-out for T-phleb. 

Does anyone else have a competency program for therapeutic phlebotomy?? I have never heard of such a thing in my 6 years at this facility where the nurses do this. Also, just venting here- this is totally a nursing issue, not a laboratory one!  

Thanks! 

[David Saikin]

If Lab is not performing this why are you responsible?  Get a letter from Admin exculping you from responsibility. 

Though I am not conversant w JCAHO in the lab.  All they ever do here is ask about transfusions.

[jshepherd]

Thanks David! It does fall under the QSA regs for BB in the JC standards, so the policy is "owned" by me, and I "oversee" it. Though you are correct, the procedures are not being performed by lab staff, but by nursing staff only. This is done in many places in the hospital, including outpatient clinics, again by nursing staff only. I'm pretty sure this falls under nursing competency, but venipuncture is venipuncture is it not? I have never had anyone complain about nursing comps for t-phleb specifically, its so crazy to me! 

[AMcCord]

My facility has never been cited by JC for therapeutic phlebotomies. Interesting. I handed that service over (quite happily) to the outpatient infusion clinic years ago. I did train them initially and give them copies of my forms as a documentation suggestion. My CAP checklist gets N/A for those questions and I've never been approached by a JC inspector. I would hope that they have yearly competencies, but I don't know for a fact. Might have to inquire.

[David Saikin]

1 hour ago, AMcCord said:

My facility has never been cited by JC for therapeutic phlebotomies. Interesting. I handed that service over (quite happily) to the outpatient infusion clinic years ago. I did train them initially and give them copies of my forms as a documentation suggestion. My CAP checklist gets N/A for those questions and I've never been approached by a JC inspector. I would hope that they have yearly competencies, but I don't know for a fact. Might have to inquire.

Me too.  My patients were/are rather unhappy w the Nursing approach to TP.  I'm not JC so I've never had that scrutiny. 

[spavlis]

JShepard, I have been approached on this subject multiple times.
There might be a loop hole. If the Nursing staff call it a "blood draw", it doesn't fall under the QSA regs for BB.
If the nursing staff call it a "therapeutic phlebotomy", it does.

What's the difference between a blood draw and a therapeutic phlebotomy?
Nothing, except what regulations fall under it.
The result is the same.
 

I have been telling my nursing staff to call it "blood draw".
Hope this helps
Stephanie

[jshepherd]

Stephanie - that is genius!  We have always called it therapeutic phlebotomy here though, and there would be a LOT of undoing things, including Epic documentation fields, that seem very complicated in the scheme of it. Thanks for the outside the box thinking though!