All my previous labs required a signed physician or qualified person (PA, NP) order before we would do the crossmatch on a patient.

 

So for OP we would get a copy of the signed order, for IP the doc would write the order on the chart.

 

Now that we are on COPE, the doctors want to order the T&S and in comment put give 2 units RBC.  We are trying to say that is not an order.  We say that you can not get the pharmacy to give you drugs by putting into a comment.

 

But I need some Regulatory Agencies input.  I could not find it in CAP, I am trying to go through the AABB tech manual but that is slow going. CFR is next.  I do not have any access to TJC regs.

 

Any help is most appreciated.

 

 

 

 

AABB Standards

5.11.1.1 A physician or other authorized health professional shall order blood, blood components, tests, tissue, and derivatives.

 

The thing is, i'ts an administrative issue, not a regulatory one, in my opinion.  The comment in the patient record "transfuse 2 RBCs", could be considered an order, if that is what is allowed at your facility.

 

If you have a policy that states that ordering docs must specifically order a certian test by entering a certian code while standing on one foot, JCAHO is going to make you do that, because it is in your P&Ps.

 

I would say that if current ordering practices are ambiguous, you would have a reason to gripe about it to the administartion, but I am not sure you will find a specific reg for this. 

 

In some cases, no specific order is required.  Here, if a doc calls from ER and orders a massive transfusion protocol, we do the ordering and process blood based on an established protocol for the patient until the MTP is called off.  We do not require them to do anything other than document the start and stop of the MTP.  But we have a protocol that allows for all this.

 

Scott

A comment would not suffice as an order in my opinion. There are other things built in our EMR order for blood that we need to know such as indication, need for special requirements, informed consent obtained, etc.

Docs tell me "I just want the blood"...yeah, I think we all agree, those days are over.

Are PA allowed to order blood independently/without consulting physician or without counter signed by physician?

I know AP can do it as they have their license.

This may be different in different State...

Usually a PA can order anything except a narcotic without an MD oversignature(?).

PA (physician assistants) and NP (nurse practitioners) are allowed to order blood products, as they work directly under a physician. They do not need the MDs approval or a signature.

I think in their credentialing it said something like "routine blood transfusions", so we made the decision at my facility to not allow them to order blood that is considered higher risk, or at least "outside the norm":

Emergency release uncrossmatched blood

Serologically incompatible blood (warm auto for example)

Massive Transfusion Protocol

Eagle Eye you are correct in that it depends on the state. In NJ APNs can order blood products independently, but PAs require co-signature by the physician.

That "in the comments" give 2 units PC's should not work as an order.  We use Meditech and the docs have to order all products regardless.  Any other testing such as type and screens are reflexed ordered when they order products.  It has been a HUGE education process getting them to use it.

We use 2 orders in CPOE. One for the crossmatch and one for the transfuse order. And yes, sometimes we get a transfuse order without a corresponding crossmatch order.......sigh............so we have to ask for the crossmatch order.

We have the same thing. We put a rule into the order to require each other as part of a set. We don't want them to be able to hold blood.

 

We use 2 orders in CPOE. One for the crossmatch and one for the transfuse order. And yes, sometimes we get a transfuse order without a corresponding crossmatch order.......sigh............so we have to ask for the crossmatch order.

Your compliance dept. should have regs on doctor's orders and might be willing to make a decision on whether the comment constitutes an order.  But you might have to abide by their determination.  You might have a stronger argument if you have a computer system where comments are not necessarily easy for Lab to view and not overlook this "order."  If they realize it might get missed, they might be more willing to comply.