OK, everybody crack open your JCAHO requirement manuals...
We are a MOHS lab and were surveyed by Joint Commission about 2 months ago. 
During the survey, we were cited because we only retain our physical tissue 
specimens for 24 hours, as they remain fresh and are not fixed. We throw the 
tissue the following afternoon vs. retaining for the "1 week after microscopic 
sections are examined and reports are reviewed and signed." (Standard 
#QC.2.120) 
Has anyone else (specifically a Mohs lab) been cited for this? We are currently 
trying to appeal, but have been denied so far. I am having a teleconference 
with the JCAHO powers that be to try and get the appeal going again, but I'm 
not the lawyer type.
The letter states that their interpretation is that even if the tissue is not 
regarded as 'gross' tissue, any 'useable' tissue must be retained for a minimum 
of a week after the case is signed off on.I am thinking on focusing on the 
'useable' bit as related to diagnostic value of delayed retained fresh tissue 
processing i.e. freeze artifact, tissue degredation, inability to perform 
ancillary testing, etc. Also, what is the definition of 'reviewed and signed 
reports'? Does this mean when the case is finalized, or just the tissue 
sections in question? We sometimes have patients that go a month + between Mohs 
procedures on the same positive lesion.
We will probably have to get a -80 freezer for this if the appeal doesn't go 
through. Not to mention the fact that some of our cases are not resolved for 
months. We would have constantly search when cases are finalized to know when 
we can dispose of the tissue. FYI, the letter also states that the JCAHO 
standard is more stringent than the CLIA standard, so I'm not even really going 
to use it in arguments. 
 
HELP!
Claire Ingles
UW Hospital & Clinics
Madison WI
 

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