Under what circumstances can a hospital provide blood products for a community dialysis center which is 'free standing' and not associated with the hospital?

A California pathologist reports that his hospital has been asked to provided blood transfusion support to a community dialysis center which is 'free standing' and not associated with the hospital. He would appreciate resources defining the requirements that must be fulfilled for this kind of program. As an aside, he wonders how colleagues would handle the situation if a physician ordering a transfusion at the dialysis center was not a member of the Medical Center's medical staff.

The following reply was submitted in response to the above:

1. Another California physician comments that in his experience, arrangements like those described above are best defined in a contract that spells out each parties duties, responsibilities, expectations, etc. If a hospital is going to serve as both the testing site for pre-transfusion samples and as the blood bank that distributes products to a dialysis center, it would be prudent to clearly define who among the dialysis center staff can collect pre-transfusion samples (RNs, LVNs, CA certified phlebotomists?) and to document that these personnel have been trained in the hospital's specimen collection procedures. It would also be prudent to clearly define who can administer blood products to dialysis patients. Finally, it would be prudent to assure that the dialysis center has well written SOPs to control the receipt, storage conditions, issuance and transfusion of the blood products, etc., that are provided to them by the hospital. Finally, the hospital might want to determine if any additional licenses or certification is needed to be able to distribute blood from the hospital lab to the free standing dialysis center.

ADDENDA Aug. 18, 2009

2. A blood banker in Northern California comments that based on a recent AABB survey at his facility, if a facility's transfusion service provides crossmatched RBC units for another free standing entity (such as a dialysis unit), the crossmatching facility must understand that it assumes joint responsibility for the transfusion at the free standing entity. Therefore, it would be prudent for a transfusion service's Medical Director to review all transfusion related SOPs for the administration, storage and return of blood products at any free standing entity for which they provide blood products. An audit of training and competency and transfusion review should be done periodcally.
   
   
3. An experienced blood banker suggests that additional consideration should be given to having the hospital participate in the review of:

1. the dialysis center's blood administration SOP, (patient identification process, vital signs, pre-medication of the patient, compatible solutions, filters etc);
2. the SOP and training of nursing staff in the recognition (signs/symptoms/treatment) of a transfusion reaction;
3. participation in the blood utilization review process; and
4. reporting of potential transmission of disease, investigation, notification, testing and follow-up.

Responsibility and oversight of these issues should be defined in a contract / agreement.

4. A Hematology and Transfusion Services Supervisor at a hospital in Arkansas comments that dialysis in her hospital is done under contract. Based on her experience with contracted dialysis services, she cannot overemphasize how important adequacy of training and competency assessment of the dialysis nurses is. The responding Arkansan acknowledges that a contracted dialysis nurse once ran glucose along with the RBCs during a transfusion. Fortunately, the dialysis system failed before any harm was done to the patient, but they had a difficult time with the investigation and corrective action follow up since the service was "contracted out." The hospital's medical director ultimately decided that until the dialysis nurses met the hospital's standards for training and competency, they would not be provided with blood products for transfusion to patients.

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