Citations checked against 42 CFR Part 493 on 11 November 2026Independent publisher. Not affiliated with CMS, CDC or any accreditation organization.
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The most-cited CLIA deficiencies, and the record that answers each one

CMS publishes the ten deficiencies its surveyors cite most often. In the 2024 list, the top standard-level findings were storage and operating conditions (42 CFR 493.1252(b)), competency assessment policies (493.1235) and the procedure manual (493.1251). The top condition-level finding was unsuccessful proficiency testing participation (493.803).

Most of these are record problems. The work was often done, and the laboratory could not show it. The tables below give each citation in plain language, what a surveyor typically finds, and the document that puts the evidence on file.

Reviewed 11 Nov 2026 against the sources linked below. General information, not regulatory or legal advice.

About the numbers
Source
CMS, Division of Clinical Laboratory Improvement and Quality
Data year
2024
Counts
Laboratories cited
Percent
"Percent of all labs" as CMS prints it

Top ten standard-level deficiencies

No.Tag and citationWhat it asks forLabs citedWhere the evidence goes
1D5413
493.1252(b)
Storage and operating conditions
Written criteria for the conditions that matter to accurate testing, such as temperature and humidity, and records showing they were monitored.
Typical finding: A missing day on a refrigerator log, a range that does not match the package insert, or no action recorded when a reading was out.
818
5.0%
PM-08 Storage and Operating Conditions Policy
PM-09 Temperature and Humidity Log
2D5209
493.1235
Competency assessment policies
Written policies and procedures to assess employee and consultant competency, and evidence they are followed.
Typical finding: Assessments missing one of the six procedures, a late first-year assessment, or an assessor who does not hold the qualifying role.
778
4.8%
CA-01 Competency Assessment Policy
CA-02 Testing Personnel Assessment Form
CA-06 Due-Date Tracker
3D5401
493.1251(a)
Procedure manual available and followed
A written procedure for every test, available to the people testing and followed by them.
Typical finding: A test on the menu with no written procedure, or staff doing something different from what the procedure says.
635
3.9%
PM-01 Procedure Manual Policy
PM-03 Procedure Manual Index and Review Log
4D5403
493.1251(b)
Procedure manual content
Each procedure covers the items the regulation lists, including specimen requirements, step-by-step performance, calibration, controls, reference intervals, critical values and what to do when the system fails.
Typical finding: A package insert used as the procedure with nothing added for the parts it does not cover.
609
3.7%
PM-02 Test Procedure Template
5D5417
493.1252(d)
Expired or deteriorated materials
Reagents, controls, kits and supplies are not used past expiration or when they have deteriorated.
Typical finding: One expired vial in a drawer, or opened reagents with no open date.
607
3.7%
PM-08 Storage and Operating Conditions Policy
WT-05 Kit and Reagent Lot Log
6D5217
493.1236(c)(1)
Twice-yearly accuracy verification
For any test not covered by required proficiency testing, the laboratory verifies accuracy at least twice a year.
Typical finding: Tests with no proficiency testing program and no record of a split sample or other check.
548
3.4%
PT-05 Twice-Yearly Accuracy Verification Record
7D5421
493.1253(b)(1)
Verification of performance specifications
Before reporting patient results from an unmodified FDA-cleared or approved test, the laboratory shows it gets performance comparable to the manufacturer's for accuracy, precision and reportable range, and confirms the reference interval fits its patients.
Typical finding: A new analyzer put into use on the installer's printout, with no study the director reviewed and signed.
451
2.8%
PM-04 Method Verification Plan and Summary
PM-05 Verification Data Worksheet
8D6016
493.1407(e)(4)(i)
Director and proficiency testing
The laboratory director makes sure the laboratory is enrolled in an approved proficiency testing program for the testing it performs, and that samples are tested as required.
Typical finding: An analyte added to the menu and never added to the proficiency testing order.
451
2.8%
PT-01 Proficiency Testing Policy
PT-04 Enrollment and Calendar Tracker
9D5429
493.1254(a)(1)
Maintenance
Maintenance is performed as the manufacturer defines and at least as often as the manufacturer specifies, and it is documented.
Typical finding: Monthly or six-monthly maintenance that is done but not written down, or skipped when the service contract lapsed.
449
2.8%
PM-06 Maintenance and Function Check Log
10D5805
493.1291(c)
Test report content
Each report carries the required elements: patient name and identification number or a unique identifier, the laboratory's name and address, the report date, the test, the specimen source when appropriate, and the result with units or interpretation.
Typical finding: Reports from an interface or an EHR that drop the performing laboratory's address.
417
2.6%
IR-01 Self-Audit Checklist

Descriptions are our summaries. A template gives the record its structure. The procedures, the data and the readings in it are yours.

Top ten condition-level deficiencies

No.Tag and citationConditionLabs citedRelated documents
1D2016
493.803
Successful participation in proficiency testing738
4.39%
PT-01 Proficiency Testing Policy
PT-03 PT Result Review and Corrective Action
2D6000
493.1403
Laboratory director, moderate complexity709
4.22%
IR-03 Personnel File Checklist
3D6076
493.1441
Laboratory director, high complexity388
2.31%
IR-03 Personnel File Checklist
4D5400
493.1250
Analytic systems340
2.02%
PM-01 Procedure Manual Policy
PM-04 Method Verification Plan and Summary
PM-06 Maintenance and Function Check Log
PM-07 Calibration and Calibration Verification Record
5D2000
493.801
Enrollment and testing of proficiency testing samples218
1.30%
PT-01 Proficiency Testing Policy
PT-04 Enrollment and Calendar Tracker
6D6063
493.1421
Testing personnel, moderate complexity182
1.08%
IR-03 Personnel File Checklist
7D6033
493.1409
Technical consultant, moderate complexity189
1.13%
IR-03 Personnel File Checklist
CA-03 Role Assessment Forms
8D6168
493.1487
Testing personnel, high complexity172
1.02%
IR-03 Personnel File Checklist
9D6108
493.1447
Technical supervisor, high complexity110
0.65%
IR-03 Personnel File Checklist
CA-03 Role Assessment Forms
10D5300
493.1240
Preanalytic systems82
0.49%
QA-01 Quality Assessment Plan

The order is CMS's. Personnel conditions turn on whether the people in each role hold the qualifications in Subpart M. A checklist helps you gather the proof. It cannot make someone qualified.

What the list tells you

  • Logs beat memory. Temperature, maintenance and reagent findings are nearly always gaps in the record.
  • Competency is cited for detail. A missing procedure out of the six, or a first-year assessment a month late, is enough.
  • Proficiency testing needs an owner. Enrollment slips when the test menu changes, and unreviewed results turn a single miss into a condition-level finding.
  • The director's signature matters. Procedures, verification studies and IQCPs all need it before use.

What is the most common CLIA deficiency?

In CMS's 2024 list, the most-cited standard-level deficiency was D5413 under 42 CFR 493.1252(b): criteria for storage and operating conditions, such as temperature, not defined or not monitored. It was cited in 818 laboratories. Competency assessment policies under 493.1235 came second with 778.

What is the difference between a standard-level and a condition-level deficiency?

A standard-level deficiency is a failure to meet one specific requirement. A condition-level deficiency means the laboratory is out of compliance with a whole condition, such as proficiency testing or laboratory director, usually because the problems under it are serious or widespread. Condition-level findings carry heavier consequences and tighter timelines.

Which areas should a small laboratory check first?

The list points to five: temperature and storage records, competency assessments, the procedure manual, expiration dates, and proficiency testing enrollment and follow-up. The readiness check walks through them in about ten minutes.

Check your own laboratory

The free survey readiness check turns this list into yes-or-no questions and shows your gaps. The Inspection Readiness Kit has the full self-audit, a binder index and a plan of correction template.

Sources

Summaries on this page are ours and are written for convenience. The regulation and the agency documents control.