Signatures should also include the provider’s credentials. Medicare Comment#4: All entries must be legible to another reader to a degree that a meaningful review may be conducted. A statement that the entry is an addendum to the medical record (it is not appropriate to add an addendum to the medical record without identifying it as such). All notes should be dated, preferably timed, and signed by the author. 4) You can make corrections to paper medical records, too Illegible documentation may result in medication errors and incorrect diagnoses being assigned to the patient. This should be entered in a timely fashion. Coders responsible for reviewing documentation should be cognizant of providers who demonstrate patterns of insufficient documentation that necessitate addenda. 3. Would you be able to cite your source when it comes to Medicare’s definition of a reasonable time frame? Compliance Tips on Comment #4: Legibility of medical record documentation is not just a billing issue; it is a patient care issue. I agree. 2 The date and time will identify when the entry is made, regardless of whether it relates to prior events. Medicare Comment #5: Documentation is considered cloned when each entry in the medical record for a patient is worded exactly alike or similar to the previous entries. Can you tell me where that is referenced? <>/Font<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]>>/MediaBox[0 0 612 792]/Contents 27 0 R/Group<>/Tabs/S/StructParents 0/Annots[57 0 R 59 0 R]/ArtBox[0 0 612 792]/CropBox[0 0 612 792]/Parent 260 0 R>> The timing of a medical record note is especially important in an inpatient chart, emergency department settings, trauma settings, and critical care units. It is important to remember that medical record addenda need to be made to the original medical record, not just to the billing copy. Medical Records Documentation Title. Further, the author of the alteration must sign and date the revision. Failure to properly amend the medical record may give the appearance of “falsifying documentation,” which is considered fraudulent. 2014-12-01. Compliance Tips on Comment #1: Medicare has clearly stated that “reasonable” means 24 to 48 hours. It is important to remember that medical record addenda need to be made to the original medical record, not just to the billing copy. Draw a single line through the erroneous information, keeping the original entry legible. There are instances where an addendum or late entry is added after discharge. The argument will be made that if the medical record had contained some additional important items of patient history or findings, the patient’s unfortunate o… Similarly, amendments or delayed entries to Medical record addenda must be properly identified and reference must be made to the original note being amended. In addition to several other issues, the medical director touched upon the overall timeliness of documentation, medical record addenda, the legibility of medical records and medical record “cloning.” And preferably, that all entries are identified by the person who made them (initialed/signed) and the information is legible. 2. As a defendant under oath, you may be subjected to skillful cross-examination by opposing counsel and asked to recall and testify about intricate details of a patient’s care. Could you please provide the reference for Medicare statement? It is not reasonable to expect that a provider would normally recall the specifics of a service two weeks after the service was rendered. Pre-dating or backdating an entry is prohibited. Providers should submit adequate documentation to ensure that claims are supported as billed. 2. A late entry, an addendum or a correction to the medical record, bears the current date of that entry and is signed by the person making the addition or change. Delayed written explanations will be considered. Like late entries, it should also bear the current date, along with the reason for the addendum. A. If there is a delay, the time of the event and the delay should be recorded. Did a little bit of poking around but all I was able to locate is the following below but I will call out that it doesn’t specify the information listed above that we are all looking for. The medical record must be legible to an individual who is not familiar with the provider’s handwriting. 2 0 obj Specifically, it may seem obvious, but providers must ensure that what is being represented in the medical record actually took place and is not something that the provider normally does but may not have done for that particular patient. PROCEDURE FOR CORRECTING HAND-WRITTEN ENTRIES IN THE MEDICAL RECORD: 1. (ii) Name, number or other identification of the animal or group. Errors must be legibly corrected so that the reviewer can draw an inference as to their origin. 2. These changes to the EHR should always be made available to the user of the record unless such changes are detrimental (e.g., incorrect information was … �������s�H�W�Ǜ ��wg.� ���3�m���s?�U�P�W}���? Questions concerning whether a medical record was contemporaneous or modified arise from time to time in the course of proceedings before the courts and the Colleges. It’s unreasonable to expect a provider to recall the specifics of a service two weeks after the service was rendered. }qO��IܔnB~�>/��.,�ĻrwR�#��'��q*�ZY�Uf[�5s�v���2�ᯰy�o#)=��1��qz��JO. 2 “The medical record cannot be altered. (f) The author of all medical record entries must be identified by code or employee number, or initials. As such, it is important to understand that anything beyond 48 hours could be considered unreasonable. x���_hSW ���MV&!�BAA:&{�e�Ie�`O{1t�0�R,�� �Ӡ&>H�T{�۷� �A8�F�M�&�Z����ι�Ro��t��p�����7�=n@)d��7��`��`��`��`��`��`��`��`��`��`��`��`��`��`��`�����ge�n{ �a7���nv����f7���nv����f7���nv����f7�����n&�ǻ'��9YX�O ��������=Q����]�.�A��������T[�J������}�(J��a�����O�n9���}�9鵳��F�����k�t:�[ ������m��*���O�9��b����vWwja�n�Y!����#>�Ȟ�%�m1h�����\=�{ ���݋Rn����\��m1p7���r�`�wc�n�< �價���(�RX�����644��-;'� ��A���7�9���1��'�jgg��+�[��'���9�{�W!�+���ݚ��� �[��s[�� V 6�as޶î p̍a���} Informing colleagues who may see the patient subsequently and supporting continuity of care. Cloning of documentation is considered a misrepresentation of the medical necessity requirement for coverage of services. We are looking for thought leaders to contribute content to AAPC’s Knowledge Center. Place the date and your initials next to the word “ERROR.” These corrections or additions must be dated, preferably timed, and legibly signed or initialed. A review of these CMPA cases from 2003–2007 indicate that the most common issues arising from the modification of medical records were: 1. Every year at the AAPC national conference, several members of AAPC’s Legal Advisory Board present an open forum session to respond to a wide variety of questions from attendees. The signature of the provider writing the addendum. The General Medical Council clearly states that records should be made at the time the events happen, or as soon as possible afterwards. Usually, such details of the patient’s medical management relate to events that occurred years earlier. A late entry is made to the medical record when information that was absent from the original entry is recorded after the original note was created, dated, and signed. When rubber stamp signatures are authorized, the medical practitioner should place a If an omission in a medical record is noticed after a short amount of time and a physician can distinctly remember administering medication or other treatment, a late entry should be made. Recording Entries in the Medical Records 1. Sometimes services that may have been provided were not properly documented. All notes should be dated, preferably timed, and signed by the author. Ideally, all entries in the medical record should be made in black ink. This should bear the current date, and include a reason for the addition or clarification of information added to the medical record. Medical Record Entry Timeliness: What Is Reasonable? The entries in the record are made promptly. Every entry in the medical record must be authenticated by the author – an entry should not be made or signed by someone other than the author. Draw a single line through the incorrect information so that it is still legible. See detailed reference at https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/pim83c03.pdf, This is a link to the First Coast reference (see page 3) If an entry is made retrospectively on a paper document, it must reflect the date and time the See Medicare Program Integrity Manual, Verifying Potential Errors and Taking Corrective Actions, Chapter 3 § 3.3.2.5. An entry should never be made in the Medical Record in advance of the service provided to the patient. Yes, but only with simpler rules and coding, I Am AAPC: Julio Paque Pena, MHA, CPC, CPCO, CDEO, CPB, CPMA, CRC, Ensure Documentation Supports Reimbursement, The Scoring of Audits Gets Docs’ Attention and Takes Advantage of Their Competitiveness, https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs-Items/CMS019033.html, https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/pim83c03.pdf, https://medicare.fcso.com/Publications_A/2006/138374.pdf. �NB��C3Y�E�!��4-1G���� e��~ɺ���w��-5}իL�~�e��[�l����G������Q�\�$��йP�7! You should also contact your local insurance carriers to determine if private insurers follow Medicare's lead on all coding matters. Would you provide reference for Medicare Care statement, please. Providing evidence if the standard of your care is called into question. 2. Date. Specify in your record amendment policy the precise information that should be included when a correction, addendum, or late entry is made, such as (a) the date and time of the revision, (b) the name of the person making the revision, (c) a clear explanation of what information is being changed, and (d) the rationale for the modification. 4. I am also seeking clarification of CMS documentation requirements, but cannot locate the information at the CMS websites. A late entry provides additional information that was originally omitted from the charted documentation. (g) The records shall include, but not be limited to, the following: (i) Name, address and telephone number of the owner or authorized agent. 3.8 All entries in the medical records, including paper-based and computerized or electronic, must be dated and authenticated, and a method must be established to identify the authors of the entries. 1 0 obj F��(5a"ď���PӘ�wNGwץ�q�Uʷ�x�����:��tp���C1�,��h��[\���/P�atw\�M����[hl�}��N��9u^=���-�F���8"�0���fI�I�˅�$�V%ٝѽ��(�IC�6����郀���x�nj�E'p��A�QPWt�}I�:�h����_��� �1����J�.�v�$)? Late entries, addendums, or corrections to a medical record are legitimate occurrences in documentation of clinical services. Addendums to existing medical records must be made in a timely manner. B. They serve for clarification only and cannot be used to add and authenticate services billed and not documented at the time of service or to retrospectively substantiate medical necessity. Paper Medical Records: When correcting a paper medical record, these principles are generally accomplished by using a single line strike through so that the original content is still readable. Earn CEUs and the respect of your peers. endobj I know that it’s not a reasonable time frame as per MCR but is this still correct? Late Entry: A late entry supplies additional information that was omitted from the original entry. It goes without saying that the addendum should be signed by the person who originally drafted the note. Entries in Medical Records: Amendments, Corrections, and Delayed Entries All services provided to beneficiaries are expected to be documented in the medical record at the time they are rendered. Medical Records Documentation. whether in paper or electronic format. 2. Correction: When making a correction to the medical record, never write over, or otherwise obliterate the passage when an entry to a medical record is made in error. Can you also tell me what the guideline states about not submitting claims until the chart documents are completed? The following are some selected excerpts from the memo, followed by some practical compliance tips that apply to each issue raised. Medical records should not be withheld because an account is overdue or a bill is owed (including charges for copies or summaries of medical records). This issue has both billing and compliance ramifications. I was interested in locating the specific Medicare reference as noted above. Nor should an entry be made in advance. No one's memory is infallible. A lack of awareness as to how to appropriately modify a deficient medical record. Entries should be made when the treatment described is given or the observations to be documented are made, or as soon as possible thereafter. The medical record should be returned to the patient's veterinarian of record for completion BEFORE the doctor is allowed to depart for the day. As a contributor you will produce quality content for the business of healthcare, taking the Knowledge Center forward with your knowhow and expertise. %���� Medicare Comment No. In addition, notes should be timed and dated appropriately. 3. An addendum to a medical record provides additional information that was not available at the time of the original entry. I would like to know what the source was as well, but since the other requests were made in August 2017, and no response seems to be posted, exactly how much credence are we to give this article? Medicare Comment #3: Every note must stand alone, i.e., the performed services must be documented at the outset. Compliance Tips on Comment #3: Addenda to the medical record should not be a normal practice — these should be the exception and not the rule. Providers should comply with this requirement and complete documentation in a timely manner. For the past few years, without fail, numerous audience members have asked for guidance on the timeliness of entries to the medical record. I was told that the provider has 30 days from the time of visit to make an addendum. All entries in the medical record automatically identify the date and time of the entry. This is not an easy topic and there is no way to give one answer that will apply to the many scenarios that coders may encounter. All documentation in the medical record must be specific to the patient and her/his situation at the time of the encounter. Hi Robert/anyone that may have this information, Can you please provide the source of the information pertaining to timeliness of medical record documentation? Compliance Tips on Comment #5: Templates certainly are useful tools, but providers must use caution when applying “templated” language. However, if a day or more has passed, it is unlikely that the physician can reliably remember exactly what happened. By Robert A. Pelaia, Esq., CPC Timely Completion and Signing of Medical Records One concern I often hear from billing staff has to do with the timely completion of medical records. Identification of this type of documentation will lead to denial of services for lack of medical necessity and recoupment of all overpayments made. Occasionally, certain entries related to services provided are not properly documented. An entry should never be made in advance. %PDF-1.3 The absolute minimum standard for accurate medical record keeping requires that records be legible (preferably not hand-written and ideally digital) and contain: Patient demographics, such as name, date of birth, and contact details. https://medicare.fcso.com/Publications_A/2006/138374.pdf. It serves as a communication vehicle for healthcare providers; it tells the patient’s story as well as the care that has been received. Those responsible for coding and/or entering charges need to be cognizant of the timeliness of medical record completion. Thank you. Cloning also occurs when medical documentation is exactly the same from patient to patient. Corrections, amendments, clarifications, and additions to a medical record are a normal part of clinical documentation. Cloned documentation does not meet medical necessity requirements for coverage of services rendered due to the lack of specific, individual information. See link to https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs-Items/CMS019033.html change in clinical state, ward round, investigation) and before the relevant staff member goes off duty. A reminder of what happened during a consultation, actions, steps taken and outcomes. I would like the CMS documentation requirements listing 24-48 hours as well. For that, the medical record must stand on its own with the original entry corroborating that the service was rendered and was medically necessary. Those responsible for coding and/or entering charges need to be cognizant of the timeliness of medical record completion. Medical Documentation: Amendments, Corrections and Delayed Entries All services should be documented in the patient's medical record at the time they are rendered. Copying for re-use of data: A clinician may copy and past entries made in a patient’s record during a previous encounter into a current record as long as care is taken to ensure that the information actually applies to the current visit, that applicable changes are made to variable data, and that any new information is recorded. `���O�Ծ�. {u�>z� ��_&-�v܇�E_�CjSK�}�� Sign and date the deletion, stating the reason for correction above or in the margin. Entries to the medical record should be made as soon as possible after the event to be documented (e.g. Clinical records fulfil several important functions. This includes all types of entries such as narrative/progress notes, assessments, flowsheets, orders, etc. Write the word “ERROR” above or beside the original entry. Medical record entries must be completed in a timely manner. Medicare Comment #1: Medicare expects the documentation to be generated at the time of service or shortly thereafter. In Good Medical Practice, the GMC says you 'must record your work clearly, accurately and legibly.' Medical records fall under this exception provided that method of record keeping conforms to certain established guidelines: The record was made in the regular course of business. All entries in the medical record shall be factual; irrelevant information and An entry should never be made in advance. Editing medical records is evidence that they are inaccurate and makes them impossible to defend. All Medical Record entries should be made as soon as possible after the care is provided, or an event or observation is made. Should it be the licensee’s policy to complete insurance or other forms for established patients, it is the position of the Board that the licensee should complete those forms in a timely manner. The date of service of the service being amended. The record was created a significant time after the clinical care was provided. The medical record is a legal document that is required by law and regulatory bodies. Compliance Tips on Comment #2: To properly execute a medical record addendum, the provider must, at a minimum, write the following details in the medical record: The medical record should be amended within a reasonable period of time that would allow the provider of service to recall the specific details of the patient encounter. It would not be expected that every patient had the exact same problem, symptoms, and required the exact same treatment. This late entry or addendum can be used, for abstraction purposes, as long as it has been added within 30 days of discharge, [Refer to the Medicare Conditions of Participation for Medical Records, 42CFR482.24©(2)(viii)], unless otherwise specified in the data element. Medical record addendums should be an exception rather than a routine or recurring part of medical record documentation. The medical director of First Coast Service Options, Inc. (FCSO), the Medicare Part B carrier for Florida and Connecticut, recently issued some useful and practical guidance regarding medical record documentation. Suddenly, a few seemingly unimportant details can become the focal point of allegations. 4��E]'Eשo�q�?xO}ԝtq���!��[]�J�=��n ʱ���e8رYj\w�P�� It is especially critical that the identity of the provider of service be legible. ?�Wf)����N�2%Iw����:��.k����qK�ƩB�cNnY�]���n8WW�E��/8���c%��F���g��G�e�.��z�sr�k���!`fy)*���n8�GQݫR�+��^ �,5�S��0�������u{J�ry�k���Tt�3�V�2]R6Ѷ���/{7�Nww­���/���kR_��������.cn��܎�]j:�0�|t�c�Ӣ �1]�K�;s�sw����ɓ�لz9!�^Ԋ5�Wu���U�@sWp�^����ŹB�큻�Z���: g%�W�BS w����#0����Q�}��^o��E������u���]��>����������~Q��ʈe~��N�w�/>����Љ�ٟ��.��܉qo����܊�R�Q3���vn�l�ü+�̫:�-��K�\�7^�HS�c~^�K�̋ڛWCi�q'뼤� ޝ�K� 1. For more information, please refer to Complying With Medical Record Documentation Requirements Fact … 3. This would make it simple to produce a photoreproduction and ensure that the subsequent copies would be legible. 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