Pediatric Coding Alert

Documentation:

Take Time to Fine-Tune Your Documentation Practices

Protect patients, providers with these 21 elements, 6 core components, and 5 tips.

If you haven’t reviewed your documentation practices recently, maybe it’s time to do some spring cleaning and get your medical records back into shape. Not only will your patients benefit from the improved quality of care they will receive as a result, but your compliance program will get a real shot in the arm as well.

Getting such a program off the ground, or even maintaining an existing one, can be a daunting prospect. So, here are some suggestions that will help you examine your medical record documentation more closely than ever before.

Tip 1: Know 6 Core Components of NCQA Guidelines

You may be familiar with the National Committee for Quality Assurance (NCQA), the healthcare accreditation and certification organization responsible for the Healthcare Effectiveness Data and Information Set (HEDIS) performance measurement tool used throughout the healthcare industry. But what you may not know is that they have produced a comprehensive set of Guidelines for Medical Records Documentation that “reflect a set of commonly accepted standards for medical record documentation.”

These standards consist of 21 elements, which include the following six best practices, or “core components to medical record documentation”:

  • Significant illnesses and medical conditions are indicated on the problem list.
  • Medication allergies and adverse reactions are prominently noted in the record. If the patient has no known allergies or history of adverse reactions, this is appropriately noted in the record.
  • Past medical history (for patients seen three or more times) is easily identified and includes serious accidents, operations and illnesses. For children and adolescents (18 years and younger), past medical history relates to prenatal care, birth, operations and childhood illnesses.
  • Working diagnoses are consistent with findings.
  • Treatment plans are consistent with diagnoses.
  • There is no evidence that the patient is placed at inappropriate risk by a diagnostic or therapeutic procedure.

(You can view the full NCQA guidelines by going to www.ncqa.org/wp-content/uploads/2018/07/20180110_ Guidelines_Medical_Record_Documentation.pdf).

Tip 2: Document Patient’s Allergies

“Often, audit findings show there is no documentation of medication allergies, adverse reactions, or known allergies [NKA] status,” says Laurie Bouzarelos, MHA, CPC-A, contracting and chart auditing specialist at Physician’s Ally Inc. of Littleton, Colorado. This means you should pay special attention to the second of the NCQA core components.

This means documenting pertinent negatives, as they are “just as important as pertinent positives, and silence in the medical record should not necessarily be interpreted to mean negative or not applicable,” notes Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

This “is consistent with the documentation guidelines for evaluation and management [E/M] services related to ROS and the exam, which refer to documenting pertinent/relevant negatives as well as positives,” Moore points out.

Tip 3: Ensure Record Explicitly States Follow-Up Plans, Care

Bouzarelos also highly recommends following guideline 14 of the full NCQA guidelines regarding follow-up plans and subsequent care.

“Notes should also include follow-up care, calls, or visits, if applicable, and the record should state the time of return specifically,” Bouzarelos advises.

Tip 4: Make Sure to Note Record’s Author

“In most audited charts, there is no indication of who is entering the items in the medical record,” says Bouzarelos. So, Bouzarelos recommends following element 3 of the full guidelines, which states that medical record entries should “contain the author’s identification.” This can take the form of a handwritten signature, unique electronic identifier, or initials.”

You can do this by turning on this function on in your electronic medical record (EMR) “by entry, not by the entire chart,” according to Bouzarelos. This way, you can be sure the author of a note, whether it be a scribe, medical assistant, physician, or nurse, will be clear — an important detail in the team-based environment of pediatric care.

Tip 5: Make Sure Signoff Is Timely

You won’t find this on the NCQA list, but Bouzarelos and Moore both believe that notes should also be signed off within 48 hours of a physician providing a service. Bouzarelos’ audits, for example, have shown a range from 0 to 58 days for signoff, with one audit of 24 charts showing a nine-day average. “Plenty of things can be forgotten or misrepresented over this period of time,” Bouzarelos cautions, leaving practices wide open to problems down the road.

The confusion over the optimal time to sign off on a note comes from an ambiguity in Medicare guidelines. Section 30.6.1(A) of Chapter 12 of the Medicare Claims Processing Manual, for example, gives no specific time parameters for documenting services, just that it should happen “during, or as soon as practicable after it is provided, in order to maintain an accurate medical record.”

This has led to “Medicare administrative contractors [MACs] offering their own interpretation of what this means. WPS GHA [the MAC for Indiana, Iowa, Kansas, Michigan, Missouri, and Nebraska] medical directors, for example, support offering a reasonable time frame of between 24 and 48 hours,” Moore notes. (See, for example, www.wpsgha.com/wps/portal/mac/site/claims/guides-and-resources/completion-of-documentation/.)