Review of Systems audit perfection

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I am the Medical Director of a surgical group practice. We recently started using a new auditor for our medical records. The new auditors keep excluding our Review of Systems as invalid because they might not exactly match the rest of the medical record. I have argued that the review of systems is noted as done and often detailed, but they argue that it must match perfectly with the rest of the record or it is invalid and they will not count it on the check off audit sheet as done. For example, if someone is in for a chief complaint of ingrown nail but on the ROS sheet they do not circle "foot pain" and this section is marked as normal or all denied, then the ROS is invalid as it is not complete. This sounds too nit picky to me. Has anyone every heard or see this in a insurance company or Medicare audit where the ROS was not counted as done because it was not exactly correct? Do any of you agree that the auditors should be excluding the ROS as done because it is not perfect??
Coastal Coders
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Your new auditors are pointing out contradictions in the documentation.
How is this information getting into your EMR?
I suspect the auditors will stop once the contradictions cease.
If you have staff entering this data into the EMR then perhaps some additional training is appropriate.
If you are scanning a pt completed sheet into some sort of pt documents folder and referencing that as your ROS then you need to insure there are no contradictions.

As far as not counting goes I know that highly trained auditors will pull ROS components from where ever they may find them. If they are simply relying on a ROS section then I suspect you have employed an incorrect team.


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I'm not a trained auditor but do informal audits for some of my colleagues. Usually, when I find a discrepancy between the ROS and other parts of a record, the EHR system has been cloning the ROS and, even though the provider may "review" the ROS, they often make errors.

One of the most common errors I find have to do with discrepancies between the medications and the ROS. An example would be where the ROS says there are no cardiovascular problems but, since it was done, the patient has been put on BP medications by their PCP which are listed in the medications the patient is taking.

It sounds to me like your auditing group is trying to make sure that your providers are really accurate when they say they have reviewed the ROS, which, in the long run, would be to your benefit in a formal audit. Remember that MAC auditors get paid a percentage of the fees they recover so they have an incentive to be nit picky.

Tom Cheezum, O.D., CPC

rebecca lopez

Local Chapter Officer
San Gabriel Valley
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Can someone comment on The ROS statement , I heard from a workshop that the Qualifying statement can't be used anymore to count towards a comprehensive ROS

" all 14 ROS system reviewed and negative other than mentioned in HPI"

it triggers something, but I can't remember.
if some one can email me at:


Cary, NC
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Hi Rebecca,

This reference from CMS might help you:

A complete ROS inquires about the system(s) directly related to the problem(s) identified
in the HPI plus all additional (minimum of ten) organ systems. You must individually
document those systems with positive or pertinent negative responses.
For the remaining
systems, a notation indicating all other systems are negative is permissible.
In the
absence of such a notation, you must individually document at least ten systems.

I use this to refer back to sometimes when it's been a while in between audits and being from CMS there's not much that the RACs and MACs can come back at you with if you are following the guidelines.

I hope this helps!