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May 2 2013

Hospital suspensions related to failure to complete medical records (yes, those are actions too)

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Image for Hospital suspensions related to failure to complete medical records (yes, those are actions too) Note from the author (added October 2016): Although the basic underlying concept that “The Board believes accurate, current, and complete medical records are an essential component of patient care” remains valid, hospitals are no longer required to report to the Board changes in staff privileges for delinquent medical records, and such changes in staff privileges, such as temporary privilege restrictions or suspensions, are no longer reported on a licensee's Medical Board information page.

Since the fall of 2009, the NCMB has been implementing and refining the expanded licensee information system mandated by the North Carolina General Assembly. As part of this work, last fall the Board began posting on its website hospital privilege suspensions related to failure to timely complete medical records. Hospitals are currently required by state law to report these actions to the Board when a licensee receives three suspensions of this type in a calendar year. These actions have been available to the public through the NCMB for several years. Until relatively recently, however, the NCMB did not post them on the Board’s website. Only privilege suspensions and revocations that stemmed from concerns about clinical competence or willful misconduct were posted to the site.

This column will discuss the recent change in Board policy regarding suspensions related to failure to complete medical records and highlight some resulting changes to how those actions are displayed on the NCMB’s website.

What changed?
Last year, the NCMB spent some time carefully considering its handling of hospital privilege suspensions related to failure to timely complete medical records. The Board analyzed the seriousness of these suspensions compared to others. Part of the analysis included a discussion of how the NCMB might differentiate medical records-related suspensions from those related to competence or misconduct.

Ultimately, it was decided that suspensions for failure to complete medical records should be published on the Board’s website and the relevant staff were directed to come up with a means of differentiating between adverse actions and administrative actions such as the records-related hospital suspensions. Staff began posting newly reported hospital privilege actions in this category in the fall. To be fair, and to ensure the accuracy and completeness of information on each individual’s Licensee Information (LI) page, the Board staff also began the process of reviewing all privilege actions that had been previously reported to ensure that all actions that meet criteria are posted.

As Board staff began posting records-related suspensions from the last few years, it notified licensees of the changes. We quickly heard back from a number of licensees who weren’t happy to see a suspension for failure to timely complete medical records on their otherwise clean public record.

As a former hospital-based physician (before joining the Board’s staff, I practiced emergency medicine in Raleigh) I can understand licensees’ frustrations. The vast majority of suspensions related to late medical records are temporary —many are resolved within a day or two—and they rarely, if ever, involve concerns about patient care. Yet a public report of a hospital “suspension” can have adverse effects on a physician or PA that may include real or perceived dings to professional reputation or difficulties with recredentialing.

Why records are important
I don’t want to minimize in any way the importance of timely completion of medical records. The Board believes that accurate, current and complete medical records are an essential component of patient care. Significant delays in the completion of medical records diminish both the accuracy and credibility of the records, and may create confusion among others treating the patient. The Board expects licensees to properly document medical care in an accurate and timely manner.

When the Board receives information that a licensee’s hospital privileges have been limited, suspended or revoked (a Change in Staff Privileges or CISP), it has a duty to investigate. Depending on the seriousness of the allegation and corresponding level of concern, the Board may conduct a field investigation or require the licensee to respond in writing with an explanation that provides their side of the story. The licensee conduct that led to a CISP may or may not result in a disciplinary action by the Board (most often it does not). In the case of a CISP related to failure to timely complete medical records, the licensee is expected to notify the Board, in writing, within 30 days that all delinquent medical records have been completed and that privileges have been restored.

NCMB’s duty to publish
Pursuant to NCGS 90-5.2 (a) (8), (b) the Medical Board is required to publish actions by health care institutions that suspend or revoke a licensee’s privileges. Corresponding rules state that these actions are to be displayed on the Board’s website (they appear on the individual’s LI page) for a period of 7 years.

The rules do not differentiate between hospital actions related to medical records as opposed to actions related to clinical competence or quality of care. However, the Board recognizes that there is a qualitative difference between them. Consequently, the Board recently modified how these actions are displayed on licensee information pages. The revised page layout now includes a section for administrative actions, including hospital suspensions related to failure to timely complete medical records. The administrative actions section is labeled to indicate that the actions listed are considered non-disciplinary by the Board and involve issues such as failure to meet certain statutory requirements or failure to follow correct administrative procedures. The Board and its staff hope that these changes will prevent confusion about the nature of posted actions and prevent undue negative consequences to licensees. Note to hospitals Finally, it must be noted that it is clear to the Board that some CISP reporting requirements are being unevenly applied by health care institutions. In reviewing suspensions related to failure to timely complete medical records, it quickly became apparent that some hospitals are reporting these suspensions in accordance with the law and some, it seems, are not. If you are a hospital administrator or chief of staff reading this article, please understand that the Board expects you to equitably and fairly comply with reporting requirements as outlined in this article. The Board accepts change in staff privilege (CISP) reports via its website.
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Licensee Tip
Licensees are sometimes confused about what information they are required to disclose to the Board regarding hospital actions. Licensees are required to report ANY limitation, suspension, revocation or other action by a hospital or health care institution at the time of annual renewal. This is true even if the licensee is aware that the hospital has already reported the action to the Board.

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