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Successfully ReduceDelinquencies: Proven

Techniques from the Trenches

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Tuesday, May 10, 2005

ii Successfully Reduce Delinquencies: Proven Techniques from the Trenches

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iiiSuccessfully Reduce Delinquencies: Proven Techniques from the Trenches

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iv Successfully Reduce Delinquencies: Proven Techniques from the Trenches

Dear Colleague,

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vSuccessfully Reduce Delinquencies: Proven Techniques from the Trenches

Agenda . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .vi

About your sponsors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .vii

Speaker profiles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

Exhibit A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 Presentation by Rose T. Dunn, RHIA, CPA, FACHE, and Eileen M. O’Heron, RHIA

Exhibit B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22Operative record document

Exhibit C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Excerpt from More with Less: Best Practices for HIM Directors by Rose T. Dunn, RHIA,CPA, FACHE, HCPro, Inc., 2004

Exhibit D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37Articles taken from HCPro’s monthly newsletter Medical Records Briefing

- AL hospital turns around delinquent record rateCommunication, revised rules, facilitywide effort all help with dramatic reduction(April 2005)

- Delinquent records trouble spotSurvey shows 9% cited by JCAHO in this area(February 2005)

Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43

Contents

vi Successfully Reduce Delinquencies: Proven Techniques from the Trenches

Agenda

I. Delinquency: Definitions and calculationsa. CMS v. accreditation agenciesb. What is an acceptable delinquency rate?

II. Health record content requirementsa. CMS v. accreditation agenciesb. Streamline and reconcile your bylaws, rules and regulations,

and policies

III. HIM department responsibility and timely record completiona. Processing timelinessb. Pros and cons of concurrent analysisc. HIM’s role in nonphysician deficiencies

IV. Case study (Rush Copley Medical Center): JCAHO s tracer method-ology process

V. Tips and Toolsa. Utilizing methods approved by CMS and JCAHOb. Making it fun for the physiciansc. Reducing obstaclesd. When the “carrot” doesn’t work

VI. How to gain administrative support

VII. Live Q&A session

viiSuccessfully Reduce Delinquencies: Proven Techniques from the Trenches

About HCPro, Inc.

HCPro is the premier healthcare information and resource provider on compliance and regulatory issues facedby hospitals, home-health organizations, nursing homes, physicians’ offices, and other healthcare facilities.HCPro has launched a number of Web “supersites” that include tips, how-to information, “ask the expert”columns, free e-mail newsletters, and so much more.

About Medical Records Briefing

Medical Records Briefing is a respected monthly newsletter that provides the best new ideas in health informa-tion management (HIM), plus a whole set of professional resources to benefit the medical records department.Each issue is full of crucial information such as the latest Medicare changes; practical advice on tough legal,financial, privacy, and human resource issues; as well as real-life success stories from other managers.

Your subscription to Medical Records Briefing keeps you up to date on • the latest changes to JCAHO IM standards • coding and transcription management • documentation and physician relations • the latest final rules and OIG reports • HIM and the revenue cycle • HIPAA and the privacy and security of health information

With Medical Records Briefing, readers discover the latest industry developments and trends shaping the field ofHIM.

Some free subscriber benefits include:

• Regular benchmarking surveys of readers • MRB Talk—our Internet discussion group where readers can network with their peers • Fax express—whenever news happens that just can't wait, subscribers receive the pertinent information by

fax so they'll always be the first to know • A Minute for the Medical Staff—six times a year, Dr. Robert Gold addresses physicians to help them under-

stand the importance of coding and billing

Available online!

Save time and shipping costs by receiving your issue of Medical Records Briefing right on your computer with

About your sponsors

viii Successfully Reduce Delinquencies: Proven Techniques from the Trenches

the click of a few buttons! We'll alert you via e-mail each month when your new issue is ready. Just order theelectronic version of the newsletter in the option box below. Order both our print and electronic versions byselecting “Print and Electronic” in the option box.

If you have questions regarding the coverage/content of this product, contact Senior Managing Editor Beth Easleyat [email protected]

ixSuccessfully Reduce Delinquencies: Proven Techniques from the Trenches

Speaker profiles

Rose T. Dunn, RHIA, CPA, FACHE

Rose T. Dunn, RHIA, CPA, FACHE, is a former AHIMA president and recipient of AHIMA’s 1997Distinguished Member Award. She is chief operating officer of First Class Solutions, Inc., of St. Louis, MO.

Rose started her career as director of medical records at Barnes Hospital, a 1,200-bed teaching hospital inSt. Louis. She was promoted to vice president at Barnes and was responsible for more than 1,600 employ-ees and new business development.

After Barnes, she joined MetLife where she worked with managed care organizations nationwide on a varietyof operational, medical management, and network development issues. Rose also has served as a chieffinancial officer of a dual hospital system in Illinois.

She is active in several professional associations including AICPA, ACHE, HFMA, and AHIMA. She holds fel-lowship status in HFMA, ACHE and AHIMA. She is also a certified in healthcare privacy and security.She is the author of several texts, including Finance Principles for the Health Information Manager, More withLess, and Haimann’s Healthcare Management. In addition, Rose has published more than 200 articles and hasmade numerous presentations across the United States on a wide variety of topics.

Eileen M. O’Heron, RHIA

Eileen M. O’Heron, RHIA, is director of medical records at Rush Copley Medical Center in Aurora, IL, andhas held many positions over the past 23 years, including director of medical records at Morris Hospital inMorris, IL, and manager of medical records at Central Dupage Hospital in Winfield, IL.

Eileen recently successfully completed a JCAHO survey under the new tracer methodology process, andthe hospital demonstrated excellent compliance with the IM standards, including those involving delinquentmedical records.

Eileen is affiliated with AHIMA, the Illinois Health Information Management Association, and the ChicagoArea Health Information Management Association. She is currently a resident of Illinois. She received herbachelor’s degree in medical records administration in 1982 from Illinois State University.

Andrea Dickey

Andrea Dickey (moderator) edits the HcPro e-zines HIM Connection, EHR Connection, and ExecutiveBriefings Digest. She also writes for Medical Records Briefing and HcPro’s newest newsletter, ElectronicHealth Records Briefing.

Exhibit A

Presentation by Rose T. Dunn, RHIA, CPA, FACHE, and Eileen M. O'Heron, RHIA

Disclaimer:Some of the information provided by Rose T. Dunn, RHIA, CPA, FACHE in this program may have beenshared at National AHIMA or CSA educational programs, or published in the journal of AHIMA orother publications

EXHIBIT A

Successfully Reduce Delinquencies: Proven Techniques from the Trenches

1

Successfully ReduceDelinquencies: ProvenTechniques from theTrenches

Rose T. Dunn, RHIA, FAHIMA, Chief Operating Officer

First Class Solutions, Inc., St. Louis, MO

Eileen M. O'Heron, RHIA, Director Medical Records

Rush Copley Medical Center, Aurora, IL.

2

Why Should We Be ConcernedAbout Incomplete and

Delinquent Medical Records?


EXHIBIT A

3

Some of the Reasons

� Medico-Legal

� Business Record Rule

� Hinders Workflows

� Another place to look

� Delay in processing requests for copies

� Patient/Other

� Payer

� Quality of the record

� As it ages, the details become more gray

4

Some of the Reasons

� CMS

� Conditions of Participation

� Visit from the CMS Team

� 45 days to demonstrate resolution

� Sometimes as short as 7 days

� Lose Medicare reimbursement

� State

� Same rules as CMS or more stringent

� Lose facility licensure

EXHIBIT A


5

Some of the Reasons

� JCAHO (Joint Commission on Accreditation

of Healthcare Organizations)

� Triple whammy (IM6.10/LD1.30/MS3.20)

� Most frequent recommendations (6.10,6.50and

6.30 – also 3.10)

� HFAP (Healthcare Facilities Accreditation

Program) #5

6

Delinquency:Definitions and Calculations


EXHIBIT A

7

What is a Delinquent Medical Record?

� JCAHO/HFAP: 30 days from discharge

� CMS-COP: 30 days from discharge

� States: Vary—some as low as 14 days from

discharge

� Can’t use date of analysis

8

What is an AcceptableDelinquency Rate?

� CMS: 0%

� State: 0%

� HFMA Self Assessment: �5-10%

� 10% is achievable

EXHIBIT A


9

Calculating Delinquency Rate� JCAHO Formula

� First calculate the average monthly discharges—thedenominator

Average Monthly Discharge Rate (AMD):

� Total number of inpatient discharges in the 12 monthsprior to survey ÷ 12

� Rolling 12 month period

� This number represents all inpatient and can includeother records such as:� observation cases,

� ambulatory surgery,

� endoscopy,

� cardiac catheterization, or

� emergency department

� Must represent record types that are analyzed

� Does not include any other type of ambulatory/outpatientencounter

10

Calculating Delinquency Rate

� JCAHO Formula

� Second capture the delinquent record count—the

numerator

� The Delinquent Record Count

� Can be an average of delinquent counts for the month

� Can be the delinquent count at the end of the month

� Can be the delinquent count on the day of the MRC

� Consistent and Documented

� Count

AMD


EXHIBIT A

11

What is Complete?

� Your Bylaws

� Your Rules

� State requirements

� Federal requirements

� Don’t overdue it

12

Reducing the Count

� Rewrite Completeness Policy

� JCAHO’s minimum requirements for the content

of the medical record

� The JCAHO IM.6.10 standard, EP 5:

� Minimum to be authenticated:

� H&P,

� Operative Report,

� Consultation, and

� Discharge Summary

EXHIBIT A


13

Reducing the Count

� If these “four core elements” are not present

� Within 30 days of discharge,

� Counted as delinquent

� Flag other Items for completion

� Considered incomplete rather than delinquent

� Do not include them in the count

14

Reducing the Count

� If your analysis process is computerized,� Create a report to pull only the four core elements

� Greater than 30 days old to determine the delinquencycount

� Physicians do not have to know the differencebetween delinquent and incomplete items as youwant all of the items to get done!

� Only difference is the way you calculate the HospitalMedical Record Statistics form to determinecompliance with IM.6.10, EP10 based on yourhospital policy


EXHIBIT A

15

What is Complete?

Accreditation requirements� www.JCAHO.org (order standards)

� FAQs:http://www.jcaho.org/accredited+organizations/hospitals/standards/hospital+faqs/faq+index.htm

� www.HFAP.org (order standards)� FAQs:

http://www.jcaho.org/accredited+organizations/hospitals/standards/hospital+faqs/faq+index.htm

� COP requirements� http://www.access.gpo.gov/nara/cfr/waisidx_99/42cfr482_9

9.html

� http://www.cms.hhs.gov/cop/1.asp

� http://www.cms.gov/manuals/107_som/som107ap_a_hospitals.pdf

16

New Proposed CMS-COP Rules

� Federal Register 3/25/05

� H&Ps

� Verbal Orders

� Post Anesthesia Evaluation

EXHIBIT A


17


� H&Ps -- 482.22(c)(5) and 482.24(c)(2) (i)� Current:

� H&P no more than 7 days prior or within 48 hours of admit

� By MD, DO, Oral Surgeon (when admit is for oral surgery)

� Proposed:

� Recognizes conflict with JCAHO’s 30 days allowance withupdate

� H&P must be completed no more than 30 days before or 24hours after admission (updated if prepared in advance ofadmission)

� By a MD, DO, or other qualified individual who has been grantedthese privileges by the medical staff in accordance with State law

� Placed in the records within 24 hours of admission

18


� Verbal Orders – 482.23 (c)(2)(ii)

� Current:

� Must be signed or initialed by the prescribing practitioner

as soon as possible

� Telephone or oral orders

� Proposed:

� Combine terminology—verbal orders

� 482.24 (c)(1): All patient record entries must be legible,

complete, dated, timed and authenticated by whomever

is responsible for providing or evaluating a service

provided.


EXHIBIT A

19


� Verbal Orders – 482.23 (c)(2)(ii)

� Proposed:

� All orders, including verbal orders, must be dated, timed and

authenticated promptly by the prescribing practitioner, except

� For the next 5 years (after the rule is final)—authenticated by the

prescribing practitioner or another practitioner who is responsible

for the care of the patient and authorized to write orders by

hospital policy, even if the order did not originate from him/her.

� CMS will re-evaluate in 5 years

� 482.24 (c)(1)(iii): Require all verbal orders to be authenticated

in accordance with specific timeframes defined in State or

Federal law, or within 48 hours. Silent about preempting State

law if State law is a broader specific timeframe.

20


� Post Anesthesia Evaluation – 482.52 (b)(3)

� Current: Must be completed by the individual whoadministered the anesthesia

� Proposed: Post anesthesia evaluation report to bewritten by an individual qualified to administeranesthesia.

� Watch for these proposed rules to befinalized� Revise your Bylaws, Rules, and Regulations

accordingly

EXHIBIT A


21

HIM Department’s Rolein Timely Record Completion

22

Chicken-Egg

� All discharges/encounters must be received

� Analysis must be current

� Transcription must be current

� Access to the records by the physicians� Space and equipment

� Quiet

� Treats

� Restricting access by others

� Not there? Can’t be Completed.

� Continuous reporting of results


EXHIBIT A

23

Why Wait UntilDischarge?

Rush Copley Medical Center’s

Case Study

24

JCAHO TRACER METHODOLOGY

� JCAHO now looks at concurrent charts so

they must be accurate, timely & complete

at the point of care

� Reviewing records for deficiencies at the

point of care gets a jump start on the analysis

process and fewer items need to be flagged

post discharge, thus reducing the number

of delinquent charts

EXHIBIT A


25

Concurrent AnalysisImplementation Strategies� Leveraging the charting function

� Analysis

� Trainer

� Expanding e-Sig capability/functionality

� Involve the caregivers

� Compliance

� Provide them with adequate supplies

� Support the data collection and displaycomponent

26

Concurrent Analysis-Cons

� Apathy

� Time

� Labor


EXHIBIT A

27

Physicians and PhysicianExtenders ONLY

� Others employed to watch non-physicians

� Limits exposure to “What is a complete

record?”

28

Tips and Tools

EXHIBIT A


29

Utilize “Tools” Allowed

� CMS-COP: Alternative signature methods� 482.24 ��

��

� http://www.cms.hhs.gov/manuals/pub07pdf/AP-a.pdf pg. A-37

� JCAHO: Minimum signature requirements� IM.6.10

� H&P

� Operative Report

� Consultations

� Discharge Summary

32

How to Reel Them In

� HIM is NOT fun for Physicians

� Make it fun

� Awards-Oscars

� Food

� Location

� Prizes

� Be careful

� Hours of Access

30


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kin

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and

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must

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to i

nd

icat

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an s

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nst

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ies

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ind

ivid

ual

rec

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.

o

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mai

l sy

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in

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ent

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tify

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cord

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d v

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r ac

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cy.

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yst

em o

f au

to-a

uth

enti

cati

on

in

wh

ich

a p

hy

sici

an o

r o

ther

pra

ctit

ion

er a

uth

enti

cate

s a

rep

ort

bef

ore

tr

ansc

rip

tio

n i

s n

ot

con

sist

ent

wit

h t

hes

e re

qu

irem

ents

. T

her

e m

ust

be

a m

eth

od

of

det

erm

inin

g t

hat

th

e p

ract

itio

ner

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t, a

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it w

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bed

.

EXHIBIT A


INT

ER

PR

ET

IVE

GU

IDE

LIN

ES

- H

OS

PIT

AL

S

TA

G

NU

MB

ER

RE

GU

LA

TIO

N

GU

IDA

NC

E T

O S

UR

VE

YO

RS

Su

rvey

Pro

ced

ure

s: §

48

2.2

4(c

)(1

)

Ver

ify

th

at e

ntr

ies

are

auth

enti

cate

d;

Ver

ify

th

at t

he

dep

artm

ent

mai

nta

ins

a cu

rren

t li

st o

f au

then

tica

ted

sig

nat

ure

s, w

ritt

en i

nit

ials

, co

des

,

and

sta

mp

s w

hen

su

ch a

re u

sed

fo

r au

tho

rsh

ip i

den

tifi

cati

on

.

Ver

ify

th

at c

om

pu

ter

or

oth

er c

od

e si

gn

atu

res

are

auth

ori

zed

by

th

e h

osp

ital

's g

ov

ern

ing

bo

dy

an

d t

hat

a

list

of

thes

e co

des

is

mai

nta

ined

un

der

ad

equ

ate

safe

gu

ard

s b

y t

he

ho

spit

al a

dm

inis

trat

ion

. V

erif

y t

hat

th

e h

osp

ital

's p

oli

cies

an

d p

roce

du

res

pro

vid

e fo

r ap

pro

pri

ate

san

ctio

ns

for

un

auth

ori

zed

or

imp

rop

er

use

of

the

com

pu

ter

cod

es.

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amin

e th

e h

osp

ital

's p

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cies

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d p

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du

res

for

usi

ng

th

e sy

stem

, an

d d

eter

min

e if

do

cum

ents

are

b

ein

g a

uth

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cate

d a

fter

tra

nsc

rip

tio

n.

A1

05

(2

) A

ll r

eco

rds

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st d

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men

t th

e fo

llo

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g,

as a

pp

rop

riat

e.

A1

06

(i

) E

vid

ence

of

a p

hy

sica

l ex

amin

atio

n,

incl

ud

ing

a h

ealt

h h

isto

ry,

per

form

ed n

o m

ore

th

an 7

day

s p

rio

r to

ad

mis

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in 4

8

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urs

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issi

on

.

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07

(i

i) A

dm

itti

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Dia

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s

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rvey

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ced

ure

s: §

48

2.2

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)(2

)

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ify

th

at t

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ien

t's m

edic

al r

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rd c

on

tain

s d

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men

tati

on

of

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hy

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l ex

amin

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n p

erfo

rmed

w

ith

in t

he

req

uir

ed t

ime

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iod

.

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ify

th

at t

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pat

ien

t re

cord

s co

nta

in t

he

foll

ow

ing

in

form

atio

n:

o

A

dm

itti

ng

dia

gn

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on

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n r

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rt d

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men

ted

as

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al s

taff

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licy

;

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epo

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ast

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:

--

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ame

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ame

of

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spit

al


EXHIBIT A

33

Reduce Obstacles

� Get rid of stacks

� Use GOOD tags

� If EHR

� Build in edits to reduce analysis time/effort

� Establish queues

� Review the documentation requirements

� Revise/combine forms

� Combine Operative Worksheet and Post Op Progress Note

� Develop a form that has the Post-op Progress Note and the

components of the discharge summary (ambi-surg)

34

Give Them Information

� Delinquency Rate by Physician

� Incomplete Rate by Physician

� Good Guys List

� Get Close and Personal—to the Office

Manager

EXHIBIT A


35

Delinquency Profile

PROFILE FOR: Dr. D. Butcher CLINICAL SERVICE: Surgery

QUARTER: July-September, xxxx

Physician's Average Monthly Discharges: 12

Current Delinquencies: 2 as of 10/2/xxxx

Delinquency Percentage: 17%

Prior Quart Delinquency Percentage: 19%

Specialty Delinquency Percentage: 23%

Comparative Physician Group: 19% (inc. all specialties)

Number of Physicians in Comparative Group: 8

Tips: Visit HIM every Thursday. Did you know that you don't need to re-dictate your

history into your discharge summary? Dictate to the transcriptionist to pick up the

history and we'll insert that piece for you. Look for tags on the records while on the

floor. It may save you a trip to HIM. Have you signed up for electronic signature

yet? It, too, may save you a trip to HIM. Thursday is chocolate day in HIM. Call

x254 to have your records pulled in advance of your visit. Thanks.

36

When the Carrot Doesn’t Work

� Suspension

� Revise Rules to suspend at 21 days but still

leave the definition of delinquency as 30 days

� See Lutz article for sample policy

� Monetary Penalties

� Fines

� Non-Monetary Penalties

� Special privileges

� Additional Assignments


EXHIBIT A

37

Getting Administrative Support

� Reimbursement

� Coding

� Denials

� Oryx/CMS abstracting

� CMS—Part A

� Qui Tam

� CMS—Part B� Documentation doesn’t support billing

� Labor time/space

38

References/Resources

� Conditions of Participation: http://www.access.gpo.gov/nara/cfr/waisidx_99/42cfr482_99.html

� Dunn, Rose. More with Less. HcPro publications

2004

� Federal Register. March 25, 2005 p. 15266-15274

� Flanagan, Christopher. “Using ‘Key Indicators’ to

Report, Monitor, and Improve HIM Operations”

AHIMA BOK

� Lutz, Laurie. “Physician Record Completion Policy.”

AHIMA BOK

References/Resources

� Conditions of Participation: http://www.access.gpo.gov/nara/cfr/waisidx_99/42cfr482_99.html

� Dunn, Rose. More with Less. HcPro publications2004

� Federal Register. March 25, 2005 p. 15266-15274� Flanagan, Christopher. “Using ‘Key Indicators’ to

Report, Monitor, and Improve HIM Operations”AHIMA BOK

� Lutz, Laurie. “Physician Record Completion Policy.”AHIMA BOK

� http://www.dwt.com/practc/healthcr/bulletins/04-05_CMSCoP(print).htm#a1

38

Exhibit B

Operative Record document

23Successfully Reduce Delinquencies: Proven Techniques from the Trenches

EXHIBIT B

Exhibit C

Excerpt from More with Less: Best Practices for HIM Directors by Rose T. Dunn, RHIA, CPA, FACHE, publishedby HCPro, Inc., 2004


EXHIBIT C

Not all incomplete patient records are due to a lack of dictated or signed reports. Some require

completion of documents, signing/cosigning of progress notes, and the HIM department favorite,

verbal/telephone orders. For a busy physician or revered “high admitter,” the number of incomplete

records can grow quickly. One physician said incomplete records seem to breed overnight.

With physician reimbursement declining, regulations increasing, and paperwork quadrupling, it’s no

wonder physicians miss documents and have incomplete records. This chapter focuses on helping

doctors—which simultaneously benefits the HIM department—and completing records at or near the

time of discharge.

Concurrent record analysis

Organizations have used several methods to achieve record completion while patients are in house.

Some of the following options are equally as effective in active outpatient settings where patients

have multiple encounters or rehabilitative settings:

• Concurrent record analysis occurs during concurrent record review by the record-review team

- Plus: The reviewers are already looking at the documentation and at this time they can

It has been said there are no incomplete or delinquent medical records in veterinaryhospitals—a theory that makes us think about the adequacy of documentation of ahuman’s health compared to our pets. We allow records to be completed after thepatient is long gone, yet expect physicians to remember intricate details of the careprovided.

INCOMPLETE MEDICAL RECORDS

EXHIBIT C

26 Successfully Reduce Delinquencies: Proven Techniques from the Trenches

assess whether the documentation is truly complete and adequate for other

caregivers.

- Minus: Depending on the review approach taken, not all records may be reviewed.

These reviewers, typically clinicians, may find the tagging of incomplete documenta-

tion more appropriate for clerical staff.

• Concurrent record analysis occurs during utilization and case-management reviews by staff who perform

these functions

- Plus: These individuals are most in need of complete documentation and have the

ability to encourage additional details often missing from physician documentation.

- Minus: Depending on the utilization review/case-management approach, not all

records may be reviewed. These reviewers may find tagging incomplete documenta-

tion more appropriate for clerical staff.

• Patient-care personnel identify documentation deficiencies and tag them as they compile the patient record

- Plus: The patient-care support staff or unit secretaries are in and out of all patient rec-

ords on the floor and can see whether a document has blanks or a verbal or telephone

order lacks a physician signature. Tagging this deficiency is within their skill set. These

staff are more likely to see the physician and remind him or her to complete the record.

- Minus: Many organizations have decreased the support staffing in patient-care areas.

Since many reports are now distributed through a network printing system, support staff

have absorbed much of the charting efforts performed by HIM and ancillary services.

• Designated HIM staff are assigned to review patient records daily for documentation deficiencies and tag

them accordingly

-Plus: The HIM staff’s purpose is to complete records, and therefore, they believe tag-

ging is an appropriate assignment.

-Minus: The HIM staff will not have the opportunity to remind physicians because the

presence of HIM staff in any patient-care area will be transient.

A coder’s true colors

Some physicians prefer a certain color; they are more aware of the flag color and more willing to

respond to the notice. If there is a large medical staff, there may not be enough colors, so segregate

color assignment by clinical specialty to avoid the possibility of overlapping physicians with the same


EXHIBIT C

color tag serving patients on the same floor. However, if the organization is unable to designate single

colors to each physician or is unwilling to permanently assign HIM staff to the patient-care area, then

the having patient-care staff review records may be the best choice because tagging alone is often not

enough to encourage a physician to complete a document. With all the other issues physicians deal

with, they often need someone to point to an item or remind them to sign a document.

Timely record processing

Reducing delinquent records is partially dependent upon a physician’s access to the records. If the

HIM processing effort consumes too many of the days between discharge and delinquency, the physi-

cians will have a restricted period in which to complete the record. Physicians may react by pointing

fingers at HIM inefficiencies. Demonstrate to the physicians that the records are available shortly after

discharge for their access and completion.

Timely transcription

In the past, some organizations allowed discharge summaries to fall to the lowest priority in the tran-

scription queue. However, this report assists the physician’s office most in continuity of care. This

report is also key for some coding activities. Convincing physicians to dictate at discharge requires a

quid pro quo exchange—a guarantee that they will have the office copy filed in their office record by

the time they see the patient for follow-up, often three to five days later. Improving the timeliness of

transcription for all reports is imperative to gaining the physician’s conviction for dictating promptly

after surgery, consultations, and discharge. HIM managers must recognize that achieving this level of

customer satisfaction may result in an increase in dictation and the associated cost of transcription.

Facilitating dictation

Add hands-free dictation capability to locations where physicians may dictate (e.g., the operating

room, emergency department (ED) examination rooms, procedure rooms). Another option is to use

downloadable, portable units to encourage physicians to dictate in the building.

Scribes

Scribes and other physician extenders can support the HIM department in timely record completion.

Scribes often are conscientious and will respond to an HIM request to come in to dictate or complete

EXHIBIT C


documentation. These individuals also are invaluable resources in identifying redundant documenta-

tion requirements as well as assisting coding in obtaining further clarification of a treated condition.

Building rapport with physician extenders will benefit HIM in multiple ways. You can ensure that

these individuals are not inappropriately using signature stamps and that final authentication must

be made by the physician. Some physicians become so trusting of their scribes or extenders that they

do not hesitate to loan their signature stamp. Federal and most state laws prohibit use of the signa-

ture stamp by anyone other than the physician.

Forms redesign

Anyone who has converted to an electronic medical record or transitioned to an electronic forms-man-

agement system knows that a total forms-redesign project is probably one of the most time-consuming

projects a HIM manager will encounter. The involvement of many who believe they have proprietary

rights to forms adds another dimension to the challenge. Tying documentation fields on the various

forms to state, federal, and JCAHO requirements, as well as departmental or leadership requires

attention to detail. However, any streamlining, elimination of redundant documentation, and refor-

matting that facilitates completion will be overwhelmingly welcomed by all users, including the

physicians. These projects often provide the following benefits:

• Reduce the number of forms

• Standardize the location of common fields (i.e., where the patient name and ID informa-

tion will appear)

• Eliminate outdated documentation efforts

• Implement the use of common terminology

• Impact positively on incomplete records

• Save the organization in forms inventory

Reassessing documentation requirements

As new documentation expectations surface, medical staffs scurry to update their rules and regulations.

Unfortunately, we rarely visit the entire set of rules to determine whether anything has fallen by the way-

side. This full review effort does not need to be an annual event, but triennially is not unreasonable.


EXHIBIT C

For example, the Conditions of Participation Interpretive Guidelines for 482.24 allow a single sign-off of multi-

ple entries (see Figure 5.1). Although the JCAHO requires certain individually signed documents, the

use of the two regulations in combination may reduce some efforts for your medical staff. Another

benefit is that it provides an opportunity for the medical staff to be reeducated about documentation

requirements.

Providing comparative data for physicians

Physicians thrive on data. They analyze and digest it. As with most individuals, they seek to have their

personal data surface as the “best.” If the data are to be presented, they must be credible and unbi-

ased to scientists. Developing a profile (see Figure 5.2) reflecting data elements that require minimal

effort include:

1. Physician’s name.

2. Specialty.

3. Average monthly discharges.

4. Current delinquencies (based on either a daily or weekly report).

5. Delinquency percentage as a percent of average monthly discharges (delinquencies divid-

ed by average monthly discharges for that physician).

6. Compared to others in same specialty, delinquency rate for the physician compared to

those for all physicians in the same specialty who had discharges).

Authentication definedFigure 5.1

482.24—Authentication:

“A system in which the physician signs off against a list of entries which must be verified in the

individual record.”

www.cms.hhs.gov/manuals/pub07pdf/AP-a.pdf p. A-37

EXHIBIT C


7. Compared to others with similar average discharges. This one may be more difficult to cal-

culate depending on the size of the medical staff as one will need to examine all the

physicians on staff with comparable monthly discharges; use a spreadsheet application to

sort data. The comparable monthly discharges should be a range of no more than +/-10%.

Make the HIM department a great place to visit

Build it and they will come. Establish a friendly environment where the physicians can find refuge—

coupled with timely processing—to control incomplete records. Patient care is not without stress, and

a place to calm down is appealing to any physician.

Sample physician delinquency assessmentFigure 5.2

Profile for: Dr. D. Butcher Clinical service: Surgery

Quarter: July–September

Physician’s average monthly discharges: 12

Current delinquencies: 2 as of 10/2/xxxx

Delinquency percentage: 17%

Prior quarter delinquency percentage: 19%

Specialty delinquency percentage: 23%

Comparative physician group: 19% (includes all specialties)

Number of physicians in comparative group: 8

Tips:

• Visit HIM every Thursday.

• Did you know you don’t need to redictate your history into your discharge summary?

Dictate to transcription to pick up the history, and we’ll insert that piece for you.

• Look for tags on the records while on the floor. It may save you a trip to HIM.

• Have you signed up for electronic signature yet? It may save you a trip to HIM.


EXHIBIT C

Consider the following options:

• Stock up on readily accessible beverages (e.g., coffee, soda, juice)

• Supply a small bowl of snacks or candy

• Hold periodic raffles for physicians who

- routinely stop by to check on their records

- rarely or never have delinquent records

- have the lowest delinquency rate in their specialty/comparative group

Sticks

Up until now, we have been discussing carrot-type approaches. The last option is the stick approach.

The stick surfaces in a variety of measures that organizations have had to institute. Common

approaches include suspensions and fines. Suspension often inconveniences the patient more than

the physician. Fines, however, have been found to be effective. Neither of these sticks works for those

physicians who neither admit nor schedule surgery. However, a measure that does work effectively for

nonadmitting physicians such as anesthesiologists, hospitalists, and ED physicians is an incentive

plan for no delinquencies (see Figure 5.3).

As with any penalty system, consistency of enforcement is paramount. Administration and the med-

ical staff must support the sanctions regardless of the physician involved. On the other hand, if there

is a shade of doubt about whether the penalty should be applied—perhaps due to HIM staff failing to

pull all records or a delay in charting transcription—then the penalty should not be invoked.

Residents/interns

Those of you working in a teaching facility have an additional hurdle to record completion: residents

and interns. Although they contribute a lot of documentation to the patient’s record, and it is usually

legible, they also leave documentation voids. These individuals are similar to extenders in that they will

create some of the documentation for the attending physician. However, because they are not employed

by the physician, their loyalty to doing all of what is asked of them is not always forthcoming.

EXHIBIT C


The first rule that must be added to your medical staff rules is that attending physicians are responsi-

ble for patients’ record completion. If the resident leaves an undictated discharge summary, then the

attending or sponsoring physician, is responsible for preparing the discharge summary.

Approach Suspensions Fines Incentives

Common

premise

Failure to complete records within 30

days of discharge results in

suspension of admitting and

operating privileges. Scheduling

services is prohibited except in life-

threatening situations.

Failure to complete records

within 30 days of discharge

results in the levy of a fine

payable by the physician to a

fund (education, HIM, charitable,

etc.).

Failure to complete records

within 30 days of discharge

results in loss of an incentive

payment that may be as much as

$5,000 or a reduction in the

contracted payment to the

nonadmitting group of the same

amount.

Major stick Failure to complete the records within

a certain period after being notified of

suspension could result in loss of

medical staff membership.

Failure to pay the fine within a

certain period after being

notified of the levy could result in

loss of medical staff

membership.

Loss of contract.

Impact Physician frustration; some projection

to clerical and management staff in

HIM. If scheduling is prohibited or

services cancelled, the patient is

inconvenienced by a delay or change

of hospital.

Sometimes, the fines are paid,

but the records remain

incomplete for some time

thereafter. The patient is not

inconvenienced.

Contract cancellation results in

an inconvenience for hospital

management and may disrupt

members of the medical staff

who respect and have aligned

with the nonadmitting group.

Other Occasionally, members of the same

group had their privileges suspended.

If not implemented for all

nonphysician groups, may result

in animosity.

Incentive plan for reducing delinquenciesFigure 5.3


EXHIBIT C

Counting incompletes and delinquents

HIM professionals know there is no wiggle room in determining which record has achieved “must-do”

status, or as some may label it, delinquent. Depending on state law, this period could be as short as

15 days after discharge or, by federal statute (Conditions of Participation), 30 days. When it comes to

sticks, the state and federal governments’ leaves JCAHO’s stick in the shadows.

Use some of the above approaches to encourage physicians to visit the HIM department more fre-

quently and avoid being suspended or labeled as delinquent. However, if you wait until day 30, for

example, to notify the physician or take action on this record, then there is no chance that this record

will be completed within the time frame mandated by the regulations.

Steps to simplify resident/attending physician coexistenceFigure 5.4

1. Always provide a bowl of snacks for the residents; an occasional sandwich assortment is

even more enticing

2. Establish a reporting system that alerts the attending and chief resident of any upcoming

delinquent records

3. Require the attending physician to sign off on the resident’s evaluation form

4. Suspend the chief resident or chief of service if the residents allow records to become

delinquent

5. Contribute $100 each month that there are no delinquent records for residents to that

service’s education fund

EXHIBIT C


Capturing deficiencies for nonphysicians

If your organization is required to analyze records for documentation deficiencies for nonphysicians,

then the organization must make a conscious and documented decision whether to count these cases

in the incomplete and delinquent count. If the organization states that a record is not complete, for

example, until the ED nurse records the discharge condition and that element is incomplete, then the

record is technically incomplete. The challenge arises when this the agency nurse does not return for

weeks, months, or forever. Further, what is the penalty for failure to complete the record if the nurse

is gone?

Many organizations have adopted the policy that nonphysician documentation is to be managed by the

employed leadership of that area. In this example, it would be the ED manager. The ED manager

should have established appropriate processes and performance-improvement measures to capture

the required documentation by the time the patient leaves the area or the nurse’s shift changes.

1. Ensure your incomplete tracking system is counting days from date of discharge—not the date thatit was analyzed or logged into the department.

2. Establish a weekly notification process for the physicians that keep them informed about therecords requiring their attention.

3. If suspensions occur, initiate the suspension seven days in advance of the absolute “drop-dead”date for the record to be in violation of state or federal law. This might be day 21 in a state thatrequires all records to be completed within 30 days of discharge.

4. Use the maximum period as the definition of “delinquency” to provide you with the greatest flexi-bility with JCAHO.

TIPS


EXHIBIT C

Building dialogue with physicians

Interview physicians regularly, either on the patient-care floors, during medical staff meetings, or

while they are doing their records in your department to gain input into improving this process.

During one assessment, we found the only dictation unit in the labor and delivery area was in the

fathers’ waiting room. The surgeons did not think it was appropriate to dictate their reports there.

Why was the dictation unit installed there? Due to a renovation, the surgeon’s charting area became

the fathers’ waiting room. No one told HIM that the renovation occurred. Another interview session

suggested that the record-completion area have a small copier so the physician could copy progress

notes and take them to office billing staff. The physicians stopped by several days a week to copy.

While there, they completed their notes. Sure seemed like a waste of professional time seeing physi-

cians copying their records, but it was an inducement for some physicians.

Summary

Timely completion of patient records requires the following tasks:

• Timely identification of those records needing attention

• Timely transcription of reports to encourage physicians to dictate immediately

after service

• Ensuring unnecessary documentation requirements are reduced/eliminated

• Providing physicians and others with the tools needed, wherever necessary, to complete

the records

• Improving forms’ design to allow easy recognition of those fields requiring attention by

the physician, nurse, other clinicians

• Accurately counting records as incomplete/delinquent

EXHIBIT C


• Establishing an inviting environment that encourages frequent visits to the physicians

incomplete area

• Consistently enforcing rules that apply to all who must complete records

There are several methods to achieve records completion while patients are in house and some are

equally effective in active outpatient settings. Improving the timeliness of transcription of all reports

may result in more timely dictation of reports by physicians, as well as an increase in the type and

volume of reports dictated by physicians. Adding scribes or other physician extenders to assist physi-

cians may improve both the quality and timeliness of documentation. Develop a profile that a physi-

cian can use to compare his or her performance to other physicians in the organization. As your staff

identify traits of physicians who never fall into the delinquent zone, list those as tips on the profile.

Offer both carrots and sticks. Reward physicians who religiously complete records. Consider penalties

for those who procrastinate, regardless of the tools offered to assist them. Finally, remember to com-

municate with the physicians to build rapport and recognition for the many challenges faced by HIM.

Exhibit D

Articles taken from HCPro’s monthly newsletter Medical Records Briefing

- AL hospital turns around delinquent record rateCommunication, revised rules, facilitywide effort all help with dramatic reduction(April 2005)

- Delinquent records trouble spotSurvey shows 9% cited by JCAHO in this area(February 2005)

EXHIBIT D


www.hcpro.com

Between January 2003 and October 2004, the delin-quent record rate at Carraway Methodist MedicalCenter (CMMC) in Birmingham, AL, decreased all theway from 52% to 1%.

The facility received a recommendation for improve-ment from the JCAHO during its March 2004 surveybecause it lacked a compliant 12-month track record,says Pamela Burns, RHIT, CCS, HIM director.

“Our quarterly statistics never exceeded 50% of ouraverage quarterly discharges, but there were a fewindividual months that exceeded 50% in the earlypart of 2003.”

Thanks to intense education during JCAHO prepsessions, the hospital saw the delinquent record ratestart to decline by survey time.

Communicate, communicate, communicateThe JCAHO task force at CMMC identified the delin-quent chart count as an area that needed attention.

“Everybody had to get on the same page, and theonly way we could do that was to communicate,communicate, and communicate some more,” Burnssays.

For that reason, the delinquent chart count made itonto every committee meeting’s agenda and ap-peared during all managers’ meetings, presentationsfrom the quality improvement director, and Burns’presentations to medical staff committees. The hospi-tal’s quarterly newsletter reported progress to theentire staff and gave kudos to the medical staff fortheir progress and hard work.

Administration’s involvement was imperative, Burnssays. Chief Financial Officer Peggy Allen champion-ed the project. Allen and Burns’ second in commandmet weekly to discuss the chart count.

Burns also sent weekly notifications to physicians viamail and fax and mailed weekly reports of deficien-

cies to each physician to make them aware of whatcharts remained incomplete.

“It was imperative that this process be consistent andthat the notifications were timely,” Burns says.

Physicians revise rules To help with consistency, CMMC revised medicalstaff rules and regulations outlining a timetable forchart completion. One revision required chart com-pletion within 21 days from discharge, rather than30 days.

With the new system, the medical staff had to followthe new rules they approved. Information technolo-gy staff produced reports that listed each physician,the number of incomplete charts, and the number ofdelinquent charts broken down by the number ofdays from discharge the record had aged (i.e., <21days, <28 days, <35 days).

AL hospital turns around delinquent record rate Communication, revised rules, facilitywide effort all help with dramatic reduction

Three reasons for delinquent records

Pamela Burns, RHIT, CCS, HIM director ofCarraway Methodist Medical Center inBirmingham, AL, cites the following three rea-sons for her facility’s high delinquent recordrate:

1. Lack of persistent, effective communication,and/or notifications to the medical and residentstaff from the HIM department.

2. Poor rules and regulations that allowed achart to age to 51 days post-discharge beforesuspension of a physician’s privileges. Thephysician was suspended after receiving consis-tent notifications.

3. Inclusion of only inpatient charts when calcu-


EXHIBIT D

www.hcpro.com

The new medical staff rules included three levels ofnotification each week, depending on the chart’sage. For charts older than 21 days, physiciansreceived a letter from Burns. Charts older than 28days warranted a notification from the chief of themedical staff. Physicians received a notification fromthe CEO of relinquishment of medical staff privi-leges for charts more than 35 days old.

The information services department provided thereports and abstracted the numbers onto a spread-sheet to allow notifications to be automatically gen-erated and sent through mail merge.

The HIM analysis staff and physician workroomstaff were dedicated to their roles in the process,Burns says. The analysis team provided the work-room with charts within fivedays post-discharge. Theworkroom staff called officemanagers, beeped physicians,faxed/mailed deficiency lists,and stopped residents in thehallways.

“You name it, they’ve done it,”Burns says.

Eliminate surprisesTo assist with the chart countcompletion process, Burnsand the rest of the team atCMMC included every deficiency at the initialanalysis process.

For example, for a discharge summary awaiting dic-tation, staff wrote, “Dictate discharge summary,awaiting transcription and signature for dischargesummary.” That eliminated surprises for the physicians.

Once the physician dictated, the dictation deficiencywas cleared. As each step was completed, the sys-tem updated the record’s status.

This benefited the weekly chart counts because thedeficiency note for the attending’s signature wasseparate from the deficiency note for transcription.

This alerted providers of a recent dictation or that aresident was responsible for that dictation, ratherthan the attending physician. This also preventedunnecessary reminders to attending physicians responsible for any delays. In the alphabetical listingof physician deficiencies, if a resident was assignedto a dictation, the computer grouped the resident toreport the page before the attending’s name.

Stay on top of transcriptionBurns also found daily log sheets of pending tran-scription needs helpful. “If you have an outsourcedcompany providing your transcription needs, reviewthe contract and make sure that the turnaround timeframes for your discharge summaries are no longerthan 48 hours,” she says. If that’s in your contract,then the vendor has to provide the manpower to

make it happen.

If your transcription doesn’tturn around quickly, thatdelays the workroom processesand, in turn, delays physicians’ability to fulfill their responsi-bilities. This same scenarioapplies to in-house transcrip-tion as well.

“Adequate coverage is impera-tive,” she says.

Another change that affectedthe delinquent record rate was including observa-tions, ambulatory surgery, outpatient endoscopy,and other outpatient cases as of January 2004.

“If we were going to conduct a full analysis processof the chart, we needed to be counting all the charts,”Burns says. With an average of only four or five delin-quent outpatient charts per week, adding those casesto the total monthly number helped reduce the overallrate.

Hard-earned but worth itCMMC’s delinquent record project met initial resis-tance, Burns says. “Not everyone was on the samepage. Communication and commitment were key.”It wasn’t an easy task, but eventually Burns and her

Reducing the time allowed to complete the medical

record and, at the same time,providing weekly reminders

of chart deficiencies led to allinvolved becoming sensitizedto completing their charts.

—Kimball I. Maull, MD

EXHIBIT D


Burns and her team won over the medical staff.

In fact, the hospital service committee chair, Kimball I. Maull, MD, says “the improved efficien-cy in chart completion has been a source of greatpride within the Carraway organization. Reducingthe time allowed to complete the medical recordand, at the same time, providing weekly remindersof chart deficiencies led to all involved becomingsensitized to completing their charts.”

This project’s success has not only improved chartcompletion for statistical purposes, but it affectedthe turnaround time for release of information pur-poses, coding, and overall quicker availability of acomplete record for continuity of care, Burns says.

“The delinquent record status must be on the radarscreen weekly for success to be achieved and main-tained,” she says.

www.hcpro.com


EXHIBIT D

Editor’s note: Survey results are based on 306responses from the following categories:

• Small (fewer than 150 beds)—55%

• Medium (150–300 beds)—27%

• Large (more than 300 beds)—18%

Forty-four percent of respondents to the recent MRBbenchmarking survey on delinquent records main-tain a delinquency level of 10% or less. Another 23%have a rate of 25% or higher (see Fig. 1).

Veteran HIM professional and JCAHO expert Jean S.Clark, RHIA, service line director of HIM at RoperSt. Francis Healthcare in Charleston, SC, expressedsurprise and disappointment at those numbers. “Thisis a requirement that has been around for a longtime, and it would seem we would be doing betterat it,” she says.

Clark is not the only one discouraged by the results.More than half of respondents (60%) said they areeither “very satisfied” or “satisfied” with their de-linquent record rates, but another 31% are either“dissatisfied” or “very dissatisfied” with them (seeFig. 2).

“I am glad to see that a large number are not happywith their delinquent records, since timely, accurate,and complete documentation is a key to qualitypatient care and safety,” Clark says. “It means wehave to continue to push to get doctors and admin-istration behind this effort.”

JCAHO citations aboundAnother statistic that does not impress Clark is thatthe JCAHO cited nearly one in 10 survey respon-dents for delinquent records.

“I think 9% of hospitals receiving JCAHO recommen-dations in this area is high,” she says. The patienttracer survey process makes the record at the pointof care an important tool for surveyors. “If 9% ofhospitals are still having trouble [completing records]

after discharge, it makes me concerned for the suc-cess of their overall survey.”

And the JCAHO requirement to conduct an annualperiodic performance review should force you toidentify areas vulnerable to documentation deficien-cies, Clark says. “A focused review and plan ofaction should help to improve documentation beforethe records come to the HIM department.” Andimproving documentation is key if you have troublewith record completion, because once records get tothe HIM department, staff there can only help youget signatures on discharge summaries.

Administrative support a mustThe administration at Straith Hospital for SpecialSurgery in Southfield, MI, has taken a special interestin the delinquent record rate, making it easier forGloria Kendrick, RHIA, health information manag-er, and her staff to keep the rate at less than 5%.

“Without their backup, the only other way I ameffective at keeping the chart delinquencies low isby establishing a relationship of mutual respect withthe physicians,” she says. “They understand that Ilook out for them in reviewing their records for legalinconsistencies, and they are eager to assist me withmy charting issues.”

But some HIM directors achieve low delinquencyrates only after their administration receives a slapon the wrist from the JCAHO, says Rose T. Dunn,RHIA, CPA, FACHE, FHFMA, chief operating officerof First Class Solutions in St. Louis. “They are luckythat CMS or the state didn’t walk in and put theirlicensure in jeopardy. CMS has a much bigger stickthan JCAHO.”

Low delinquency takes timeWhen asked how much time facilities spend ondelinquent records, 14% of respondents said “noneof the time” or “little of the time.” About half (54%)said they spend “some of the time” and the remain-ing 32% said they spend “most of the time” or “all ofthe time.”

Delinquent records trouble spot Survey shows 9% cited by JCAHO in this area

EXHIBIT D


One respondent said that delinquent records costher facility 2.5 full-time equivalent employees, or$60,000, per year. But Clark is not surprised at thepercentage of time it takes to deal with the process.

“It can be very time consuming, especially depend-ing on how often the hospital conducts its delin-quent counts,” she says.

Despite the time it may cost you and your depart-ment, HIM has several responsibilities that affect thedelinquent record rate, Dunn says. These include thefollowing:• Regularly notifying physicians of their incomplete

and delinquent records• Processing discharged records in a timely manner

so physicians get the records promptly after dis-charge, when information is fresh in their minds

• Consistently applying the rule for all physicians

Making the HIM department a fun environment forthe physicians is always a good way to get them tocome and complete their records, Dunn adds. Youshould make the physicians’ work area as comfort-able and appealing as possible.

Fig. 2: How satisfied are you with your delinquentrecord rate?

Fig. 1: What is your delinquent record rate?

29% very satisfied

satisfied

neutral

dissatisfied

very dissatisfied

31%

9%

23%

8%

Editor’s note: Survey results are based on 306responses from the following categories:

• Small (fewer than 150 beds)—55%

• Medium (150–300 beds)—27%

• Large (more than 300 beds)—18%

Forty-four percent of respondents to the recentMRB benchmarking survey on delinquent recordsmaintain a delinquency level of 10% or less.Another 23% have a rate of 25% or higher (seeFig. 1).

Veteran HIM professional and JCAHO expert JeanS. Clark, RHIA, service line director of HIM atRoper St. Francis Healthcare in Charleston, SC,expressed surprise and disappointment at thosenumbers. “This is a requirement that has beenaround for a long time, and it would seem wewould be doing better at it,” she says.

Clark is not the only one discouraged by theresults. More than half of respondents (60%) saidthey are either “very satisfied” or “satisfied” withtheir delinquent record rates, but another 31% areeither “dissatisfied” or “very dissatisfied” with them(see Fig. 2).

“I am glad to see that a large number are nothappy with their delinquent records, since timely,accurate, and complete documentation is a key to

Resources

RESOURCES


Speaker resources

Rose T. Dunn, RHIA, CPA, FACHEFirst Class Solutions, Inc.2060 Concourse DriveSt. Louis, MO 63146Phone: 314-997-8998Fax: 314-997-0400E-mail: [email protected]

Eileen M. O’Heron, RHIADirector Medical RecordsRush-Copley Medical Center2000 Ogden AvenueAurora, IL 60504Phone: 630-499-2304Fax: 630-236-4279E-mail: [email protected]

HCPro sites

HCPro: www.hcpro.com

With more than 17 years of experience, HCPro, Inc., is a leading provider of integrated information, educa-tion, training, and consulting products and services in the vital areas of healthcare regulation and compliance.The company’s mission is to meet the specialized informational, advisory, and educational needs of thehealthcare industry and to learn from and respond to our customers with services that meet or exceed thequality they expect.

Visit HCPro’s Web site and take advantage of our online resources. At hcpro.com you’ll find the latest newsand tips in the areas of

• accreditation• corporate compliance• credentialing• health information management• infection control• long-term care


RESOURCES

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HCPro offers the news and tips you need at the touch of a button—sign up for our informative FREE e-mailnewsletters, check out our in-depth, how-to information in our premium newsletters, and get advice from ourknowledgeable experts.

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© 2004 The Greeley Company, a Division of HCPro is not affiliated in any way with the Joint Commission on Accreditation of Healthcare Organizations, which owns the JCAHO t r a d e m a r k .

FAX: 800/738-1533TEL: 800/801-6661 WEB: www.greeley.com

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