NARHC Forum

Contributor: Crista Davis, Confluence Health - Wenatchee Clinic

How do others track the following requirement of chart review?

§491.8(b) Physician responsibilities. The physician performs the following:
(3) Periodically reviews the clinic's ...patient records...

§491.8(c) Physician assistant and nurse practitioner responsibilities.
(1) The physician assistant and the nurse practitioner members of the clinic's ...staff:
(ii) Participate with a physician in a periodic review of the patients' health records.

The requirement of at least 5% or 50 records (whichever is less)/ year.

Thank you.

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Contributor: Bill Finerfrock, National Association of Rural Health Clinics - Retired

There is no specific number or percentage of charts that must be reviewed as a matter of federal law or regulation. Chart review - to the extent it is specifically addressed - is a state law or state regulation matter.

(b)Physician responsibilities. The physician performs the following:

(1) Except for services furnished by a clinical psychologist in an FQHC, which State law permits to be provided without physician supervision, provides medical direction for the clinic's or center's health care activities and consultation for, and medical supervision of, the health care staff.

(2) In conjunction with the physician assistant and/or nurse practitioner member(s), participates in developing, executing, and periodically reviewing the clinic's or center's written policies and the services provided to Federal program patients.

The Federal Regulation stipulates that the physician:

(3) Periodically reviews the clinic's or center's patient records, provides medical orders, and provides medical care services to the patients of the clinic or center.

There is no specific federal requirement as either a percentage of records or number of records. Note also that the requirement is not specific to a particular type of practitioner (i.e. PA, NP, other). So if you maintain a log indicating that the physician reviewed records noting how many as either a number or percentage, that should be sufficient to satisfy a surveyor. If your state law stipulates a specific number or percentage of chart review for PAs or NPs as part of their practice act, then you would be expected to meet your state's requirements.

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Contributor: Crista Davis, Confluence Health - Wenatchee Clinic

Thank you for your reply. The last sentence shows the requirement of 5% or 50 charts-
This was found in the interpretive guidelines:
(c) The purpose of the review is to determine whether:
(1) The utilization of services was appropriate;
(2) The established policies were followed; and
(3) Any changes are needed.
Interpretative Guidelines §491.11(a)-(c)
The RHC is required to conduct an evaluation of its total clinical program, at least annually. This evaluation may be done by RHC staff or through arrangement with other appropriate professionals. The RHC must have documentation of who conducts the review or portions of the review, and what their qualifications are to do so.
The evaluation must include, at a minimum, the number of patients served and the volume of services provided. The evaluation should be able to determine whether the RHC provides appropriate types and volume of services based upon the needs of its patient population. It should also be able to evaluate whether RHC patient policies were followed and whether or not changes to the policies or to procedures are warranted. The evaluation does not have to be done all at once or by the same individuals. However, if the evaluation is not performed all at once, no more than one year may elapse between evaluating the same components.
A RHC that has been certified for less than one year may not have done a program evaluation. However, the RHC must have a written plan that specifies who is to do the evaluation, when and how it is to be done, and what will be covered within the evaluation.
The evaluation must also include a review of a representative sample of both active and closed clinical records of RHC patients. The sample must also include at least 5 percent of the RHC's current patients or 50 records, whichever is less.

The question is how are others tracking this requirement?

Thank you

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