Medical Records Documentation Guidelines
A network provider's office records must be made available to MPHC. This access allows MPHC to monitor compliance with regulatory requirements.
General Requirements
Each provider office will maintain complete and accurate medical records for all MPHC members receiving medical services in a format and for time periods as required by the following:
- Applicable state and federal laws.
- Licensing, accreditation, and reimbursement rules and regulations to which MPHC is subject.
- Accepted medical practice and standards.
The provider's medical records must be made available to MPHC for reasons including (but not limited to) the following:
- Utilization Review
- Payment Audit
- Risk Management/Quality of Care
- Peer Review Studies
- HEDIS 365 Review
- Risk Adjustment Data Validation Audit
- Customer Service Inquiries
- Grievance and Appeal Processing
- Clinical Quality of Care issues and reviews.
If your organization utilizes a third-party chart retrieval vendor for medical record requests, please recognize that due to security purposes put forth by the Department of Health Administration we are unable to discuss members or request records from a third-party vendor for our Uniformed Services Family Health Plan (USFHP), so all medical record requests for our USFHP must be performed by provider site or internal health information management department.
To be compliant with HIPAA, providers should make reasonable efforts to restrict access and limit routine disclosure of protected health information (PHI) to the minimum necessary to accomplish the intended purpose of the disclosure of member information.
If a Martin's Point plan member changes his/ her PCP for any reason, the provider must transfer a copy of the member's medical record to the member's new PCP at the request of the plan or the member. The participation agreement states whether the original or a copy of the medical record must be sent. If a provider terminates plan participation or service to our member, the provider is responsible for transferring the member's medical records.
Charges for copying medical records are considered a part of office overhead, and copies are to be provided at no cost to members and Martin's Point, unless state or federal regulations stipulate differently.
Timeline Requirements
The participating provider must respond within the designated timeframe set forth on the Martin's Point request for records to allow us to comply with time frames established by CMS, TRICARE, NCQA, and/or the applicable state Bureau of Insurance.
Only those records for the time period designated on the request should be sent. The submission must include complete and accurate records that were created in a timely manner.
If Martin’s Point deems that a quality incident likely has occurred a corrective action plan letter will be sent to your organization. The expectation is a response is sent within 15 days to comply with time frames established by CMS and TRICARE and allow the cases to be investigated and followed up on.
Additional Options
We fully appreciate the challenges and resource constraints of our participating providers. As such, we make every effort to minimize negative impact of these medical records requests when possible. If you receive a large volume of medical records requests from us in a short period of time, and have concerns about returning records expeditiously, other arrangements are available to you.
Depending on the kind of medical records request, it may be possible to save you time, cost, and effort via the following pathways:
- MPHC staff working to obtain the appropriate medical records onsite at your physical location.
- EMR access or extraction to allow MPHC staff to obtain the appropriate medical records remotely.
- Direct flat file extract, CCD, or FHIR file from EMR that supports the requested data by MPHC. MPHC will provide specs as requested.
- MPHC will also work with any vendor with whom you have contracted to support your organizations data extracts.
If you have specific questions about whether one of these may be a good option for you, please contact the number on the request to inquire further.
The following standards for medical records have been adopted from the National Committee for Quality Assurance (NCQA), and Medicaid Managed Care Quality Assurance Reform Initiative (QARI) as the minimum acceptable standards within most health plans.
1. Organization
Medical records must be organized systematically and uniformly to allow for efficient and rapid review.
Papers must be firmly attached. Individual unit medical records are recommended as opposed to family medical records.
If family records are utilized, each patient's component of the record must be clearly distinguishable and organized.
2. Patient Identification
Each page in the medical record must contain the patient’s name or identification number.
3. Personal/Biographical Data
Personal and biographical data must be noted.
This may include address, employer, date of birth, sex, marital status, and home/work telephone numbers.
4. Provider Identification
All entries, including dictation, must be identified by the author (with credentials) and authenticated by his or her entry.
Authentication may include signatures or initials, thereby verifying that the report is complete and accurate.
5. Entry Date
All entries must be dated, and all records must be complete within thirty (30) days of discharge or, if in the outpatient setting, within thirty (30) days of the office visit.
6. Legible
The medical record must be legible to someone other than the writer.
7. Problem List
Significant illnesses and medical conditions should be indicated on the problem list.
If the patient has no known medical illness or condition, the medical record must include a flow sheet for health maintenance.
8. Allergies
Allergies/no known allergies (NKA) must be documented in a uniform location on the medical record.
Medication allergies and other adverse reactions must be listed if present. List no known allergies (NKA) if applicable.
9. Past Medical History
Past medical history should be easily identifiable and include serious accidents, operations, illnesses, and familial/hereditary disease.
10. Smoking/Alcohol/Substance Use (for patients seen three or more times)
Notation concerning cigarette, alcohol, and substance use.
11. Physical Exam (complete)
All body systems to be reviewed within two years of the first clinical encounter.
Basic Data: Height, weight, blood pressure, and temperature must be documented on the initial visit.
History and Physical: Subjective and objective information is obtained and noted for the presenting complaints.
Working Diagnosis: Working diagnosis is consistent with findings (physician's medical impression).
Plan/Treatment: Documentation of plan of action and treatment are consistent with diagnoses.
Patient Education/Instructions: Documentation present as applicable.
Consults/X-ray/Lab/Imaging Reports/ Referrals/Records: Reports are filed in the medical record and initialed by the primary care physician, thereby signifying review. Consultation and abnormal lab imaging study results should have an explicit notation in the medical record of follow-up plans and notification to patient of all results (i.e., positive and negative). Referrals, past medical records, and hospital records (e.g., operative and pathology reports, admission and discharge summaries, consultations, and ER reports) should be filed in the medical record.
Follow-up/Return Visits: Encounter forms or notes have a notation concerning follow-up care, call or visit. Specific time to return is noted in weeks, months, or as necessary. Unresolved problems from previous visits are addressed in subsequent visits.
Medical Care/Services/Consults: A general overview of medical care, services and consults ordered will be reviewed. If any potential quality issues are identified, the reviewer should refer to the practice or health plan's designated Medical Director for further direction.
Immunization Record Must Indicate:
- Tetanus/diphtheria immunization status for patients 21 and older.
- Influenza/pneumococcal immunization status for patients 65 and older.
- Influenza, pneumococcal, and/or hepatitis B immunization status for high-risk patients 21 and older.
- Documented immunization record for patients under 21. If there is no record, there must be documentation regarding immunization status (e.g., "Up To Date" (UTD)), stating who reported the status and that a copy was requested for the medical record.
Preventive Services (for adult patients seen three or more times): Record should indicate preventive services are offered according to defined Adult Screening Guidelines for Asymptomatic Men and Women. (For patients under 21, preventive health services must be provided according to the state's mandated periodicity schedule.)
Advance Directives (for patients 21 and older only): There should be evidence that the patient has been asked if he or she has an advance directive (written directions about their health care decisions). Yes/no response should be documented. If the response is "yes," a copy must be included.