Accreditation

History and Physical Examination Time Frames and Required Updates

Accreditation Monthly, June 9, 2005

Dear Colleague,

A little-noticed change in the 2004 update of the Comprehensive Accreditation Manual for Hospitals is provision of care standard PC.2.120 EP 7 that requires an update to a history and physical (H&P) at the time of the admission or prior to an invasive procedure.

While this new requirement was clarified in a December 2004 Frequently Asked Question posted on the JCAHO Web site, I continue to hear from hospitals that are unaware of this heightened JCAHO expectation, which essentially makes the CMS seven-day H&P rule a moot point.

If an H&P has been performed and documented within thirty (30) days of the patient's admission to the hospital or admission for a scheduled operative or invasive procedure, a legible copy of that H&P examination may be used in the patient's medical record, provided an update is performed by an licensed independent practitioner or designee with privileges to perform H&Ps, and it is documented prior to the procedure or at the time of or within 24 hours of admission.

This updated H&P examination must:

(a) Address the patient's current status / any changes in the patient's status (if there are no changes in the patient's status, this should be specifically noted)

(b) Include an appropriate physical examination of the patient to update any components of the exam that may have changed since the prior H&P, or to address any areas where more current data is needed

(c) Confirm that the necessity for the admission, procedure, or care is still present

(d) Be written or otherwise recorded on, or attached to, the previous H&P, or written in a progress or consult note

(e) Be placed in the patient's medical record prior to the procedure or within 24 hours of admission

CMS Conditions of Participation have long required an update to the H&P if the H&P is 8 to 30 days old. However, this new JCAHO requirement calling for an update to any H&P older than one day supersedes the CMS rule for accredited organizations.

I suggest working to make it easy for your medical staff to comply with this important enhancement of a long-standing patient status communication tool. Your rules should allow for use of a written progress or consult note for this purpose. Or your preprinted H&P form could be modified to accommodate a simple check box and brief note section to record any updates.

If you are interested in a sample focused H&P form for this purpose please write me at jrosing@execpc.com.

Sincerely,

John Rosing
Practice Director of Accreditation
and Regulatory Compliance
The Greeley Company

For more information on our accreditation and regulatory compliance consulting services, click here or contact Sandi Reen, Practice Manager, at sreen@greeley.com or call 888/749-3054, ext. 3263.

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