Health Information Management

CMS releases revised Interpretive Guidelines for hospital CoPs

Medical Records Briefing, May 1, 2008

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On February 8, CMS issued revised Interpretive Guidelines for hospital Conditions of Participation (CoP) that provided long-awaited clarification regarding history and physicals (H&P), timing/dating and authenticating entries, verbal orders, and postanesthesia evaluations addressed in the November 27, 2006, Federal Register.

The guidelines, which take effect immediately, also reflect changes incorporated into the 2008 Outpatient Prospective Payment System regulations that clarify the time frame requirements for H&P exams and postanesthesia evaluations. “I think that [the delay in releasing the guidelines] is very confusing to people. It’s our government playing catch up,” says Patricia Pejakovich, a senior consultant based in Battle Creek, MI, for The Greeley Company, a division of HCPro, Inc., in Marblehead, MA.

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