Category Archives: JCI Standards

JCI Standard MCI.7 – Medical Records contents sharing

Posted on by
Reply

Medical Records continue to be a primary source of information containing patient-specific information to provide effective care, develop treatment guidelines, determine ability to pay for care, bill third-party payers, and anonymously conduct research studies. Any hospital must maintain a medical record for each inpatient and outpatient. It needs to be available during inpatient care, for outpatient visits, and at other times as needed and it must be up to date to ensure communication of the latest information. Thus, the medical record containing medical, nursing and other patient care notes is an essential communication tool that is useful to support the continuity of the patient’s care and must always be available so that it can be shared among all of the patient’s health care practitioners at all times.

Since the Medical Record is always available to all the patient’s health care practitioners, a hospital must create written privacy policies and procedures, which clarify who has the right to access protected information, how protected information will be used within the covered entity, when protected information may be disclosed, and employees must be trained on such privacy policies and procedures to ensure confidentiality of patient information.

An example when written privacy policies and procedures must be created is epitomized  in the Health Insurance Portability and Accountability Act of 1996 (HIPAA) in the United States of America.

Electronic Medical Records (EMR) like paper based medical records, must also be available to all the patient’s health care practitioners. In order to maintain patient confidentiality, the patient’s health care practitioners must be granted need-to-know status to gain access to the EMR. However there are exceptions, like when attending and resident doctors who are involved in current treatment episodes or on an emergency basis can also gain access through a security override feature incorporated into the EMR system.

It is very important that when all of the patient’s health care practitioners and/or other employee or medical staff member are granted access to the EMR, he or she receives training on system security, appropriate access to and utilisation of patient information, password protection features, existence of audit trails and access monitoring, and consequences of inappropriate access and/or most importantly, breach of patient confidentiality.

Many hospitals also require that their employees and medical staff members sign a statement indicating that they understand the confidential nature of patient information and the need to keep the information and their password secure.

Thus, every hospital must, regardless of its level of computerisation, need to have a comprehensive information security policy which defines the hospital’s commitment to confidentiality for patients, members of the community and its employees. It provides a blueprint for defining standards and procedures and it establishes a standard of care with respect to the handling of its confidential informational resources. A confidentiality committee with the task of developing a comprehensive information security policy should be appointed by the hospital’s leaders.

The issue of confidentiality is so important so much so that a preprinted confidentiality statement on the outside of the medical records file folder usually alerts users that patient information in the medical record is confidential and cannot be removed from the facility without proper authority.

If you are a Health Information Management (HIM) / Medical Records (MR) practitioner practising at a hospital which is already Joint Commission International (JCI) accredited or seeking JCI accreditation status or undergoing re-survey for JCI accreditation status, then he or she must be aware that the JCI Standard MCI.7 requires that “The patient’s record(s) is available to the health care practitioners to facilitate the communication of essential information.”

In all instances, the HIM / MR department at any type of hospital is responsible for allowing appropriate access to patient information in support of clinical practice, health services, and medical research, while at the same time maintaining confidentiality of patient and provider data.

This is also true when the  HIM / MR department at a hospital which is already JCI accredited or seeking JCI accreditation status or undergoing re-survey for JCI accreditation status, is responsible to collect medical records selected and for allowing appropriate access to patient information in support of a Medical Records Review session.

To end, HIM / MR practitioners  please take note that the JCI Standard MCI.7 is among the five (5) JCI MCI standards within the Communication Between Practitioners Within and Outside of the Organisation block of the JCI MCI Chapter.

References:

  1. Caroline, BR & Mary, TK 2012, Textbook of basic nursing, 10th edn, Wolters Kluwer Health, Lippincott Williams & Wilkins, Philadelphia, USA
  2. Joint Commission International, 2010, Joint Commission International Accreditation Standards For Hospitals, 4th edn, JCI, USA
  3. Michelle, AG & Mary, JB 2011, Essentials of Health Information Management: Principles and Practices, 2nd edn, Delmar, Cengage Learning, NY, USA
  4. Neil, SS (ed.) 2011, Electronic Medical Records A Practical Guide for Primary Care, Humana Press, New York, USA

Nutrition therapy and the medical record

Posted on by
2

Patients are screened for nutritional risk as part of the initial assessment with the application of screening criteria to gather information on nutritional status or functional status – often done by nurses, which must also be completed routinely within 24 hours of admission to the hospital or at an earlier time period.

I had covered at length on this requirement as you can follow from the posts (each of the following links will open in a separate new tab of your current browser window) Hospital screening criteria data to identify patients with nutritional or functional needs and 6 steps in documenting hospital screening to identity patients with nutritional or functional needs.

A patient identified with nutritional or functional needs i.e. at nutrition risk, is referred to a nutritionist for further assessment and a collaborate plan for nutrition therapy is carried out by doctors, nurses, and the dietetics service, and when appropriate with the help of the patient’s family. The nutritionist monitors at intervals the patient’s progress from the nutrition therapy, the nutritionist’s reassessment throughout this special care process is part of all reassessment by all the patient’s health care practitioners as the key to understanding whether care decisions are appropriate and effective, and records the progress in the patient’s record.

So what is nutrition therapy?

A patient is after a burn or surgery. Another patient is with a high fever, or suffering from acute diarrhoea. Yet another patient is with diabetes mellitus, a disorder throughout life. One other patient is suffering an acute illness with coronary or vascular disorders.

Nutrition is a vital component of therapy for the above listed disorders. According to (eds. Catherine, Benjamin, Robert, Katherine, & Thomas 2014, p. 1162), “use of the term therapy recognizes the role of nutrition in affecting patient outcome and acknowledges the demonstrable risks and benefits to nutrition intervention in both the short term and the long term.”

So, nutrition therapy is required with a high protein intake to rebuild, repair and heal body tissues after a burn or surgery. Nutrition therapy is provided when a patient needs fluids and electrolytes to replace what is being lost due to haemorrhaging, vomiting, and perspiring profusely. Because most serum glucose depends on dietary intake, nutrition therapy is a vital component in the prevention and management of diabetes mellitus which necessitates a special diet plan. Nutrition therapy  is again necessary with a special diet limiting or modifying the fat and sodium intake for a patient with coronary or vascular disorders.

Thus, Health Information Management (HIM) / Medical Records (MR) practitioners will find within medical records, progress notes with the nutritional care of the patient met in accordance with the doctor’s orders which includes the nutrition therapy, and the patient’s progress from the nutrition therapy documented by the nutritionist.

I think medical records will only be complete if a patient at nutrition risk undergoing nutrition therapy has his or her medical record showing progress notes from the nutrition therapy documented by the nutritionist. This particular instance of medical record completeness must be satisfied irrespective of your type of hospital, either it is or it is not already Joint Commission International (JCI) accredited or seeking JCI accreditation status or undergoing re-survey for JCI accreditation status, but if it is, then your hospital will need to comply with JCI Standard COP.5 which requires that “Patients at nutrition risk receive nutrition therapy.”

If JCI Standard COP.5 and its four (4) Measurable Elements are complied satisfactorily, then your medical record also complies with the JCI Standard MCI.19.1 which states that “The clinical record contains sufficient information to identify the patient, to support the diagnosis, to justify the treatment, to document the course and results of treatment, and to promote continuity of care among health care practitioners.”

Before I end, some of you may be wondering what’s the difference between a dietitian and a nutritionist? I am not going to elaborate much on this but since I have used the terms dietitian and nutritionist in three related posts on nutrition,  I know for certain that dietitians and nutritionists are both food and nutrition experts respectively. You may find out more on dietitians and nutritionists from the Academy of Nutrition and Dietetics (United States) and from the University of Maryland Medical Center, United States. Some say dietitians are considered to be nutritionists, but not all nutritionists are dietitians.

References:

  1. Catherine, AR, Benjamin, C, Robert, JC, Katherine, LT & Thomas, LT (eds.) 2014,  Modern nutrition in health and disease, 11th ed, Lippincott Williams & Wilkins, Philadelphia, USA
  2. Joint Commission International, 2010, Joint Commission International Accreditation Standards For Hospitals, 4th edn, JCI, USA
  3. Sylvia, ES 2012, Nutrition and diagnosis-related care, 7th edn, Lippincott Williams & Wilkins, Philadelphia, USA

Impossible for a hospital to collect data to measure everything it wants

Posted on by
Reply

It is impossible for a hospital to collect data to measure everything it wants due to its limited resources.  Thus, while a hospital may desire to choose which ever clinical processes and outcomes are most important, but I think it is a prerequisite that any hospital must collect data to measure the managerial processes and outcomes which relates to patient demographics and clinical diagnoses based on its mission, patient needs, and services.

The process, procedure, or outcome to be measured for the managerial area which relates to patient demographics and clinical diagnoses is one of the nine managerial measures recommended by the Joint Commission International (JCI) as outlined under the JCI Standard QPS.3.2 which states that “The organization’s leaders identify key measures for each of the organization’s managerial structures, processes, and outcomes.”

The subject of process, procedure and outcome reminds me of the Three Core Process Model, which groups the many processes that take place in any hospital into three core categories: (1) clinical processes, (2) operational or patient flow processes, and (3) administrative processes.

I shall focus on operational or patient flow processes, and administrative processes which concern the managerial processes and outcomes which relates to patient demographics and clinical diagnoses.

Health Information Management (HIM) / Medical Records (MR) practitioners will be familiar with the standardised operational or patient flow processes which includes processes that typically start with registering and admitting of patients during their visit to the hospital or in the course of their stay in the hospital that enable them to access the clinical processes related to diagnosis, treatment, prevention, and palliative care to address their clinical needs. An operational/patient flow process is an example of a managerial process which utilises and collects patient demographics data during the processes available and familiar to HIM / MR  practitioners when:

  1. admitting inpatients for care
  2. for registering outpatients for services
  3. admission directly from the emergency service to an inpatient unit
  4. the process for holding patients for observation in the Emergency department (ED)
  5. how patients are managed when inpatient facilities (beds and/or services) are limited
  6. how patients are managed when no space is available due to ED crowding and high hospital occupancy rates, thereby creating temporary inpatient holding areas (boarding patients) before admitting patients or to admit patients to the appropriate unit

The administrative decision-making core processes occupy two positions in The Three Core Process Model, one above clinical processes and the other below operational or patient flow processes. Decision making, communication, resource allocation, and performance evaluation processes make up the administrative decision-making core processes. These processes are definitely not under the domain of HIM / MR  practitioners, but HIM / MR  practitioners do contribute to administrative decision-making core processes by the hospital’s leaders by providing data, e.g bed statistics for resource allocation, participating in performance evaluation processes from e.g. Medical Records Review data analysis, uniform use of diagnosis and in the procedure codes based on patient record documentation which supports data aggregation and analysis as well implementation of diagnosis-related groups (DRGs) for decision making processes, and when they communicate with care providers about documentation and compliance issues related to the appropriate assignment of diagnosis and procedure codes.

HIM / MR  practitioners will be aware of prevailing mandatory local, national and international guidelines, standards and norms to measure processes related to patient demographics and clinical diagnoses. Nonetheless a hospital’s leaders are finally responsible for making the final selection of targeted measurement activities. The hospital’s leaders will decide and determine the following:

  1. identify the process, procedure, or outcome to be measured
  2. the availability of “science” or “evidence” supporting the measure to reduce unwanted variation in outcomes
  3. how the measurement will be accomplished by deciding the frequency of measurement
  4. how to organise the measurement activities so as to incorporate data collection into daily work processes

Hospital leaders are busy attending to both operating and strategic-level issues that concern quality, but they usually and always put patients first, and they will use data and information to examine and respond to problems, and rely on the participation of the entire workforce including HIM / MR  practitioners as members of the team who must possess a thorough understanding of the processes and the knowledge of specific tools to assess and to improve processes including those related to patient demographics and clinical diagnoses.  HIM / MR  practitioners must work with the hospital’s leaders to constantly seek changes that will co-produce improvement in a continuous cycle while outside regulators for example, the JCI checks on the quality of care of patient care systems and the outcomes they produce.

The measures selected and the analysis of the measurement data must ultimately fit into the hospital’s overall plan for quality measurement and patient safety, when they prove helpful in better understanding or more intensively assessing the areas related to patient demographics and clinical diagnoses that is under study. They also help to formulate strategies for improvement in the area being measured, and subsequent follow-up measures becomes helpful in understanding the effectiveness of the improvement strategy.

References:

  1. Diane, LK 2007, Applying quality management in healthcare : a systems approach, 2nd edn, Health Administration Press, Chicago, Illinois, USA
  2. Joint Commission International, 2010, Joint Commission International Accreditation Standards For Hospitals, 4th edn, JCI, USA
  3. Prathibha, V (ed.) 2010, Medical quality management : theory and practice, 2nd edn,  Jones and Bartlett Publishers, Sudbury, MA, USA

JCI Standard MCI.19.4 – Patient Clinical Record, Medical Records Review, Medical Records Review Protocol, latest Medical Records Review Tool

Posted on by
Reply

I know that the most frequently viewed post(s) on this blog are regarding Medical Record Review (MMR) using the Joint Commission International (JCI) Accreditation Hospital Standards.

This post is also regarding Medical Record Review. I shall be using ‘Medical Record Review’ rather than ‘Medical Records Review’ from now on to reflect what JCI uses in its manual. I guess this is no big deal, but I shall conform.

I have been using the term MMR Tool (MMRT) but do take note that the MMRT is also referred to as the Medical Record Review Form (MMRF) as in the JCI’s Hospital Survey Process Guide (HSPG).

This post is about the MMRT / MMRF as recommended in the JCI’s HSPG, 4th Edition, Version 2 effective 1 January 2011. All future posts related to the application of the MMRT / MMRF will be based on this latest edition of the JCI’s HSPG.

I have been posting posts related to the application of the MMRT / MMRF (you can view this particular tool /form from this link which will open in a new tab of your current window) as recommended in the JCI’s HSPG, 3rd Edition, effective January 2008.

You can view a sample of the latest MMRT / MMRF from this link, which will open in a new tab of your current window.

The purpose of using the MMRT / MMRF according to JCI (HSPG, 4th edn, p. 70) remains as before, that is to help “validate the hospital’s compliance with the documentation track record”, i.e to also say in JCI’s words (HSPG, 4th edn, p.70) that is “to gather and document compliance with standards that require documentation in the patient’s record”.

Health Information Management (HIM) / Medical Records (MR) practitioners need to know that the MMRT / MMRF is used during closed patient medical record review session(s) in addition to during tracer activities when the same MMRT / MMRF is used during open patient medical record review session(s) using ‘open’ medical records of patients currently staying in the hospital are evaluated.

While I understand that the survey team will provide the latest version of the MMRT / MMRF which will include any approved changes in the standards, an HIM /MR practitioner or the hospital quality assurance (QA) department is usually required to provide the MMRT / MMRF for mock closed or open patient medical record review session(s).

You will notice that both the latest and previous versions of the MMRT / MMRF are organised as follows:

By three (3) topic headings, ‘Consent’, ‘Assessments’ and ‘Other’

  1. Each topic heading includes several standards
  2. Each standard under a topic heading lists the specific standard number e.g ‘ACC.3.2.1’ as listed under the topic heading ‘Other’
  3. Each specific standard under a topic heading lists the standard requirement i.e the specific standard’s requirement as will be printed in the ‘Documentation Requirement’ column in the MMRT / MMRF, e.g the standard ACC.3.2.1 requirement is as printed below:

“Discharge summary contains the following:

      • Reason for admission, diagnoses, and comorbidities
      • Significant physical and other findings
      • Diagnostic and therapeutic procedures performed
      • Significant medications, including discharge medications
      • The patient’s condition/status at the time of discharge
      • Follow-up instructions”

During an accreditation survey,  the surveyor(s) – be they be members of the real JCI accreditation surveyor or members of the hospital’s mock MMR process team, will both use the MMRT / MMRF :

  1. to enter the number of the medical record being reviewed and the type of medical record requested (recorded by diagnosis) on the top of the form, e.g  “Record #1234678  Asthma”)
  2. to review the medical record according to JCI (HSPG, 4th edn, p. 70) so as “briefly to decide what type of patient or care was received (for example, surgery, medical, emergency, and rehabilitation).”

Another request (s) by the survey team or a typical MMR session by the hospital’s mock MMR process team can be read by reading my previous posts as follows  (each of these links will open in a separate tab of your current window) :

  1. JCI Standard MCI.19.4 – Patient Clinical Record, Medical Records Review, Medical Records Review Protocol, Medical Records Review Tool
  2. JCI Standard MCI.19.4 – Patient Clinical Record, Medical Records Review, Medical Records Review Protocol

References:

  1. Joint Commission International, 2010, Joint Commission International Accreditation Standards For Hospitals, 4th edn, JCI, USA
  2. Joint Commission International, 2010, Hospital Survey Process Guide (HSPG), 4th edn, JCI, USA
  3. Joint Commission International, 2010, Hospital Survey Process Guide (HSPG), 3rd edn, JCI, USA

MSQH – SERVICE STANDARD 7, Organisation and Management for STANDARD 7.1.1

Posted on by
Reply

MSQH-Book-SS7-HMISOrganisation and Management is the first topic among six (6) topics which make up the standards under SERVICE STANDARD 7 for Health Information Management System (HIMS) based on the 4th Edition of the Malaysian Society for Quality in Health (MSQH) Hospital Accreditation Standards effective January 2013, used by the MSQH, which is the sole Malaysian accreditation body with nationally established standards for health care facilities and services since 1997, dedicated to improving the quality of Malaysia’s health care through voluntary accreditation. You can read about the 6 topics from the post MSQH – Introductory Post (this link will open in a new tab of your current window) as well view the hierarchy of these topics (the green boxes) from the graphic below (click on the graphic to view a larger image which will open in a new tab of your current window).

MSQH Service Standard 7

Standard 7.1.1 is the first standard for Service Standard 7 and the only standard under the topic Organisation and Management (OM) which states that “The Health Information Management System (HIMS) Services shall be organised and administered to facilitate the collation, aggregation and analysis of hospital demographic data through an established system which includes safe keeping and retrieval of medical records and documents related to patient care.

Health Information Management (HIM) / Medical Records (MR) practitioners in Malaysia whose hospitals are engaged in hospital accreditation using the 4th Edition of the Malaysian Society for Quality in Health (MSQH) Hospital Accreditation Standards effective January 2013 for the Service Standard 7 HIMS must truely know that his or her hospital needs to fully satisfy fifteen (15) criteria for compliance to the OM topic for this service standard.

The criteria for compliance to the OM topic for this service standard ranges from the organisation management of the HIM / MR Department through processes planning and continued development, data management of information about major clinical services that meets Malaysian statutory requirements, reporting systems for incident reports, the formation and activities of a Medical Records Committee, and ends with the department’s involvement in quality improvement activities.

You can view the whole range of criteria listed from https://docs.google.com/file/d/0B1XnOSMJXDaqR184d1BsbHQxQWs/edit (this link will open in a new tab of your current window) from the Download List Sub-Menu under the Resources Menu.

Now I like to draw your attention to the variation or differentiation between nearly identical entities and other non-identical entities found under MSQH Service Standard 7, Standard 7.1.1 and those found under the  Joint Commission International (JCI) hospital accreditation standards,

HIM / MR practitioners will find a similarity between JCI hospital accreditation found in Standard MCI.9 (which I have not blogged on as yet) with  the MSQH Service Standard 7, Standard 7.1.1 under Criterias 7.1.1.1 to 7.1.1.10 when both of them try to cover aspects of the HIM / MR department’s mission, services provided, resources, access to affordable technology,and support for effective communication among caregivers

HIM / MR practitioners will find another similarity between JCI hospital accreditation found in Standard MCI.19.4 with the MSQH Service Standard 7, Standard 7.1.1 under Criteria 7.1.1.13 which requires regular Medical Records Review (MRR) sessions. However the MSQH Service Standard 7, Standard 7.1.1 under Criteria 7.1.1.13 does not elaborate the review process nor is there any  MMR tool to use unlike that found under JCI.

Unlike hospital accreditation for JCI accreditation status, a specific Root Cause Analysis (RCA) activity is required of HIM / MR practitioners under  the MSQH Service Standard 7, Standard 7.1.1 under Criteria 7.1.1.12 . I hope HIM / MR practitioners will not be wrongly allocated the task of conducting RCA for all incidents that occur in the hospital but rather they will only be confined to RCA for all incidents that occur for HMIS services only. as I understand from Criteria 7.1.1.11, MSQH Service Standard 7, Standard 7.1.1 which stipulates that “The Head of the HIMS Services shall ensure that the staff of HIMS Services complete incident reports which are discussed by the services with learning objectives and forwarded to the Person In Charge (PIC) of the Facility.”

There is no direct reference to “The Medical Records Committee” to be found in JCI. However, HIM / MR practitioners in Malaysia need to be aware that according to the notes found under Criteria 7.1.1.13, MSQH Service Standard 7, Standard 7.1.1 “The Medical Records Committee is a subcommittee of Medical and Dental Advisory Committee (MDAC) who advises the Governing Body on matters pertaining to HIMS.” and not as reporting directly to the Hospital’s Director or other equivalent top management official.

Quality Assurance (QA) Managers and their departments are normally assigned the duties of facilitating quality improvement (QI) activities for the hospital. I can infer that QA managers have a specialised and trained role in QI, and thus are fully qualified to be the facilitator of such QI activities, Nonetheless, Criteria 7.1.1.15, MSQH Service Standard 7, Standard 7.1.1 has assigned this role with the given and added responsibility to HIM / MR practitioners to be the “facilitator for quality improvement activities of the Facility. Areas of involvement may include:

a) compiling patient care data for clinical review/research;

b) supervising data collection and advising on analysis of data collected by personnel of other services.”

Lastly, I find that MSQH Service Standard 7, Standard 7.1.1 does not have set criteria to cover the clause “safe keeping and retrieval of medical records and documents related to patient care.” while on the contrary Standard MCI.12 of the JCI clearly states that “The organization has a policy on the retention time of records, data, and information.”

References:

  1. Joint Commission International, 2010, Joint Commission International Accreditation Standards For Hospitals, 4th edn, JCI, USA
  2. SERVICE STANDARD 7 Health Information Management System 2013, Malaysian Hospital Accreditation Standards, 4th edn, The Malaysian Society for Quality in Health (MSQH), Malaysia