Martin has hit the nail cleanly on the head. The current regs are
difficult to interpret. I have had informal chats with several colleagues
around the country and the bottom line appears to be that people are
interpreting the rules as they see fit. In some places diiferent members
of the same group have different understandings of the rules (this
doesn't make much sense because if you get dinged by the feds, the whole
group takes the hit).
I have heard every possible interpretation from "I am present if I am in
the ED to I stand at the bedside and critique every suture and count
every drop of CSF."
We have elected to document on the same page as the resident and to
document only the "key elements" of the, history, exam, impression, and
plan. We not so jokingly call this the four words (e.g. "Fever,
Non-toxic, Otitis, Amox). We do ask the resident to indicate on the chart
that we saw the patient. (if we indeed did)
Finally, not that I'm paranoid, mind you but I would caution the members of
the list to discuss this in rather generic terms, at least on the list.
This list is essentially public information. I wouldn't want someone to
attract a HCFA audit by a posting that indicates a variance from the rules.
One of my fellow attendings made a wise crack about a certain drug
company on the E-Med-L list and soon thereafter received an angry reply
from a company executive who had been lurking on the list for a while, so
you never know who reads this stuff.
For more information, send mail to [log in to unmask] with the message: info PED-EM-L
The URL for the PED-EM-L Web Page is: