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President's Message
By Frank Randolph, M.D.
PLEASE COMPLETE THIS FORM!
I
don't think I need to cite a study to prove to any physician that
significant physician time is committed to the completion of paperwork.
First, there is the medical record: lists for problems and medications,
progress note, flow sheets, data base, history and physical form,
history and physical update form, procedures, surgical and otherwise,
informed consent, sponge counts, operative notes, delivery notes,
admission order forms for the acute hospital, nursing home, adult
day care, home care, hospice, and various rehab entities, and discharge
order forms, to name a few. There are forms for quality improvement,
risk management, credentialing, and numerous insurance-related forms
related to being a provider. Forms to order labs. Forms to indicate
one has seen and acted upon lab and radiologic data. There are newer
forms mandated by government entities that require inquiry about
risky behaviors, nutrition, and assorted other health risks.
Second, there are payer-initiated authorization forms for services,
medical supplies, and durable medical equipment. In like fashion,
the managed care industry has contributed a legion of forms documenting
the utilization management process.
Third, there are forms related to state or federal reporting requirements.
There are numerous conditions that must be reported to the Department
of Health Services. Certain types of injuries, or patient-initiated
threats of physical violence must be reported to the Department
of Justice. Other examples include the reporting conditions likely
to impair driving. There are forms to insure that physician report
their knowledge of circumstances likely to endanger the safety of
children, dependent adults, and the elderly to protective agencies.
The National Childhood Vaccine Injury Act of 1986 requires health
care providers to report to DHHS using the VAERS form. Some reporting
is voluntary, such as reporting of adverse events involving medications,
but a form is used for this as well (FDA form 3500). The CMA has
helped to develop forms for reporting that simplify the process.
Better keep a log of such disclosures, because, with some exception,
a patient has the right to receive an accounting of disclosures
of protected health information for the six year period prior to
the request (new HIPAA requirements).
Finally, there are a plethora of forms that federal, state and
county agencies have developed that require physicians to make judgments
about a patient's capacity to make decisions about health care,
finances, and other matters.
One wonders about the nature of the physician obligation toward
all of these forms. Clearly we have a duty where it concerns the
direct medical care of the patient. But many of these forms grow
outside that duty. In some cases we are compensated. In many cases,
there is no compensation. If we choose not to complete the forms,
we may fear that patients will not get the care or services they
need, or that they may be harmed in some way. If we complete the
forms hastily or inaccurately, or if we elect not to complete certain
forms, we might do harm to our patients, be accused of fraud, be
in violation of contracts we may have signed with health plans or
insurers, or face fines or incarceration. A recent article (American
Medical News, March 24/31, v. 46 (12), confirms that some physicians
are choosing to charge an administrative fee for certain services,
and that medical societies and consultants are receiving more phone
calls from physicians asking for advice on fee structures.
Important information regarding forms and laws governing forms
and reporting may be found in the California Physician's Legal Handbook,
a CMA publication. My personal revelation related to the myriad
of rules we must adhere to and forms we must complete is as follows:
- Continuing medical education for physicians should include up
to date summaries and how-to-do-it-all refreshers, approved by
accrediting bodies.
- Organized medicine should work with the medical board, state,
and federal agencies (including HIPAA experts) to standardize
the forms and reporting requirements. Medical Societies should
examine their role in helping their members with the dilemma posed
above, in terms of simpler methods to comply, or when it is OK
to charge for the time spent.
- Medical schools should cover this information through all four
years of medical school, to begin to prepare physicians for the
deluge.
Many feel that the HIPAA requirement will actually simplify many
of the forms we must currently complete -that is encouraging. Physicians
currently discouraged by the mountain of paper and complicated compliance
requirements they face in modern practice need a break here. There
is no getting around some of these requirements but there has got
to be a simpler way.
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