No adverse action should be taken until peer review is completed, and even then, education should be the first recourse taken. An important aspect in this simplified plan, of course, will be an appeals mechanism at all levels of the review. The approach HCFA is taking toward documentation will rely extensively on development of vignettes. The AMA supports the use of vignettes. While it is still undetermined how these vignettes will be developed, or by whom, their use will be critical to the success of the new approach.
Physicians have some familiarity with the use of vignettes.
Physicians will need to know the rules carriers will use in determining the adequacy of the medical record documentation. Consistency in carrier review of the adequacy of the documentation in the medical record is of utmost importance. I look forward to a timely response to our concerns. Copyright 1995-2001 American Medical Association. All rights reserved.