January 19, 2016 – Revised 01.13.20
Entries in Medical Records: Amendments, Corrections, and Delayed Entries
All services provided to beneficiaries are expected to be documented in the medical record at the time they are rendered. Occasionally, certain entries related to services provided are not properly documented. In this event, the documentation will need to be amended, corrected, or entered after rendering the service.
When making review determinations the MACs, CERT (Comprehensive Error Rate Testing), Recovery Auditors (RAC), SMRC, and UPICs shall consider all submitted entries that comply with the widely accepted Recordkeeping Principles described below. The MACs, CERT, Recovery Auditors, SMRC, and UPICs shall NOT consider any entries that do not comply with these principles, even if such exclusion would lead to a claim denial. For example, they shall not consider undated or unsigned entries handwritten in the margin of a document. Instead, they shall exclude these entries from consideration.
Regardless of whether a documentation submission originates from a paper record or an electronic health record, documents submitted to MACs, CERT, Recovery Auditors, SMRC, and UPICs containing amendments, corrections or addenda must:
- Clearly and permanently identify any amendment, correction or delayed entry as such, and
- Clearly indicate the date and author of any amendment, correction or delayed entry, and
- Clearly identify all original content, without deletion
Paper Medical Record
- Use a single line strike through so the original content is still readable, and
- The author of the alteration must sign and date the revision.
Electronic Health Records (EHR):
Medical record keeping within an EHR deserves special considerations; however, the principles specified above remain fundamental and necessary for document submission to MACs, CERT, Recovery Auditors, SMRC, and UPICs.
Records sourced from electronic systems containing amendments, corrections or delayed entries must:
- Distinctly identify any amendment, correction or delayed entry, and
- Provide a reliable means to clearly identify the original content, the modified content, and the date and authorship of each modification of the record.
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