Agree with above. Most of our denials are from records that are months old so we wouldn't query on those records. Even if we did get a denial from a recent discharge, we would not query and consider the chart closed at that point.
Yes, most payers will not accept such amendments, but more serious issue from my point of view is that you are running a compliance risk.
Unless you discovered that information for one patient was accidentally documented in the other patient record, adding and amending documentation after such a long time will be non-compliant from HIM perspective.
JCAHO does not provide a definite timeframe within which documentation amendments post-discharge are allowed, but most facilities accept 30 days as their internal policy..
You probably have to discuss your internal process for documentation amendments with your HIM and Compliance departments/
Thank you to everyone that has provided feedback. below are some of the references I have found. I still do not feel we have a clear answer. I see this dilemma as ultimately setting the patient record straight. If there is no time limit on reporting a complications then why is there a time limit on clarifying information in the record? I will post more as I peel back this onion...
of Federal Regulations (CFR) > Title 42 (The Public Health and Welfare) >
Chapter IV > Subchapter G > Part 482 > Subpart C > Section 482.24
Condition of participation: Medical record services.
The hospital must
have a medical record service that has administrative responsibility for
medical records. A medical record must be maintained for every individual
evaluated or treated in the hospital.
(c)Standard: Content of record. The medical
record must contain information to justify admission and continued
hospitalization, support the diagnosis, and describe the patient's
progress and response to medications and services.
(4) All records must document the
following, as appropriate:
(viii) Final diagnosis with
completion of medical records within 30 days following discharge.
#3 is mostly related to my question as to whether a retrospective query is compliant or acceptable when seeking clarification on record (even if it is brought to hospital attention by auditing company). This still does not give a black and whit answer to the question at hand.
There are no regulations that I was able to find, other then payor contracts that state query has to be submitted within 60 days. Allen is correct, Medicare allows rebills even for higher weighted DRG up to 1 year. 3 years for quality, non-financial rebill. Other Medicare Advantage plans have to abide by the same regulation. For Medicaid and Medicaid Advantage plans in CA it is 3 months.