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A hospital repeatedly reminded a physician to update his medical records in a timely manner. After there was no change in the physician’s behavior, the hospital initiated an investigation, which revealed that the physician had more than 300 incomplete medical records. As a result, the hospital took a professional review action to suspend the physician’s clinical privileges for 60 days, citing professional misconduct. Because there was no actual patient harm, should this be reported to the NPDB?
It depends. A clinical privileges action must be reported to the NPDB if it is the result of a professional review action related to professional competence or conduct that adversely affects, or could adversely affect, the health or welfare of a patient and lasts for a period longer than 30 days. Whether a practitioner’s behavior affects or could affect patient health or welfare is a determination that generally must be made by the entity taking the action. If, in the opinion of the Medical Executive Committee (MEC), the physician’s lack of attention to updating medical records in a timely manner could adversely affect the health or welfare of a patient, and the action is the result of a professional review, the action must be reported to the NPDB.