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VA’S PATIENT RECORD FLAGS: THE REST OF THE
STORY — More about who can flag a veteran’s
medical records and what can be done about it.
On Sep. 11, 2007, I posted a story about the Patient Record Flag (PRF) in the VA’s VistA electronic medical records system. That story here… http://www.vawatchdog.org/
The general tone of the above story was that veterans could be “blacklisted” by having their records flagged.
This raised a number of questions that need answering.
I would like to thank many current and former VA employees for helping me piece together the following information about PRFs. And a special thanks to Jo Schuda who is in Public Affairs at the VA’s Central Office (VACO).
WHY DOES A VETERAN’S FILE GET FLAGGED?
Patient record flags are used to alert VHA medical staff and employees of patients whose behavior and characteristics may pose a threat either to their safety, the safety of other patients, or compromise the delivery of quality health care. These flag assignments are displayed during the patient look-up process.
The use of patient record flags must be strictly controlled and implemented following the instruction provided in VA Directive 2003-048.
The above VistA instruction can be found here…
The purpose of the PRF is to protect the veteran, other patients and VA staff.
Here is an example of a PRF:
1. Flag Name: <BEHAVIORAL>
Category: I (NATIONAL)
Assignment Narrative: On 4/8/03, this veteran was disruptive and threatening toward numerous
staff. RECOMMEND: VA Police should be immediately called to standby until they and the clinician decide that standby is no longer necessary.
Initial Assignment: May 20, 2003
Approved By: ADTAPPROVER,ONE
Next Review Date: May 20, 2005
Owner Site: ALBANY VAMC (UPSTATE NEW YORK HCS)
Originating Site: EL PASO VA HCS (EL PASO VA HCS)
Progress Note Linked: No
What are some of the reasons for a flag? The VA lists the following:
Criteria for Category I PRFs may include, but are not limited to:
1. A history of physical violence against patients or staff at a medical center or clinic.
2. Documented acts of repeated violence against others.
3. Credible verbal threats of harm against specific individuals, patients, staff, or VA property.
4. Possession of weapons or objects used as weapons in a health care facility.
5. A history of suicidal or parasuicidal behavior within health care facilities.
6. A history of repeated nuisance and disruptive or larcenous behavior that disrupts the environment of care.
7. A history of sexual harassment toward patients or staff.
WHO CAN FLAG A VETERANS’ RECORDS?
Although many VA staff members have “write” access to VistA to enter clinical notes and information, the number of people who can flag a veteran’s records is strictly limited.
Just because a caregiver can enter clinical notes does NOT mean they can flag a record.
Entry of flags is controlled by the local VA’s Disruptive Behavior Committee (DBC) which is led by the hospital’s Chief of Staff.
If a VA employee feels a veteran should be flagged, they must present evidence to the DBC. The DBC then decides if a flag should be entered.
Only a few persons in each VA facility can actually enter a flag. They are assigned by the Chief of Staff and usually are heads of departments are senior medical personnel.
Once a flag is entered, it must be reviewed every two years to see if it is still valid and should stay in the system.
WHO CAN SEE A PATIENT FLAG?
Basically, this is any VA employee with a need to know. The VA lists the following:
(1) Emergency room clerks and receptionists,
(2) Administrative Officer of the Day,
(3) Pharmacists and pharmacy technicians,
(4) VA police officers,
(5) Enrollment clerks,
(6) Social Work staff,
(7) Triage and/or telephone care staff,
(8) Ward and clinic clerks,
(9) Insurance and billing staff
(11) Travel clerks,
(12) Laboratory clerks and technicians,
(13) All medical staff,
(14) Patient advocates,
(15) Nursing and unit supervisors,
(16) Decedent Affairs Clerk,
(17) Scheduling staff, and
(18) Fee clerks.
CAN A VETERAN FIND OUT IF THEY HAVE A PRF?
The easy way is to just look over the doctor’s shoulder when they access the records. If the flag box (see graphic above) is grey…no flag. If it’s red…that’s a flag.
Chances are a VA doctor will not explain the flag to a veteran.
But, a veteran can get this information.
Here is how you do that. This information is from the VA:
A PRF is part of the medical record and can be accessed by the veteran in the same way he or she accesses the medical record.
The veteran must make a written request for a copy of the record.
The PRF may or may not be subject to sensitive-record review prior to disclosure as required by 38 U.S.C. 5701.
The above mention of “sensitive-record” means that some vets will not be able to get the information about the flag. These would be the same vets who find their records cannot be given to them “for the good of the patient.” This happens, generally speaking, in cases where the vet has severe mental health issues and would, most likely, not be able to understand the content of the records or flags. This only applies to a VERY small number of vets.
CAN A VETERAN GET A FLAG CHANGED OR DELETED?
Again, this information is from the VA.
A veteran has the right to request an amendment to any information or records retrieved by the individual’s name or other individually-identifiable information contained in a VA system of records. This is specified in 38 CFR 1.579 and 45 CFR 164.526.
The request must be in writing and mailed or delivered to the facility, addressed to the privacy officer.
If the amendment request to remove language is approved, whatever was specified for removal is no longer in the active view.
If a request to amend a record is denied, the system manager or designee for the system of records involved, and/or the facility privacy officer or designee, will promptly notify the veteran. The written notification will state the reasons for the denial, notify the individual that the denial may be appealed to VA’s Office of the General Counsel and include the procedures for such an appeal.
It should be noted that although a vet can get a flag amended or deleted from active-view (no red flag box), the information does stay in the record. The reason is that medical records cannot have deletions. They can have information corrected, but information cannot be permanently removed. This is standard practice in the healthcare industry.
IS THE VA’S PRF SYSTEM SUBJECT TO ABUSE?
This could be done, but it would be a difficult process.
Recent interviews with a Chief of Staff at a VA hospital and a former Information Technology (IT) chief at another VA hospital leave me with the impression that the controls implemented by the DBC work in the veteran’s favor and make it virtually impossible for an individual VA employee to forward some kind of vendetta through the PRF system.
I have heard many veterans complain about bogus PRFs (see below), but I have never seen any evidence to substantiate their claims.
This is another reason why veterans’ advocates tell all veterans to get a copy of their VA records at least once a year. The veteran should be sure to ask for PRF information when requesting records.
MY PERSONAL VIEWS ON PRFs
I went to see my VA doctor yesterday. The flag box was grey…now I know I am not flagged.
I have communicated with many vets who have complained about being flagged. After many email or phone exchanges, ALL of them finally admitted that they had either been loud, unruly, abusive, threatening, lost their temper or gone in for an appointment under the influence of alcohol. These are all good reasons for a flag.
These vets all have the right to get these flags modified or removed from view. I hope they keep their act(s) together and get the flags taken care of as their behavior improves.
But, can the system be abused? Yes. But, it would take a lot of work…and, the question would be: Why?
So, the previous article’s mention of “blacklists” is accurate in that flags can be viewed in that perspective. But, another way to view the “blacklist” is that it serves as a warning about possible dangerous behavior.
Even though the PRF system may be “open to” widespread abuse by VA employees, we have no evidence that this has happened or that veterans have been harmed by the PRF system in any way.
For a complete look at the VA’s guidelines and regulations for Patient Record Flags, click here…
For more about VistA software, use the VA Watchdog search engine…click here…
Larry Scott —
Read the full thread below
repost.......... Printer Friendly Page VAS PATIENT RECORD FLAGS: THE REST OF THE STORY -- More about who can flag a veterans medical records and what can be done about it. On Sep. 11, 2007, I posted a story about the Patient Record Flag (PRF) in the VAs VistA electronic medical records system.