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4.4.09

Networking

One advantage electronic records have to offer is simple
and fast electronic transmission of test results and
other documents between health care providers or
facilities. At the time of writing, electronic systems are
not sufficiently sophisticated to manage such transactions.
This development is anticipated. In the interim,
a physician may not rely on electronic communications
of this type unless he or she has taken reasonable
steps to ensure that documents sent are received.
Transfer from Paper to Electronic Records
When a physician scans his or her paper records to
convert them to electronic form, the original paper
records may be destroyed in accordance with the principles
set out in this policy.
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2.4.09

Record Storage

Copying patient records is easy and inexpensive in
electronic form. It is essential that a physician be aware
of the number of copies of his or her records that are
created and ensure that only as many copies are maintained
as are required for system security. For example,
many physicians will rely on systems in which a central
server is used for storage. The physician must ensure
that the privacy of patient records will be adequately
protected whether the information is stored in premises
within the physician’s control or otherwise. Physicians
must discuss how records can be expunged or protected
by the service provider before entering into a contract
for the provision of the service. In order to protect
patient privacy, when the physician ceases to use that
storage system, he or she should ensure that no copy is
left with the server. If the information is stored on the
computer’s hard drive, the hard drive itself should
either be crushed or wiped clean with a commercial
disk wiping utility. Similarly, any back-up copies of
medical records should be destroyed when the original
records are destroyed.
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Electronic Records

All of the principles discussed in this policy apply
equally to electronic records. The records must contain
the story of the patient. While there is some
debate about the preferred format of electronic
records (e.g., template-based records vs. voice dictation-
based records), an electronic format will be adequate
if it can capture all the pertinent personal health
information and allows the user to centralize the
essentials of the patient’s story on several screens. If
the format cannot do this, it is probably not satisfactory
and the physician should consider using an alternative
system.
The College recognizes some limitations of electronic
records at the time of writing this policy. In many
cases, the printable version of the electronic record
does not readily enable a reviewer to understand the
whole patient record and is, therefore, of limited use.
Furthermore, some of the systems do not readily allow
the physician to capture nuances of the patient
encounter. Physicians using such systems must ensure
that each record entry captures the unique aspects of
that particular patient encounter. The College is aware
that this is a developing area and that there is great
potential for electronic record keeping to enhance the
practice of medicine.
Physicians have an obligation to provide printed
copies of electronic records when asked to do so. In
order to ensure they can be understood, some physicians
provide the print-out from the electronic record
together with a dictated summary to provide an
overview of the patient’s story.
Specific requirements for physicians who maintain
electronic patient records are set out in sections 18-21
of Ontario Regulation 114/94, listed in Appendix A.
The College notes that residents frequently retain
patient information on PDAs and laptops in order to
track workload and for educational purposes. Issues
about storage, deletion of records and privacy of
health information can pose the same problems in this
context as discussed elsewhere in this policy, and those
who are using records in this fashion are cautioned to
ensure that they are doing so in adherence to the policy.
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1.4.09

Storage and Security

Medical records must be stored in a safe and secure
environment to safeguard their physical integrity and
confidentiality. Physicians must take reasonable steps
to ensure that records are protected from theft, loss
and unauthorized use or disclosure, including photocopying,
modification or disposal.
What is reasonable depends on the threats, risks and
vulnerabilities to which the information is exposed,
the sensitivity of the information, and the extent to
which it can be linked to an identifiable individual.
Consideration must be given to each of the following
aspects of record protection:
• Physical security (for example, locked file cabinets,
restricted office access, alarm systems).
• Technological security (for example, passwords,
encryption and firewalls).
• Administrative controls (for example, security clearances,
access restrictions, staff training and confidentiality
agreements).8
Patient records should be kept in restricted access
areas or locked filing cabinets, and measures should be
in place to ensure that only those who need access to
the records for a legitimate purpose are able to see
them. Physicians need to consider that non-medical staff,
such as maintenance staff, may have access to
records, and must ensure that steps are taken to
ensure that access to the records is limited or that
those who have access to the records are bound by an
appropriate confidentiality agreement.
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29.3.09

Removing Portions of the Record

Sometimes storage requirements may necessitate the
removal of some materials from a patient’s active
chart. If investigation results and consultation reports
are no longer relevant to the patient’s current care, it is
permissible to store them elsewhere (in accordance
with the retention requirements set out in the regulation,
see below for further detail). In such instances,
the physician should make a notation indicating that
documents have been removed from the chart and the
location where they have been stored.

Clarity and Legibility
The regulation requires that medical records be legible.
5 Furthermore, the College expects that the records
can be interpreted by the average health care professional.
If there is difficulty with the legibility of the
records, an alternate means of note taking should be
considered (e.g., voice dictation, electronic medical
records, or handwriting recognition software).
Using conventional medical short forms is permissible.
However, the meaning should be readily available to
a health care professional reading the record.
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28.3.09

Timing of the Events

All patient-related documentation must be dated.
Consultation reports, laboratory and diagnostic results
must be manually or electronically initialed and dated
when they are reviewed. Every patient encounter must
be documented and dated in the medical record.
Where there will be more than one physician making
entries in a record, each physician’s entry must be identified
by signature and, if appropriate, position or title.
The Health Insurance Act (relevant excerpts of which
can be found at Appendix C) requires that physicians
record the start and stop time for certain types of
patient encounters, such as psychotherapy and counselling.
In addition to these, it is prudent for physicians
to record the start and stop times for some other
types of clinical encounters, such as procedures in the
ER, resuscitation, administration of medications, and
telephone conversations.
The College recommends that entries be recorded as
closely as possible to the time of the encounter, when
the detail is most fresh in the physician’s mind. This
will allow physicians to keep records that are detailed,
accurate and comprehensive
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26.3.09

OHIP Documentation Requirements

OHIP and Ministry of Health and Long-Term Care
(MOHLTC) requirements may change over time and
physicians should stay abreast of any changes through
OHIP and Ontario Medical Association (OMA)
information sources.
Physicians must understand their obligations under
the Health Insurance Act and the OHIP Schedule of
Benefits. Section 37.1 of the Health Insurance Act,
which deals with record keeping, is attached as
Appendix C.
Good records demonstrate that a service was provided
to the patient and establish that the service provided
was medically necessary. It is, therefore, imperative
that physicians maintain accurate and comprehensive
records, in order to receive payment for their services.
Any questions that physicians may have regarding the
OHIP Schedule of Benefits should be directed to the
appropriate local branch of OHIP or the Provider
Services Branch of the MOHLTC.
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25.3.09

The Daily Diary of Appointments

Maintaining a daily diary of patient appointments is
required by the regulation4 and must include all
professional encounters.
While some physicians use the diary only to list the
patients seen each day, the daily diary can also contain
other useful information, such as the patient file and
OHIP number, the patient complaint or health problem,
and information related to the complaint or problem.
Recording information relating to the patient complaint
or problem will facilitate the task of billing OHIP.

Chronological and Systematic
It is strongly recommended that all materials in the
patient chart be organized in a chronological and
systematic manner.
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Comply with all Legal Requirements

The medical record is a legal document which records
events and decisions that help physicians manage patient
care. A physician following the recommendations in this
policy will be in compliance with the record keeping
requirements of the College and requirements set out in
the Ontario Regulations made under the Medicine Act
(referred to in this policy as the “regulation”).2 The regulation
is included at Appendix A.
Many physicians are also associated with institutions
or facilities that may have their own record keeping
requirements. Physicians to whom this applies should
investigate and be familiar with those legal obligations
that may arise in the Public Hospitals Act, the Long-
Term Care Act, or the Independent Health Facilities Act.
Other legislation, such as the Mental Health Act and
the Personal Health Information Protection Act
(PHIPA)3 also has an impact on medical records,
either on what is in them or to whom they may be
transferred. These will be referred to in more detail in
the applicable sections below.
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Continuity and Quality in Medical Care

The medical record must “tell the story” of the patient
as determined by the physician in the circumstances
in which he or she saw the patient. The components
necessary to tell the story are set out in detail below.
The record is not just a personal memory aid for the
individual physician who creates it. It must allow
other health care providers to read quickly and understand
the patient’s past and current health concerns.
It is not expected, however, that all patients will
always be able to read and understand their medical
records. Medical records may contain abbreviations
and terminology unique to the health care professions.
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PRINCIPLES of Medical Records

Good medical record keeping is part of providing the
best quality of medical care.
Physicians are obligated to make records for each of
their patients. The primary use of these records is for
the treating physician and other health care professionals
to ascertain the patient’s medical history and identify
problems or patterns that may help determine the
course of health care that should follow. In addition,
good records can help optimize the use of resources,
both financial and human, by reducing duplication of
services and, sometimes, by identifying abuse of the
health care system. They may also provide information
essential to others for a wide variety of purposes:
billing; research; and response to public complaints,
legal proceedings or insurance claims, for example.
Some of the elements of the guidance provided below
are mandatory: either required by law, or expected by
the College as a minimum practice standard. Wherever
this is the case, the policy will explicitly indicate that
adherence is obligatory. In some cases, the obligations
do not arise from medical practice standards but from
Ontario Health Insurance Plan (OHIP) requirements:1
such instances are identified in the text. Other components
of the policy are offered as recommendations as
to the best means of providing patients with quality
medical care. These references have been included to
provide physicians with as much information about
record keeping as possible, but are not College requirements
for medical record keeping. The ultimate objective
of the policy is to set out what must be kept in
medical records and to provide physicians with a tool
that will permit them to maintain a record keeping system
that is functional, practical and easy to maintain.
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10.2.09

Pay Per Click Advertising - PPC

Definition: Ads you place for your web site with a search engine, such as Google or Yahoo. You bid the amount you are willing to pay per click. The more you bid, the higher your ad will appear in the search engine results. Google has implemented an additional factor in where you ads rank that is based on the relevancy or importance that Google places on your site, which is very difficult to manipulate.

Also Known As: PPC Advertising, Google AdWords

Examples: Using a pay per click advertising tool, like Google AdWords, your ads can appear for keywords you select whenever someone conducts a search using your keyword phrase. PPC can lead to increased traffic for your website.
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