Q&A: Clarifying RC.02.01.03 EP 5 (Lack of timely documentation)

February 12, 2026
Accreditation & Quality Compliance Advisor
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Q: During our recent survey, the surveyor cited four instances in which the operative notes where not timely, all of which were dictated. How can I clarify this?

A: Consider the following in this case for a clarification:

  • If there were no delays in dictation that would clear this finding, was a postoperative note documented at all? Most surgeons will write a brief note postoperatively even when dictating.
  • If not, audit the number of procedural notes and compare this to the total number of procedures requiring a note for the 30 days prior to survey to meet the 90% compliance requirement. This citation can be overturned.

Editor’s Note: Do you have a question about clarifying RFIs, policy management, or survey-prep for our experts? E-mail your queries to Jaclyn Beck at jbeck@hcpro.com and receive one-on-one advice from our experienced advisory board. Submit a question and our credible sources will provide you with a timely answer.

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