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Topic starter
Over the years, I have encountered numerous sites that document VIS distribution incorrectly. It seems that even today, some confusion remains. The intent of this post is to encourage sites to review their workflows and adjust accordingly.
Federal law requires that VIS sheets be provided to patients prior to administration of any vaccine. I think we all understand that clearly. But how well do we understand the details of the requirement?
For ease of reference, as it relates to VIS date, the law requires two components to be recorded in the patient's chart:
1) The date of the VIS sheet (edition date)
2) The date the VIS sheet was provided to the patient.
#1 above is where many go wrong. When recording 'today's date' in the VIS Date field, you are actually documenting #2, leaving #1 as an unfulfilled mandate.
For the record, #2 is satisfied by either the obs date (for obsterm workflows) or the row creation date (for table based workflows). The EMR makes it easy for us in that regard, as long as proper documentation workflows are followed (i.e. date of update is the actual date of encounter).
So, what about #1? Where does that date come from? It comes from the VIS sheet handed to the patient. It is located on the last page, typically in the lower right corner. That is the date that you are required to document as VIS Date, not 'today's date'. It is important to note that Federal Law permits distribution of 'older' VIS documents up to 6 months past a 'new version date'. This is a hold over for those site that still use 'floor stock hard copy' workflows. After 6 months, even those sites are required to update their documentation to the latest version, by law.
It is also important to note that the CDC updates the VIS documentation (thus editions) frequently, especially for certain vaccines, so if we understand the 6 month rule, it should be clear that 'storing' the VIS date for later recall/use is a BAD IDEA, unless of course you like medical-legal drama...
To be clear - the VIS date field should NOT be populated with 'today's date', rather the actual 'edition date' of the VIS document given to the patient.
Because sourcing your facts is always important, please read the following links:
https://www.cdc.gov/vaccines/hcp/vis/about/required-use-instructions.html
http://www.immunize.org/catg.d/p2027.pdf
For ease of reference, current VIS Documentation for all vaccines can be found here:
https://www.cdc.gov/vaccines/hcp/vis/current-vis.html
I encourage discussion and if you found this useful, please comment. Regardless, if you are not doing it right, please fight the good fight and get it right!
Posted : June 8, 2017 4:10 am
Hi Lee,
This is good for discussion, as many clinics do not realize what has to be documented. We found a way to make sure that we document #2, while not having to manage the latest VIS dates in our system.
In our EMR, we have a button that launches the VIS website, and we can print directly from the CDC. after giving the most current VIS for each item, we mark that a VIS from the CDC was given at todays visit. I am curious if anyone else has a similar setup. Do you just update your VIS dates as needed Lee? How often do you check if a version is updated?
Posted : June 8, 2017 5:58 am
Topic starter
The ideal workflow would require the staff to enter the date manually that is printed on the handout itself. That same date is also present on the web page(s) navigated in order to print it in the appropriate language.
It is also important to note that edition dates may differ between various language formats for the same vaccine - hence why a 'stored' value is not optimal.
If the workflow utilizes stored dates, it should be closely monitored. You can sign up for email alerts from the CDC on when VIS sheets are updated to help, but due to the different language formats and dates, it becomes a bit complex to manage.
Posted : June 8, 2017 8:00 am
1. The Date of the VIS - We get email notifications whenever a new VIS is posted to the CDC Website. When that happens, we update the new VIS date on the Immunization Custom lists and print new VISs to hand out to patients (and discard the old ones of course).
2. The date the VIS was given to the patient. I have to say that our health dept in NYS has been very specific about what they want to see. We cannot justify an obs term for example. They want information in the office visit note itself. We have been able to satisfy health dept reviewers by ensuring that the last question on the questionnaire (on the Immunization Management Form) is marked "Yes." The question says, "Vaccine information given and explained to patient?" If you're hoping to be on the safe side, please be sure your staff is marking this box!
Posted : June 14, 2017 5:11 am
Topic starter
Indeed, a workable solution. It sounds like you might also be accounting for different version dates for the languages as well.
It is possible to generate the needed text in the chart note by evaluating the VIS obsnow value (obsterm based workflows) or the VIS date in the table based array (Imms table values). The core intent of the value itself is to satisfy the law, which, by being populated already implies 'VIS given and discussed with the patient'. Knowing this, all that is really needed is a translation that, when populated, produces chart note text such as 'VIS dated <VIS Date here> given to and discussed with the patient today.' This would cover all aspects of the mandate.
Side note: That your auditors do not understand the intent of the obsterm reflects that they do not understand the EMR itself (an ongoing struggle for all EMR systems). An institutional policy and good design can help clarify those misunderstandings and aid in avoiding needless clicks. Your suggested solution is certainly one approach that works.
Posted : June 14, 2017 8:47 am
