How do I know if my adverse action narrative description is factually sufficient to meet the statutory reporting requirements?
To meet the statutory reporting requirements, the description must have enough detailed information so that a knowledgeable reviewer can determine clearly the circumstances of the action or surrender. In other words, you must provide a clear understanding of what the subject/practitioner is alleged to have done and the nature and reasons for the action taken. Merely repeating the adverse action or basis for action code is not factually sufficient. Do not reference personal identifying information about patients, other health care practitioners, plaintiffs, and/or witnesses (e.g., names). The narrative may be up to 4,000 characters in length. Examples of factually sufficient narratives are available on the Fact Sheet on Fact Sheet on Submitting A Factually Sufficient Narrative Description. (Also in Narrative Descriptions FAQ.
