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Procedure Note Template: Universal Protocol Time-Out, LOINC 28570-0, and Modifier 25

Clinical guide to the bedside and outpatient procedure note template (LOINC 28570-0), Joint Commission Universal Protocol Time-Out, and CPT Modifier 25.

Written and maintained by CASRAI Editorial Board

Last updated

Non-clinical documentation notice: This reference describes electronic health record (EHR) charting schemas, Joint Commission Universal Protocol accreditation audit fields, HL7 C-CDA interoperability mappings, and CPT Modifier 25 coding governance for health informatics and patient-safety research. It does not provide clinical instructions on how to perform invasive medical procedures.

A standardized procedure note template captures the mandatory medical-record documentation for non-operating-room bedside, emergency department, interventional suite, and outpatient clinic procedures. In hospital patient-safety programs and clinical research registries, a structured procedure note serves three distinct governance functions: verifying compliance with The Joint Commission Universal Protocol (`UP.01.01.01–UP.01.03.01`), populating interoperable HL7 C-CDA LOINC 28570-0 fields, and establishing clear documentation boundaries between minor procedural work and separately identifiable Evaluation and Management (E/M) services across clinical documentation workflows.

What are the required elements of a bedside or outpatient Procedure Note (indication, informed consent, Universal Protocol Time-Out, technique, findings, EBL, complications)?

Whether recorded in an inpatient intensive care unit, an ambulatory clinic, or an interventional radiology department, hospital medical record bylaws and clinical documentation improvement (CDI) audit checklists require every procedure note template to capture ten core charting fields:

  1. Date, Time, and Location of Procedure: Exact timestamp when the procedure started and ended, plus clinical unit or clinic room.
  2. Performing Practitioner, Assistants, and Supervision Attestation: Name and credentials of the primary operator, assisting clinicians, and—when a resident or fellow performs the procedure—an explicit teaching physician presence attestation (such as “I was present for the entire procedure” or “I was physically present during all critical and key portions of the procedure and immediately available throughout” per CMS teaching physician rules).
  3. Pre-Procedure and Post-Procedure Diagnosis & Clinical Indication: The specific clinical condition and diagnostic or therapeutic indication (`ICD-10-CM`) justifying the procedure.
  4. Informed Consent Documentation: Verification that procedural risks, benefits, and alternatives were explained to the patient or legally authorized healthcare proxy and that a signed written informed consent form is in the chart (or explicit documentation of an emergent life/limb-saving exception).
  5. Universal Protocol Verification & Time-Out (`UP.01.01.01–UP.01.03.01`): Confirmation of patient identity (two identifiers), procedure to be performed, anatomical site/laterality marking, and completion of the pre-procedure pause immediately prior to starting.
  6. Anesthesia / Analgesia / Sedation Metadata: Type of local anesthetic, regional block, or moderate procedural sedation documented in the medical record (cross-referenced to the nursing clinical documentation sedation monitoring flowsheet).
  7. Summary of Procedure / Device / Imaging Guidance Recorded: High-level record of the anatomical site accessed, imaging guidance modality utilized (with permanent image storage verification in PACS when billing ultrasound or fluoroscopic guidance), and any catheter, tube, or device lot/serial identifier placed.
  8. Findings and Specimens Collected: Gross appearance of fluid or tissue obtained and exact laboratory/pathology tests ordered on numbered specimen containers (or “No specimens removed”).
  9. Estimated Blood Loss (EBL) and Immediate Complications: Quantified EBL (e.g., < 5 mL) and presence or absence of immediate procedural complications, plus post-procedure confirmation studies (such as post-procedure chest radiograph verification).
  10. Patient Tolerance and Post-Procedure Plan: Vital-sign stability upon completion and post-procedure monitoring orders.

How does The Joint Commission Universal Protocol (`UP.01.01.01`–`UP.01.03.01`) require pre-procedure verification, site marking, and a documented Time-Out?

A critical accreditation audit reality is that The Joint Commission Universal Protocol for Preventing Wrong Site, Wrong Procedure, and Wrong Person Surgery (read 2026-11-10 at https://www.jointcommission.org/standards/standard-faqs/hospital-and-hospital-clinics/universal-protocol/000001507/) applies not only to main operating rooms, but to all inpatient bedside and outpatient clinic invasive procedures that expose patients to more than minimal risk. Every compliant EHR procedure note template embeds discrete verification fields corresponding to the three Universal Protocol standards:

Universal Protocol Standard Mandatory Patient-Safety Requirement Required EHR Procedure Note Documentation
UP.01.01.01 — Pre-Procedure Verification Process Verify correct patient, correct procedure, and correct site using active communication and the patient’s involvement whenever possible; match required documents (signed consent, H&P/assessment, diagnostic imaging, and implants/equipment) before starting. Discrete attestation confirming patient identity verified via 2 identifiers (e.g., name and date of birth/MRN), signed informed consent verified, and relevant imaging/labs reviewed.
UP.01.02.01 — Mark the Procedure Site For any procedure involving incision or percutaneous puncture where laterality (left/right), multiple structures (fingers/toes), or multiple levels (spine) are present, the site must be marked unambiguously by a licensed practitioner who is privileged/permitted to perform the procedure and will be present during the procedure. Documentation of anatomical site and laterality (`Right` vs. `Left`), confirmation that the proceduralist marked the site with an unambiguous site mark visible after skin prep/draping (or documented clinical exemption such as midline single-organ catheterization).
UP.01.03.01 — Perform a Time-Out Conduct a final standardized Time-Out immediately before starting the invasive procedure. All participating team members pause other activities and agree on: (1) correct patient identity, (2) correct site, and (3) correct procedure to be performed. Exact Time-Out timestamp (`HH:MM`) and explicit confirmation that the entire procedural team paused and agreed on patient identity, procedure, and site/laterality prior to starting.

What is a complete worked template for a bedside Procedure Note (LOINC 28570-0) that supports CPT procedure + Modifier 25 E/M separation?

In the HL7 Consolidated Clinical Document Architecture (C-CDA R2.1), non-operating-room procedures are encoded using the Procedure Note Document Template (OID 2.16.840.1.113883.10.20.22.1.6), identified by LOINC 28570-0 (Procedure note, read 2026-11-10 at https://loinc.org/28570-0/).

Under the CMS Medicare Claims Processing Manual (Chapter 12, § 40.2.A.8, Global Surgery Booklet `MLN907166`, read 2026-11-10 at https://www.cms.gov/files/document/mln907166-global-surgery-booklet.pdf), all minor surgical and bedside procedures (those with a 0-day or 10-day global period) include the routine pre-procedure evaluation required to perform the procedure and immediate post-procedure care. A physician may append CPT Modifier 25 to an Evaluation and Management (E/M) code on the same calendar date as a minor procedure only when the E/M service is a “significant, separately identifiable E/M service by the same physician or other qualified health care professional on the same day of the procedure.”

While CMS policy states that the E/M and procedure notes do not strictly have to be stored in two separate electronic file objects, best-practice health informatics governance and clinical documentation software architectures create a standalone `LOINC 28570-0` Procedure Note (or a visually segregated block with its own header) so that auditors can verify that the cognitive E/M work (documented in the progress note or SOAP note assessment) went above and beyond the routine pre-/post-procedure work captured in the procedure note.

Worked EHR Charting Template: Standalone Procedure Note (`LOINC 28570-0`)

  • 1. Procedure Administrative Header:
    • Document Type: Standalone Procedure Note (`LOINC 28570-0`)
    • Date of Service: YYYY-MM-DD | Procedure Start Time: 14:15 | Procedure End Time: 14:35
    • Location: Medical ICU Room 604 | CPT Code(s): [Procedure CPT Code + Ultrasound Guidance CPT Code if applicable]
    • Primary Operator: [Resident Name, MD] | Supervising Attending: [Attending Name, MD]
    • Teaching Physician Attestation: “I, [Attending Name, MD], was physically present at the bedside for the entire procedure and directly supervised all aspects of the procedure.”
  • 2. Indications & Diagnoses (`LOINC 59768-2` / `59769-0`):
    • Pre-Procedure Diagnosis: Large symptomatic right pleural effusion with acute hypoxic respiratory failure (`ICD-10-CM J90`, `J96.01`).
    • Post-Procedure Diagnosis: Same; diagnostic and therapeutic pleural fluid drainage completed.
    • Clinical Indication: New large right-sided pleural effusion on chest radiograph requiring diagnostic fluid analysis to evaluate for parapneumonic effusion/empyema and therapeutic volume removal to improve oxygenation.
  • 3. Informed Consent & Universal Protocol Time-Out (`UP.01.01.01–UP.01.03.01`):
    • Informed Consent: Risks (pneumothorax, hemothorax, infection, visceral organ injury, re-expansion pulmonary edema), benefits, and alternatives were explained to the patient, who demonstrated understanding and signed the written informed consent form placed in the medical record.
    • Universal Protocol Pre-Procedure Verification (`UP.01.01.01`) & Site Marking (`UP.01.02.01`): Patient identity verified using two identifiers (full name and date of birth/medical record number); pre-procedure platelet count (`210 x 10³/µL`), INR (`1.08`), and chest imaging reviewed; Right posterior hemithorax marked unambiguously by the performing physician prior to draping.
    • Time-Out (`UP.01.03.01`): Standardized Time-Out conducted at 14:14 with the attending physician, resident, and bedside ICU nurse (`[Nurse Name, RN]`). All team members paused and verbally confirmed correct patient identity, correct procedure, and correct site/laterality (`Right chest`).
  • 4. Imaging Guidance & Sterile Precautions (`LOINC 29554-3`):
    • Real-time point-of-care ultrasound examined the right posterior chest wall, confirming a large anechoic pleural fluid pocket above the right hemidiaphragm without interposing lung parenchyma. Permanent ultrasound still image documenting the pleural effusion and safe acoustic window was saved to the hospital PACS archive. Maximal sterile barrier precautions (cap, mask, sterile gown, sterile gloves, full-body sterile drape, and chlorhexidine skin antisepsis) and local analgesia (`1% lidocaine`) were documented in the nursing flowsheet.
  • 5. Procedure Findings (`59776-5`) & Specimens Collected (`59773-2`):
    • Findings: 1,150 mL of serous yellow pleural fluid removed without cough or chest discomfort; normal lung sliding visualized on post-procedure bedside ultrasound.
    • Specimens Sent to Laboratory: Pleural fluid (`Right pleural fluid`) labeled at bedside and sent for cell count with differential, total protein, LDH, glucose, pH, Gram stain, aerobic/anaerobic bacterial cultures, and cytology.
  • 6. Estimated Blood Loss (`59770-8`) & Complications (`55109-3`):
    • Estimated Blood Loss (EBL): < 5 mL.
    • Complications: None. Patient tolerated the procedure well; post-procedure SpO2 improved from 91% on 4 L/min nasal cannula to 96% on 2 L/min nasal cannula.
  • 7. Post-Procedure Plan (`LOINC 18776-5`):
    • Post-procedure upright portable chest radiograph ordered and reviewed: marked decrease in right pleural effusion with full right lung re-expansion and no pneumothorax. Continue routine ICU vital-sign monitoring and follow pending pleural fluid laboratory studies.

Frequently Asked Questions

What are the required elements of a bedside or outpatient Procedure Note (indication, informed consent, Universal Protocol Time-Out, technique, findings, EBL, complications)?

A compliant procedure note template documents procedure date/time and location, performing and supervising clinicians (with teaching physician presence attestation), pre-/post-procedure diagnoses and indication, informed consent verification, Joint Commission Universal Protocol site marking and Time-Out timestamp, analgesia/sedation, imaging guidance archive confirmation, findings and labeled specimens, estimated blood loss (EBL), complications, and post-procedure stability/imaging results.

How does The Joint Commission Universal Protocol (`UP.01.01.01`–`UP.01.03.01`) require pre-procedure verification, site marking, and a documented Time-Out?

The Joint Commission Universal Protocol requires three steps for all invasive surgical and bedside procedures: (1) Pre-procedure verification of patient identity, consent, and imaging (`UP.01.01.01`), (2) unambiguous site marking by the performing practitioner for procedures involving laterality, multiple structures, or multiple levels (`UP.01.02.01`), and (3) a documented Time-Out immediately before starting (`UP.01.03.01`).

What is a complete worked template for a bedside Procedure Note (LOINC 28570-0) that supports CPT procedure + Modifier 25 E/M separation?

A standalone HL7 C-CDA LOINC 28570-0 Procedure Note isolates all procedure-specific fields (`59768-2` indications, `UP.01.03.01` Time-Out, `29554-3` description/imaging guidance, `59773-2` specimens, `59770-8` EBL, and `55109-3` complications) from the daily cognitive E/M progress note, allowing auditors to verify when a separately identifiable E/M service (`CPT Modifier 25`) occurred on the same calendar day.

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