Is updating the problem list a physician-only task?

This resource is part of the AMA's Debunking Regulatory Myths series, supporting AMA's practice transformation efforts to provide physicians and their care teams with resources to reduce guesswork and administrative burdens.

There is no federal regulation prohibiting licensed and unlicensed care team members from assisting physicians in maintaining an accurate, up-to-date problem list. 

The problem list in a patient’s chart should include current, active diagnoses in addition to past diagnoses relevant to the patient’s ongoing care.¹ The maintenance of an accurate problem list is essential to making informed decisions about a patient’s treatment, identifying risks and care gaps, and ensuring continuity of care. Redundant or outdated information contributes to inaccuracy and cognitive load. 

Problem lists facilitate clinical decision support such as the best choice of medication given a patient’s particular set of health conditions; allow clinicians to easily access patients’ ongoing health issues without having to navigate through past notes; and provide clinical and quality improvement researchers with information to study specific diagnoses, health conditions, and interventions to support better care.^2,3,4  Problem lists are used for determining appropriate health maintenance topics and which questionnaires patients receive.^2,4  The problem list is a common location in the EHR to keep current problem-specific diagnostic and treatment plans. Well-curated problem lists also help ensure that the most specific diagnosis codes are used for optimal Hierarchical Condition Category coding. Inadvertently adding or removing a diagnosis from the problem list can have unintended consequences due to the ways EHR systems depend on it.

As the number and variety of clinicians included in the care of any single patient continues to grow, the responsibility for curating the problem list should be shared by all physicians and care team members involved. Maintaining an accurate and up-to-date problem list within the EHR as a shared responsibility across and within care teams can reduce clerical work for physicians, allow more time for patient-facing tasks, and improve problem list completeness to support better patient care.^3,5 

A report funded by the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology provides guidance regarding how clinical assistants (e.g., medical assistants and licensed practical nurses) can help update information in the problem list based on the decision-making of the physician or other licensed independent practitioner caring for the patient.³ Physicians and care team members should adhere to applicable state scope of practice regulations.

Shared responsibility among physicians, non-physician practitioners, and clinical assistants to maintain an up-to-date, accurate problem list can help enhance care coordination and improve patient care while reducing clerical burden for physicians.

• AAFP “Taming the Problem List” article. Accessed January 2025.
• AMIA “Problem Management Module” article. Accessed January 2025.

1. Centers for Medicare & Medicaid Services (CMS). Eligible Hospital and Critical Access Hospital Meaningful Use Core Measures: Measure 3 of 11 Stage 1. Published online May 2014. Accessed January 8, 2025. https://www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/downloads/3_maintain_problem_list.pdf
2. Hodge CM, Kuttler KG, Bowes WA, Narus SP. Problem Management Module: An Innovative System to Improve Problem List Workflow. AMIA Annual Symposium Proceedings. 2014;2014:661-670. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4419930/
3. Hummel J, Evans P. Standardizing the Problem List in the Ambulatory Electronic Health Record to Improve Patient Care. AHRQ; 2012. Accessed January 8, 2025. https://www.ahrq.gov/sites/default/files/wysiwyg/evidencenow/tools-and-materials/ehr-problem-list.pdf
4. Wright A, Feblowitz J, Maloney FL, Henkin S, Bates DW. Use of an Electronic Problem List by Primary Care Providers and Specialists. Journal of General Internal Medicine. 2012;27(8):968-973. https://doi.org/10.1007/s11606-012-2033-5
5. Wright A, McCoy AB, Hickman TTT, et al. Problem List Completeness in Electronic Health Records: A Multi-Site Study and Assessment of Success Factors. International Journal of Medical Informatics. 2015;84(10):784-790. https://pubmed.ncbi.nlm.nih.gov/26228650/

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Disclaimer: The AMA's Debunking Regulatory Myths (DRM) series is intended to convey general information only, based on guidance issued by applicable regulatory agencies, and not to provide legal advice or opinions. The contents within DRM should not be construed as, and should not be relied upon for, legal advice in any particular circumstance or fact situation. An attorney should be contacted for advice on specific legal issues. Additionally, all applicable laws and accreditation standards should be considered when applying information to your own practice.