This manuscript documents the development of an implicit review method for assessing the quality of in-hospital nursing care for congestive heart failure patients. The steps described include the adoption of a conceptual framework for nursing quality, nursing expert review, development of the Congestive Heart Failure Implicit Review Form and Instruction Manual (reproduced in Appendices B and C), and the selection and training of reviewers. Key principles of implicit review are summarized, and the medical record sample is described. The Congestive Heart Failure Review Form consists of 19 questions. To structure the quality review, these questions guide the reviewer through specific aspects of nursing process: 1) assessment, 2) identification of problems, and 3) problem management, including development of nursing goals, interventions, and evaluation. The form then asks reviewers to rate the overall quality of care. It also collects information on patient acuity, expected outcomes, adverse events, and charting methods.