Chief Compliance and Ethics Officer Health Care

Retention and Destruction

  • 1.  Retention and Destruction

    Posted 03-27-2019 09:57 AM
    I am working on a Retention and Disposal policy and was hoping that others in the community could share what they currently have. I am interested in everything under the sun, form and category (e.g. paper, electronic, cloud, emails, financial, medical, contractual, HIPAA related and not, general, bills, communications, files, documents, etc.).

    Cross-checking with others could help keep me from missing items. I understand that state laws come into play but the list of items is still of value. If the regulation source (federal vs state) is noted, that's a bonus.

    I am hoping someone has a simple list, rather than a complex what-if matrix, but whatever you are willing to share is appreciated. I have searched through the forum and picked up a few items but am hoping to get a wider selection and a few more current samples.

    Thank you in advance to those willing to freely share and promote the compliance community.

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    Carl Russell
    Compliance Analyst
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
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    2019 HCCA Compliance Institute


  • 2.  RE: Retention and Destruction

    Posted 03-27-2019 10:02 AM
    Here are 3 resources I often offer...see attached...as they have some good info...in my view.

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    ► Study Session Link for CI ◄
    https://www.surveymonkey.com/r/GJSW959
    ►Study Session: April 7th - 8 PM...stay tuned...◄
    --------Frank Ruelas---------
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    2019 HCCA Compliance Institute


  • 3.  RE: Retention and Destruction

    Posted 03-27-2019 10:30 AM
    Thanks Frank. Though I just glanced at them for now, they look great, nice and straight forward.

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    Carl Russell
    Compliance Analyst
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
    ------------------------------

    2019 HCCA Compliance Institute


  • 4.  RE: Retention and Destruction

    Posted 03-27-2019 10:33 AM
    I know one of the attachments is a listing of many business types of documents...but I recall seeing one more that I used once.  Would you like a copy or is what was attached enough.

    ------------------------------
    ► Study Session Link for CI ◄
    https://www.surveymonkey.com/r/GJSW959
    ►Study Session: April 7th - 8 PM...stay tuned...◄
    --------Frank Ruelas---------
    ------------------------------

    2019 HCCA Compliance Institute


  • 5.  RE: Retention and Destruction

    Posted 03-27-2019 10:35 AM
    Sure, I'll take a copy. When I dive into this I want all the ammunition I can get. Thanks.

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    Carl Russell
    Compliance Analyst
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
    ------------------------------

    2019 HCCA Compliance Institute


  • 6.  RE: Retention and Destruction

    Posted 03-27-2019 10:38 AM
    This is where we got most of our information from then tweaked based on any state laws.
    https://www.shrm.org/resourcesandtools/tools-and-samples/policies/pages/cms_017186.aspx

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    Savannah Knuettel CHC
    Compliance Officer
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
    ------------------------------

    2019 HCCA Compliance Institute


  • 7.  RE: Retention and Destruction

    Posted 03-27-2019 11:15 AM
    Savannah,
    Thank you for the link. It requires a paid login to get access. So unfortunately I won't be able to use it at this time. Perhaps we'll look more into it in the future. Thanks anyway.

    ------------------------------
    Carl Russell
    Compliance Analyst
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
    ------------------------------

    2019 HCCA Compliance Institute


  • 8.  RE: Retention and Destruction

    Posted 03-27-2019 11:21 AM
      |   view attached
    Attached is our policy which was developed based off the link I posted. :)

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    Savannah Knuettel CHC
    Compliance Officer
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
    ------------------------------

    Attachment(s)

    2019 HCCA Compliance Institute


  • 9.  RE: Retention and Destruction

    Posted 03-27-2019 01:57 PM
    Thank you very much Savannah.

    ------------------------------
    Carl Russell
    Compliance Analyst
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
    ------------------------------

    2019 HCCA Compliance Institute


  • 10.  RE: Retention and Destruction

    Posted 03-28-2019 09:51 AM
    Thank you Frank and Savannah for sharing your resources.

    I am also involved in updating our destruction/retention policy and recently posted in the online LTC community about destruction of electronic records, but did not get a reply, so I thought I might put it out here in this thread.  For those with an electronic medical record system, do you delete medical records out of your EMR system at the prescribed destruction time frame?  Does your EMR have a  process for that?  We currently use PointClickCare and they told me they have no record deletion process.  So currently we are holding records in electronic format that exceed our time frame for retention.  I worry about that.....like i don't have enough to worry about -- LOL!

    Thanks in advance for any insight this community can provide on this topic.

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    Gwen Harrison
    Corporate Compliance Officer
    Christ's Home
    Warminster,PA
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    2019 HCCA Compliance Institute


  • 11.  RE: Retention and Destruction

    Posted 03-28-2019 02:00 PM
    Gwen,
    We have discussed retention for electronic medical records also, but at this time we do not have a process. We too exceed the time frame.

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    Savannah Knuettel CHC
    Compliance Officer
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
    ------------------------------

    2019 HCCA Compliance Institute


  • 12.  RE: Retention and Destruction

    Posted 03-29-2019 03:28 PM
    we just went through this process of updating as well
    we maintain the notion that they are disposed of according to policy but you are correct there is no way to archive them off from a "list" of patients
    as a post acute care provider with multiple programs records could be useful lets say someone is getting private duty services and then becomes hospice eligible . The other issue with hospice is family members are part of the unit of care so knowing you have taken care of someone's loved one in the past is almost expected when they are involved with a second or third family member receiving our services.


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    Eugenia Smither CHC
    VP Compliance/Quality Improvement
    Bluegrass Care Navigators
    Lexington,KY
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    2019 HCCA Compliance Institute


  • 13.  RE: Retention and Destruction

    Posted 03-28-2019 09:32 AM
    I am updating my policy, so this was timely. We are a quasi-governmental hospital--community hospital, teaching hospital; therefore, we follow the TX state Library archive schedules. They are the local schedule GR, HR, and PS, websites below. We adjust the time based on requirements for CLIA, HIPAA, or legal cases, etc., if the time in the schedule is shorter than what is required elsewhere.

    Local Schedule GR

    https://www.tsl.texas.gov/slrm/recordspubs/gr.html

     Local Schedule HR

    http://www.tsl.state.tx.us/slrm/recordspubs/hr.html#3.3

     Local Schedule PS

    https://www.tsl.texas.gov/slrm/recordspubs/ps.html



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    Deborah Dabbs CHC,CHPC,CHRC,MBA,Other
    Compliance Manager
    Univ Medical Center
    Lubbock,TX
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    2019 HCCA Compliance Institute


  • 14.  RE: Retention and Destruction

    Posted 03-28-2019 12:03 PM
    Thank you Deborah.

    ------------------------------
    Carl Russell
    Compliance Analyst
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
    ------------------------------

    2019 HCCA Compliance Institute