Employee Record Retention for America’s Largest Employer: Healthcare


Healthcare employs more people in the United States than any other industry. Like patient information, employee records must meet strict retention requirements, and often human resource management (HRM) and enterprise resource planning (ERP) systems are replaced before that timeframe is met. When a system storing critical person information is displaced, active archiving comes to the rescue, securely storing records for the largest employer in our nation – the healthcare industry.


As an industry, Healthcare must retain employee records for the more than 22 million of its healthcare workers at over 784,000 healthcare businesses in the United States. And, human resource (HR) record retention guidelines in healthcare go deep and wide.

Healthcare delivery organizations are required to manage and retain several types of records for varying timeframes (sometimes 30+ years), including:

  • Personnel Records
  • Records for Employment Tests and Employment Opportunities
  • Online Application Records
  • Apprentice Programs
  • Payroll Records
  • Income Tax Withholding
  • Time Cards and Schedules
  • Wage Differential
  • General Ledger/Accounting
  • General Business Records
  • Minor Employees
  • Federal Contractors
  • EEO-1 Reports
  • Agreements, Contracts, Benefits
  • Family and Medical Leave Records
  • Affirmative Action Plans
  • OSHA Records
  • Drug Testing Records

Plus, the HR team must stay abreast of new issues and the employee recordkeeping that is required. A few recent examples:

  • COVID-19 vaccine records – While health systems are grappling with the legal issues of requiring employees to obtain a COVID-19 vaccine, employees’ vaccine records are being tracked at more than one third of U.S. businesses.
  • New Rules for COBRAThe American Rescue Plan Act (ARPA) signed into law in March 2021, mandates that employers provide 100 percent of COBRA premium subsidies to eligible employees. Recordkeeping compliance for this additional program requires auditing workforce records to determine eligibility, coordinating the program and also retaining the business records of all COBRA subsidies and attestations obtained from AEIs.

HRM and ERP systems play a large role in managing the business side of healthcare. When it comes time to replace these systems for various reasons, there are many decisions to be made about where, how and for what duration the employee and business data they contained will be retained.

While HIPAA is a driving factor for employee data retention at healthcare facilities, there are a few other federal employee data retention requirements that apply to all organizations:

  • The Equal Employment Opportunity Commission (EEOC) Regulations require employers to retain personnel or employment records for one year.
  • The Fair Labor Standards Act (FLSA) states that employers must keep payroll records for a minimum of three years and any records that might be needed to explain wage discrepancies for employees of the opposite sex for a minimum of two years.

Other federal laws regarding the retention of employee records and HR information often depend on the number of employees at an organization. Those record retention requirements might range anywhere from one to 30 years. The Society of Human Resource Management has a good consolidation of guidelines from those requirements.

According the United States Department of Labor, The Occupational Safety and Health Administration (OSHA) requires “the retention of occupational medical records for 30 years after termination of a worker for the purpose of providing access to the records for employees and their representatives after a worker has left employment. Both employee medical and exposure records must be retained.”

How to Store Employee and other HR Records Long-term

When your employee record retention policy requires data storage for the long haul (i.e., up to 30 years or beyond) and, especially if the systems that store your employee data have been replaced by a newer system, you may need to seek an archive vendor and solution.  When it comes to decommissioning legacy human resources software that stores employee and HR data, a legacy data management strategy is an important consideration. Whether you are retiring one, four or 14 legacy systems at once, a legacy data management strategy from an expert archiving vendor helps guide decisions around system retirement prioritization.  It also provides a common data retention methodology and framework.

There are numerous benefits to employing an active archive solution like HealthData Archiver® in your record retention strategy. The primary benefits of HealthData Archiver® for the HR team includes data accessibility and security for numerous types of employee and other HR data like time and attendance or payroll. A few notable features include audit logs, role-based security, reporting and record purging.

Harmony Healthcare IT also handles the migration of legacy employee records to the go-forward HRM system.

For more information about managing legacy employee data at healthcare delivery organizations, contact us.

Note: This blog is an update from a previous blog published on Nov. 15, 2017.

Jun 23 2021

Ready to learn more?

Contact us today to learn more about our healthcare data management solutions.

First Name *
Last Name *
Email *

Healthcare IT tips, guides, news & more delivered to your inbox

Sign me up