What to do with Medical and Other Records when a Hospital or Practice Closes due to COVID-19 or other Business Reasons

Summary

If your practice or hospital is among those that may soon close its doors, it’s time to develop a record retention strategy. Here are tips and considerations for securing electronic medical and other records records long-term. 

Senior Male Caucasian Doctor With Stethoscope In Medical Scrubs

The financial impact of COVID-19 on U.S. hospitals and health systems is in excess of the $202 billion recorded from March 1 to June 30, 2020.  For ambulatory practices, the initial decline of 60% less visits reported in early April 2020 has rebounded, but still is one-third lower than pre-pandemic levels. And, certain specialties have been hit even harder. Visits to ophthalmologists are down 79%, dermatology 73%, urology 63% and cardiology 61%. While telehealth has offset some losses, there still are big gaps in the revenue for many areas of healthcare.

For some smaller hospitals and physicians offices, the pandemic accelerated the financial challenges that have been forcing consolidation for the past decade. In a recent survey of 2,774 doctors, 42 percent had to lay off or furlough staff and 10 percent predict they will close because of financial shortfalls. In an unusual twist, 236 of the doctors surveyed have actually received patient donations from online fundraisers.

Bottom line: COVID-19 and the shifting delivery of medical care will continue to affect how many of the nation’s 6,146 hospitals will remain open. And, with more doctors now employed by health systems than in private practice, there are increased pressures to consolidate or face going out of business.

All Providers Should Develop a Legacy Data Management Strategy

If your practice or hospital is among those that may soon close its doors, it’s time to develop a record retention strategy. This entails putting a plan into action for securing electronic records long-term. While this certainly includes protected health information for patients as dictated by the organization’s medical record retention policy, it also includes other business and employee information like general ledger, accounting and HR record retention.

Tips for securing medical and other records during a practice or hospital closure

Here’s a quick checklist to get started:

  • Obtain Legal Advice – Work with an attorney to make sure legal bases are covered in terms of notifying relevant parties in a timely manner and complying with medical record retention and destruction laws.
  • Review your state law – Each state has different requirements for medical record retention. Confirm you know what is expected so your organization is in compliance. Get more information on state medical record retention here.
  • Review Medical Record Retention Options – If you haven’t already invested in transferring legacy medical records into an archive, now might be the time to investigate your options. Records can be stored electronically in a vendor-managed cloud with information released for a fee using an 800-number and/or online request for payers, patients, employers, lawyers, auditors, etc. Contact Harmony Healthcare IT for more information about health data archival.
  • Create a Legacy Data Management Plan – The data experts at Harmony Healthcare IT have put together a process that has helped hundreds of ambulatory and acute care organizations evaluate their legacy clinical, financial, HR and ERP system portfolio to create a Legacy Data Management Strategy that works. The process guides providers through a system inventory, financial forecast and system prioritization for decommissioning legacy systems enterprise-wide.
  • Consult an Authority before Closing the Practice Doors — The American Academy of Family Physicians (AAFP) has a complete checklist for closing a medical practice. In terms of EMR, they recommend that you:
    • Arrange for safe storage for both paper and electronic medical records.
    • Notify your state medical board of the storage location.
    • Determine the correct amount of time your medical records should be stored, as defined by your state law.
    • Make sure the storage facility has experience handling confidential patient information and HIPAA agreements.
    • Establish a mailing address or PO Box for medical record requests after closing.
    • Arrange for storage of personnel and other records according to your state law.
    • Organize the disposal or proper storage of clinic documents such as financial records, patient education materials, brochures, etc.

For the complete checklist, click here.

Hospital

Editor’s Note: This blog was updated from a previous version that was published in June 2018.

Aug 26 2020

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