What to do with Medical and Other Records when a Hospital or Practice Closes


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

Senior Male Caucasian Doctor With Stethoscope In Medical Scrubs

The financial impact of COVID-19 on U.S. hospitals and health systems continues with industry analysts reporting that hospitals will be in a “tough spot for the foreseeable future.”

For some smaller hospitals and physicians offices, the pandemic accelerated the financial challenges that have been forcing consolidation for the past decade. In a 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 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 if one is not already in place. 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.

Every Legacy Data Strategy Should Include a Provision for Future Release of Information Requests

An important part of every legacy data management plan is to ensure that the records will be secure and accessible for future release of information requests. Possible future requests may be needed for patient care, litigation, insurance audits, workers’ compensation, validation of employment and other reasons. Our Records Release service provides customized options, with a general plan to:

  • Extract data from legacy systems (clinical, financial and administrative)
  • Store discrete data in an active archive with release of information workflows
  • Provide a web landing page for requestors to learn about the record release process
  • Offer a secure information provision to requestors such as patients, employers and payers
  • Deliver a detailed audit trail of the record release process with date and time stamping

Our team is equipped to support organizations at any stage of a possible closure or impending acquisition.

Ready to Begin? Tips for securing medical and other records during a practice or hospital closure or acquisition

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.
  • Choose a trusted agent to manage future release of information requests – Harmony Healthcare IT is in a unique position to offer this service with its broad experience with more than 550 clinical and financial software brands. As a HITRUST CSF®-certified organization, we follow some of the highest security protocols in the industry to safeguard patient and employee records with personally identifiable and protected health information.
  • 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.


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

Aug 26 2020

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