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Scenario
You are the manager of the Medical Records Department at
Rasmussen Hospital and were recently reviewing the
organization’s current Document Retention Policy (linked
below).
Download:
Document Retention Policy
The current policy addresses the retention and destruction of
medical records in the normal course of business. However, you
noticed that it does not include instructions for how employees
should respond to a litigation hold. Ultimately, the policy will
need to be updated, but in the meantime, you decide to create a
short training document to educate the staff.
Instructions
In a two (2) page training document, written using proper
spelling and grammar, as well as professional tone and
vocabulary, address the items below.
Differentiate between the three (3) legal terms below by
explaining each and comparing them to one another.
Litigation Hold
Notice of Preservation
Order for Preservation
Provide instructions explaining how the staff should handle a
litigation hold.
Your training document should be well organized and include
appropriate headings/subheadings. Be sure to incorporate and
cite at least one (1) credible, scholarly resource using APA
format.
Rasmussen Hospital
: Medical Record Management
Policy # Policy Title: Effective Date: Revision Date: Forms #:
Policy
6.01
Document Retention 10/23/2003 05/01/2019
None
It is the policy of Rasmussen Hospital to apply appropriate and
cost effective management techniques to maintain complete and
accurate records. Records are retained in accordance with all
applicable laws and regulations and this policy. The purpose of
this policy is to establish the policy and procedures for the
creation, use, maintenance, retention, preservation and disposal
of Rasmussen Hospital's records in order to:
1) Meet current Company needs in record storage (or other
electronic media) and retrieval systems
2) Ensure compliance with the various governmental regulations
concerning document retention
3) Ensure uniformity in records retention throughout the
Company
1) Records shall not be destroyed before the prescribed
retention period has expired. Records shall not be retained for
longer than the prescribed period without first contacting the
applicable department head.
2) Retention periods are specified for original documents only,
unless otherwise specified. Duplicates of original documents
should generally be properly destroyed after use, unless the
retention of such duplicate original document is necessary to
support current operations. If duplicates are retained, they
should be properly destroyed after they have served their
purpose.
3) Records containing confidential and proprietary information
will be securely maintained, controlled and protected to prevent
unauthorized access.
4) All records generated and received by Rasmussen
Hospital are the property of Rasmussen Hospital. No Rasmussen
Hospital employee, by virtue of his or her position, has any
personal or property right to such records even though he or she
may have developed or compiled them.
5) Any unauthorized destruction, removal or use of such records
is strictly prohibited.
6) No person shall falsify or inappropriately alter information in
any record or document. Information pertaining to unauthorized
destruction, removal or use of Rasmussen Hospital records or
regarding falsifying or inappropriately altering information in a
record or document must be reported to management.
General Information
Page 1 of 5
Rasmussen Hospital
: Medical Record Management Policy 6.01 Document Retention
Procedure
The following special considerations apply to the application
of Rasmussen Hospital Document Retention policy and
procedure.
1) Records Relevant to more than one category When records
may be subject to more than one category and corresponding
retention period, employees must use the longest retention
period.
2) Copies Only one copy of each record must be retained to
comply with record retention requirements.
3) Exceptions Any exceptions to Rasmussen
Hospital's Document Retention policy and procedure may be
made only after consultation with the Compliance or Legal
Department.
4) Assistance Employees should never guess as to the retention
period applicable to a particular record or category of records.
Any questions in this regard should be directed to the
Supervisor/Manager who shall consult with the Compliance or
Legal Department as appropriate.
Last Reviewed: 05/01/2019
Page 2 of 5
Rasmussen Hospital
: Medical Record Management Policy 6.01 Document Retention
Rasmussen Hospital
Document Retention Resource
Record Type
Medical Records of Patients
Medical Records of Patients - Minors
Retention Period
10 years from date of discharge
10 years from the date the minor turns 18 years of age
Current +7 Years
Current Year + 2 years Current Year + 1 year
Comments
Follow state regulations regarding Medical Record retention
when stricter
Follow state regulations regarding Medical Record retention
when stricter
From policies 5.25, 5.26 and 5.30
NA
Per HIPAA Policy H-21A procedure 5
Any items scanned and attached to electronic medical record
Until verification is completed by the patient service specialist
to ensure all documents are scanned, attached to the electronic
medical record and legible.
Appointment / Schedule Book
Current Year + 2 years
Patient schedules that are maintained or modified on paper must
be retained as noted in“retention period”. Electronic schedules
(i.e., TherapySource) that can be recalled from a computerized
system are not required to be retained in a paper format.
Informed Consent General release Forms; Program
Agreements/Release Waivers
Patient Sign-In Sheets Fax Cover Sheets
Daily Close Reconciliation Packet
Co-pay pack (Co-pay Checklist /
Daily Receivables log, TS Copay Collections Report, InstaMed
Deposits Report, signed credit card receipts, scanned money
orders)
TS End of Day Reconciliation Report
TS Completed Notes Report
Accepted Visits / Rejected Visits
Report
RT Billing Coding Edit Report
RT Billing Reconciliation Report
Daily Charge Reconciliation
Report
Batch Information Report
RT Charges Posting
Reconciliation Report
Most current 15 months unless otherwise noted below
CBOs will retain for co-pay pack for 10 years with the
exception of original credit card receipts.
Manual Charge Tickets
Until verification is completed by the patient service
specialistto ensure all documents are
Page 3 of 5
Rasmussen Hospital
: Medical Record Management Policy 6.01 Document Retention
Rasmussen Hospital
Document Retention Resource
Record Type
Organizational Charts
Invoices
Signed staff time cards
Customer Complaint Forms Net Promoter Surveys
Clinical Operations Policy and Procedure Manual
Center Handbook Documents
Retention Period
scanned, attached to the electronic medical record and legible.
Until superseded by new organizational chart
Current + 1 year Current + 7 years
Current year + 6 years Most recent 4 quarters Current policies
Current + 1 year unless otherwise noted below
Term of Contract + 6 years
Term of employment + 5 years
Current + 7 years
Term of employment + 2 years
Term of employment + 2 years
Comments
NA
NA NA
NA NA NA
Management reports (Examples: Income statements, KPI
reports, referral tracking reports)
While useful in the center
Any reports generated from the RMT or Oracle system do not
need to be retained in hard copy.
Administrative Logs (staff schedules, day-to-day management
of office personnel / functions, petty cash requests)
Current + 3 years
NA
Clinical Quality Assurance Audits
For audits completed by hand or Excel spreadsheets, maintain
current year plus previous year.
Audits entered into the SM QA database, NA
NA
Equipment Calibration
Safety Procedures pertaining to
security of patients and/or
employees
Evacuation drill reports
Safety Inspections of building or
equipment
Meeting Minutes
Current year + 3 years.
Includes all records documenting the inspection of facilities for
potential safety hazards
Contracts – Medical Director, Contract Employees and Lease
Agreements
Personnel Files of Employees and other employee records
(unless noted below)
Employee Medical Records
Performance Appraisals / Compensation Adjustments /
Awards and recognition
Company sponsored education
Keep the previous year’s records in a separate folder to
decrease size of the Center Handbook.
NA NA
NA NA
NA
Page 4 of 5
Rasmussen Hospital
: Medical Record Management Policy 6.01 Document
Retention Select Medical Outpatient Division Document
Retention Resource
Record Type
Job related accidents and injuries
Employee Exposure Incidences or documents recording incident
Retention Period
Current Year + 5 years NA 30 Years NA
Permanent NA Permanent NA
Comments
Incident Reports
Record Destruction – records supporting the documentation of
destruction of medical records
Destruction of Records:
a) Medical records shall be shredded or after they have been
retained the greater of the following: i. Company policy as
outlined in policy 6.01 (Document Retention),
ii. State law if more stringent, or
iii. Unique contractual requirements (if applicable)
b) Where required by law, notice of record destruction will be
reported to the appropriate agency in accordance with stated
statutes, rules and regulations.
c) The Regional Director or Market Manager shall be
responsible for ensuring there is a mechanism to destroy the old
records and that destruction is completed properly.
d) During the course of normal daily activities, parts of the
patient’s medical record may be copied for business purposes.
These copies shall be destroyed by shredding once their purpose
is completed.
Page 5 of 5

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ScenarioYou are the manager of the Medical Records Department at.docx

  • 1. Scenario You are the manager of the Medical Records Department at Rasmussen Hospital and were recently reviewing the organization’s current Document Retention Policy (linked below). Download: Document Retention Policy The current policy addresses the retention and destruction of medical records in the normal course of business. However, you noticed that it does not include instructions for how employees should respond to a litigation hold. Ultimately, the policy will need to be updated, but in the meantime, you decide to create a short training document to educate the staff. Instructions In a two (2) page training document, written using proper spelling and grammar, as well as professional tone and vocabulary, address the items below. Differentiate between the three (3) legal terms below by explaining each and comparing them to one another. Litigation Hold Notice of Preservation
  • 2. Order for Preservation Provide instructions explaining how the staff should handle a litigation hold. Your training document should be well organized and include appropriate headings/subheadings. Be sure to incorporate and cite at least one (1) credible, scholarly resource using APA format. Rasmussen Hospital : Medical Record Management Policy # Policy Title: Effective Date: Revision Date: Forms #: Policy 6.01 Document Retention 10/23/2003 05/01/2019 None It is the policy of Rasmussen Hospital to apply appropriate and cost effective management techniques to maintain complete and accurate records. Records are retained in accordance with all applicable laws and regulations and this policy. The purpose of this policy is to establish the policy and procedures for the creation, use, maintenance, retention, preservation and disposal of Rasmussen Hospital's records in order to: 1) Meet current Company needs in record storage (or other electronic media) and retrieval systems
  • 3. 2) Ensure compliance with the various governmental regulations concerning document retention 3) Ensure uniformity in records retention throughout the Company 1) Records shall not be destroyed before the prescribed retention period has expired. Records shall not be retained for longer than the prescribed period without first contacting the applicable department head. 2) Retention periods are specified for original documents only, unless otherwise specified. Duplicates of original documents should generally be properly destroyed after use, unless the retention of such duplicate original document is necessary to support current operations. If duplicates are retained, they should be properly destroyed after they have served their purpose. 3) Records containing confidential and proprietary information will be securely maintained, controlled and protected to prevent unauthorized access. 4) All records generated and received by Rasmussen Hospital are the property of Rasmussen Hospital. No Rasmussen Hospital employee, by virtue of his or her position, has any personal or property right to such records even though he or she may have developed or compiled them. 5) Any unauthorized destruction, removal or use of such records is strictly prohibited. 6) No person shall falsify or inappropriately alter information in any record or document. Information pertaining to unauthorized destruction, removal or use of Rasmussen Hospital records or
  • 4. regarding falsifying or inappropriately altering information in a record or document must be reported to management. General Information Page 1 of 5 Rasmussen Hospital : Medical Record Management Policy 6.01 Document Retention Procedure The following special considerations apply to the application of Rasmussen Hospital Document Retention policy and procedure. 1) Records Relevant to more than one category When records may be subject to more than one category and corresponding retention period, employees must use the longest retention period. 2) Copies Only one copy of each record must be retained to comply with record retention requirements. 3) Exceptions Any exceptions to Rasmussen Hospital's Document Retention policy and procedure may be made only after consultation with the Compliance or Legal Department. 4) Assistance Employees should never guess as to the retention period applicable to a particular record or category of records. Any questions in this regard should be directed to the Supervisor/Manager who shall consult with the Compliance or Legal Department as appropriate.
  • 5. Last Reviewed: 05/01/2019 Page 2 of 5 Rasmussen Hospital : Medical Record Management Policy 6.01 Document Retention Rasmussen Hospital Document Retention Resource Record Type Medical Records of Patients Medical Records of Patients - Minors Retention Period 10 years from date of discharge 10 years from the date the minor turns 18 years of age Current +7 Years Current Year + 2 years Current Year + 1 year Comments Follow state regulations regarding Medical Record retention when stricter Follow state regulations regarding Medical Record retention when stricter From policies 5.25, 5.26 and 5.30
  • 6. NA Per HIPAA Policy H-21A procedure 5 Any items scanned and attached to electronic medical record Until verification is completed by the patient service specialist to ensure all documents are scanned, attached to the electronic medical record and legible. Appointment / Schedule Book Current Year + 2 years Patient schedules that are maintained or modified on paper must be retained as noted in“retention period”. Electronic schedules (i.e., TherapySource) that can be recalled from a computerized system are not required to be retained in a paper format. Informed Consent General release Forms; Program Agreements/Release Waivers Patient Sign-In Sheets Fax Cover Sheets Daily Close Reconciliation Packet Co-pay pack (Co-pay Checklist / Daily Receivables log, TS Copay Collections Report, InstaMed Deposits Report, signed credit card receipts, scanned money orders) TS End of Day Reconciliation Report TS Completed Notes Report
  • 7. Accepted Visits / Rejected Visits Report RT Billing Coding Edit Report RT Billing Reconciliation Report Daily Charge Reconciliation Report Batch Information Report RT Charges Posting Reconciliation Report Most current 15 months unless otherwise noted below CBOs will retain for co-pay pack for 10 years with the exception of original credit card receipts. Manual Charge Tickets Until verification is completed by the patient service specialistto ensure all documents are Page 3 of 5 Rasmussen Hospital : Medical Record Management Policy 6.01 Document Retention Rasmussen Hospital Document Retention Resource
  • 8. Record Type Organizational Charts Invoices Signed staff time cards Customer Complaint Forms Net Promoter Surveys Clinical Operations Policy and Procedure Manual Center Handbook Documents Retention Period scanned, attached to the electronic medical record and legible. Until superseded by new organizational chart Current + 1 year Current + 7 years Current year + 6 years Most recent 4 quarters Current policies Current + 1 year unless otherwise noted below Term of Contract + 6 years Term of employment + 5 years Current + 7 years Term of employment + 2 years Term of employment + 2 years
  • 9. Comments NA NA NA NA NA NA Management reports (Examples: Income statements, KPI reports, referral tracking reports) While useful in the center Any reports generated from the RMT or Oracle system do not need to be retained in hard copy. Administrative Logs (staff schedules, day-to-day management of office personnel / functions, petty cash requests) Current + 3 years NA Clinical Quality Assurance Audits For audits completed by hand or Excel spreadsheets, maintain current year plus previous year. Audits entered into the SM QA database, NA NA Equipment Calibration
  • 10. Safety Procedures pertaining to security of patients and/or employees Evacuation drill reports Safety Inspections of building or equipment Meeting Minutes Current year + 3 years. Includes all records documenting the inspection of facilities for potential safety hazards Contracts – Medical Director, Contract Employees and Lease Agreements Personnel Files of Employees and other employee records (unless noted below) Employee Medical Records Performance Appraisals / Compensation Adjustments / Awards and recognition Company sponsored education Keep the previous year’s records in a separate folder to
  • 11. decrease size of the Center Handbook. NA NA NA NA NA Page 4 of 5 Rasmussen Hospital : Medical Record Management Policy 6.01 Document Retention Select Medical Outpatient Division Document Retention Resource Record Type Job related accidents and injuries Employee Exposure Incidences or documents recording incident Retention Period Current Year + 5 years NA 30 Years NA Permanent NA Permanent NA Comments Incident Reports Record Destruction – records supporting the documentation of destruction of medical records
  • 12. Destruction of Records: a) Medical records shall be shredded or after they have been retained the greater of the following: i. Company policy as outlined in policy 6.01 (Document Retention), ii. State law if more stringent, or iii. Unique contractual requirements (if applicable) b) Where required by law, notice of record destruction will be reported to the appropriate agency in accordance with stated statutes, rules and regulations. c) The Regional Director or Market Manager shall be responsible for ensuring there is a mechanism to destroy the old records and that destruction is completed properly. d) During the course of normal daily activities, parts of the patient’s medical record may be copied for business purposes. These copies shall be destroyed by shredding once their purpose is completed. Page 5 of 5