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Subject:
From:
Bruce White <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 19 May 2009 18:01:28 -0700
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On 5/19/09, Steven Whitaker <[log in to unmask]> wrote:
> Bruce White CRM, PMP, you used to work for NARA years ago.  What was
> the process for developing retention policy?  And..., were they blowing
> off Dawn instead of simply taking care of her needs by developing the policy?
If my memory serves me the agency is responsible for submitting new
records series (via SF115) not covered on a GRS or approved by NARA
for the agency.  NARA's website
(http://www.archives.gov/records-mgmt/policy/records-schedule-review-process.html)
discusses the steps involved in developing records series (also known
as records schedules).  Depending on the nature of the request could
take weeks or months.

Dawn, since you fall under the VA's Office have you contacted your
Federal Records Officer on this topic (I see a couple of names on
NARA's website)?  You may also check with the NARA Regional Office
that is supporting your region (Laguna Niguel) and ask them for advice
- they might be able to give you some direction.

And although I agree with Steve's point that records managers need to
go through the process of evaluating the value of a record to the
organization (administrative, financial, legal, etc) I also think
asking how long other organizations are retaining their records isn't
a bad idea as well.  I wouldn't use this as the sole criteria in
establishing retention of records.  But sometimes I believe it is a
good idea (in my humble opinion) to find out what are best practices,
especially with regard to industry specific records (yes I know the
discussion was on software licenses, something common to most
organizations.)

I've been wrestling with this issue with patient records for some time
now.  Each state and (the feds) has it's own definition of what a
patient record is as well as different retention periods for both
adult and pediatric records.  Where it gets real ugly is with regards
to pediatric - some states define the age of majority as 18, others as
21, etc.  The challenge for my company is that we have operations in
all 50 states.  So not only am I considering the various laws and
regulations but also recommendations from organizations such as AHIMA.

It would be great if one of the standards coming out of Obama's
electronic health records initiative is a uniform retention for health
records.

-- 
Bruce L. White, CRM, PMP
Orange County, CA
e-mail: [log in to unmask]

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