The Electronic Health Record Incentive Program and the Electronic
Health Record Demonstration Program are two separate programs which
fall under the ARRA program. Both programs are run by Centers for
Medicare and Medicaid Services (CMS). The records retention
requirements for these two programs appear to be different at this time.
The Electronic Health Record Demonstration Program was developed in
2008 and was designed to reward delivery of high-quality care supported
by the adoption and use of electronic health records in physician
practices. Demonstration program retention requirements are listed as
a record type in the March 2010 CMS Records Schedule as shown below:
L. Demonstration Project Files (Disposition Authority: N1-440-98-1)
The demonstration file consists of the following information for
management payment (capitation or cost) as well as for the evaluation:
Award/initiation letter, cost reports, financial statements,
correspondence, progress reports, corrective actions, site visit
reports, interim and final reports, desk review programs, notices of
program reimbursement, adjustment reports, appeals information (e.g.,
position papers), payment information, enrollee data, monthly and
history edits.
DISPOSITION: Close demonstration file at the end of the fiscal year
after final action is completed (e.g., final payment, settlement,
appeal or evaluation). Transfer to a Federally-approved records storage
facility 2 years after closure. Destroy 10 years after closure. If
inactive case becomes active, it must be PERMANENTLY WITHDRAWN from the
Federally-approved records storage facility.
The Medicare and Medicaid EHR Incentive Programs provides incentive
payments to eligible professionals, eligible hospitals and critical
access hospitals (CAHs) as they adopt, implement, upgrade or
demonstrate meaningful use of certified EHR technology.
42 CFR Parts 412, 413, 422 et al., Medicare and Medicaid Programs;
Electronic Health Record Incentive Program; Final Rule states as
follows regarding records retention related to the program:
“Comment: Some commenters recommended a shorter record retention period
that the ten years proposed. Commenters recommended periods ranging
from three to eight years. The reasons given for a shorter time period
were the cost of record retention, no perceived need for a retention
period longer than the incentive period, rapid changes in EHR
technology and consistency with other unspecified retention
requirements. Response: After reviewing the comments, we agree with
commenters that ten years is longer than necessary to ensure the
integrity of the program. In considering a shorter retention period, we
believe that there may be cause to look over the entire incentive
period. As a Medicaid EP would be eligible for incentives over a
six-year period if they successfully receive an incentive each year and
that is the longest such period available to any participant in the
Medicare and Medicaid EHR incentive programs, we adopt a new retention
period of six years for this final rule.”
For a complete reading of this Federal Register section, go to
http://edocket.access.gpo.gov/2010/pdf/2010-17207.pdf
Julie Ann Fleming, CRM
-----Original Message-----
From: Richard G. King <[log in to unmask]>
To: RECMGMT-L <[log in to unmask]>
Sent: Tue, May 3, 2011 11:26 am
Subject: Re: Records retention requirements ARRA
On 5/3/2011 6:18 AM, John Montana wrote:
> Further to Larry's comment, if you got the money as a federal grant
of some kind, there may be some recordkeeping requirements for that
specific grant program. Federal agencies have regulations dealing with
the grants they hand out, and those usually contain some sort of
recordkeeping and retention requirement. The recordkeeping is usually
standard accounting records and retention is normally only a few years
and not a problem, but without looking you can't be absolutely sure,
since every agency has its own set of rules, and many have more than
one grant program. Here's one example, from H.U.D.:
>
Folks,
Also Under (I believe) FAR 7 if you image any hard copy records
(financial) related to Federal grants & contracts you will need to keep
the hard copy for one year after imaging for audit purposes. You would
obviously need to check with the relevant agency to see if this is the
case. Personally, I'd check with my audit agency rather than the
funding agency. Dick King, University of Arizona
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