Classification: UNCLASSIFIED
Caveats: NONE

Hugh are you asking about their concerns regarding any HIPAA issues?  From
what I read, that should be a primary concern.  Do they have a business
associate's agreement with their offsite storage vendor regarding HIPAA
protection?  Our records are stored in-house until they are transferred to
the appropriate Federal records center.  Our biggest concern is HIPAA!  We
pretty much have a good handle on the records themselves.

Judy K. Tyler, CRM
Records Management/FOIA/PA/Forms Management Officer
Carl R. Darnall Army Medical Center
Fort Hood, TX  76544
DSN 738-8009
Commercial 254-288-8009
Fax 254-286-7755

Serving to Heal...Honored to Serve



-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Hugh Smith
Sent: Wednesday, September 18, 2013 10:35 AM
To: [log in to unmask]
Subject: Re: How does records management work in a hospital?

I am working with a Children's Hospital and as often happens, the records
management function has come undone with all the move to Electronic Record
Keeping.

They have no records manager, they have no real CIO, everything is decided
by the Operating Committee which is primarily doctors who clearly don't have
the business background to consider all the issues.

They store their xrays and imaging on site in the basement (pretty standard
), they pay attention to MRI because that is a cash cow but now what to do
with those pesky tapes.

They became concerned so they decided to do a large pull and check the
offsite inventory with their understanding of what they had.  First off the
large offsite company storing their imaging put a hold on their withdrawals
as their software at the storage vendor perceived it as a client trying to
change vendors. They were told they were only allowed to pull so many at a
time but would be continued to be billed as if those back up media units
(LTO's) were still offsite.

So the first response of the storage company was not to service the client's
needs but to protect their own interests. This incident then created a panic
with the Doctors because they seemed to lose control of their own media.

When their audit revealed that their tapes that they were being billed for
seemed far in excess of what they showed they actually created, the fears of
HIPAA violations.

Depending on the state the hospital is in, the records of children must be
kept for Life plus 20 or for life period. Then the issue of media stability
came up as the GE people who make the MRI units and such pointed out that
was a concern.

Do we have any records managers on the List from hospitals?  What are the
concerns that the hospital should be most concerned about.  They also just
found out that the room that the offsite vendor said was a vault is really
not designed to protect media and they are moving faster and faster to an
all electronic and digital records storage platform to comply with the
Affordable Care Act and other federal requirements.

I pointed out that spoliation can create real problems for them. Their
concern was primarily not having a HIPAA exposure but now are concerned
about liability for not maintaining viable media. The radiology group that
does the hospital's readings stated that aging media was more difficult to
read.

This is probably not that interesting to everyone but if anyone had some
pointers for them, please let me know.  I mentioned some the CRM's as a
source for consultant's but right now they are concerned about learning
where they are before they expose themselves to any one from the outside.

I have looked at RAIN for some posts on hospitals and the fines, but medical
records keeping is changing so drastically that finding solid ground is hard
to do. It seems that their organizational structure is totally wrong for the
task at hand. Lifetime storage for fragile media, cloud storage in the age
of Data Mapping and the fact that they are being herded very fast to an area
they have no experience in.

What should the medical records keeping function look like in this world? Up
until now, the Doctors took the approach that they are Doctors and this is
not their concern but they read about fines but the cost of becoming
compliant is very high.  Now they find the vendor they trusted to be a part
of their records management function is now so concerned about losing the
records income that they are not helpful.

Can anybody cite some good articles on this topic.  "Imaging and Digital
Records Keeping in the Health Organization for Dummies" is not available at
Barnes & Noble. ;~)

Hugh Smith
FIRELOCK Fireproof Modular Vaults
[log in to unmask]
(610)  756-4440    Fax (610)  756-4134
WWW.FIRELOCK.COM

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