Good discussion.  A few things to note.  

Retention of medical records is based on a trigger event of "after last
service" or something similar.  A 10 year retention, therefore, means
the medical provider maintains the record for 10 years after the last
time the patient was seen or treated.  If they do not see or treat
someone for 10 years, it is generally supposed that the patient has gone
to another medical provider or moved away or died.  If the patient wants
their medical history to "follow" them, they must request (usually in
writing) the records be sent to their new medical provider.

A records storage facility owned by a third party is not responsible for
setting retention for the records stored there.  The owner of the
records (in this case, the medical facility) sets the retention.  The
storage vendor follows instructions from the "owner" as to when and how
records should be destroyed.  Even if the "owner" no longer exists (i.e.
out of business), the storage vendor should follow the instructions
received when the records were placed in storage.

Ginny Jones
(Virginia A. Jones, CRM, FAI)
Records Manager
Information Technology Division
Newport News Dept. of Public Utilities
Newport News, VA
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