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
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