Diane,
Very astute questions.

I would encourage you to try to change the filing procedures, for a
couple of reasons.  First of all, the reimbursements for medical-related
expenses, while probably not considered "medical records" per se, may
contain some health related information that could bring them under
HIPAA.  They will have a higher level of sensitivity, although not
necessarily a longer retention (they are still, basically, accounting
records). This is something you may want to discuss with your general
counsel. 

Secondly (and here's the carrot you can offer to persuade accounting to
change), filing the medical records in a separate folder will be a lot
faster than the current practice of filing on two different sides of the
same folder.  It is much more efficient to loose-file documents than it
is to punch holes and prong file them.  Both filing and retrieval are
quicker. Since you currently recognize the need to keep the two kinds of
documents apart, then I'd say do it in the most efficient way.

Regarding retention, you will have to determine if there are any
regulatory or audit requirements that specify a retention period.  Then
determine, from the accounting folks, what their actual usage of old
record is - how far back do they typically have to go to retrieve
records (and is the information they need available to them from an
automated system or elsewhere)?  That should give you a pretty good
retention.  In my experience, normal accounting records are fairly short
term, 3 to 6 years.

Greg Schildmeyer, CRM 
"You know your landing gear is up and locked when it takes full power to
taxi to the terminal."


-----Original Message-----

Please share your opinions and advice with me re:  (a)  retention period
for existing "mixed" files, and (b) attempting to change file set up.

Thank you,


Diane Dodge
Total Resource Management, Inc.
510 King Street, Suite 300
Alexandria, VA  22314
Ph:    (703) 548-4285
Fax:  (703) 548-3641
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