I'm not quite sure that you have a problem.  Both records have sensitive
information that requires protection (medical information and personal info
- SSN's).  Both require destruction by shredding or a means that protects
the sensitive information contained in the file.  I don't believe either has
precedence.  

I'm also not quite sure what was accomplished by HR managing the
reimbursements for expense of miscellaneous medical claims.  Someone has to
maintain the medical claim information as a backup as part of the accounts
payable for tax audit.  If HR sends the payment information to Accounts
Payable for payment, you still have to attaché the supporting documentation.
You can't have a reimbursement without the supporting documentation. If HR
is the paying the claim then they must retain the supporting documents for
Tax Audit.    If so, then it would appear that HR has there own accounting
function that pays medical expenses of the company which would be a
duplication of the accounting function.  

I'm not sure that you can find a legal precedence for the requirement.  If
you can't trust the people in the accounting function to manage claim
information, then you really have a problem.  

Bob Dalton, CRM
Dalton Consulting



-----Original Message-----
Behalf Of Schildmeyer, Greg
Subject: Re: Retention of "Mixed" Files

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. 

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