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Records and Retrieval

Inventory is key to off-site record storage

New HIPAA rules demand tighter retention practices. By April D. Robertson


he American Recovery and Reinvestment Act’s (ARRA) modifications to the HIPAA regulations affecting record storage and re- tention are shaking up the way records are

indexed and stored in three key areas: record inven- tory, retention requirements and provider liability. As originators of the protected health information (PHI), it is imperative that providers address their processes, policies and education programs in con- junction with their off-site medical record storage providers in a combined effort to curb data breaches and mitigate risk.

the covered entities (CEs) they serve at greater risk for breaches, penalties and fines.

Record inventory beyond the box Records must be accounted for and electronically

indexed to the individual level into the storage facil- ity’s inventory control system, and both the business associate (BA) and CE must possess the inventory. If boxes of PHI were stolen (or lost) from an off- site storage facility, the BA and CE would be unable to respond to the incident appropriately because they would be unable to identify and notify every individ- ual of the potential breach and the respective state government department as required under the new HIPAA regulations. The CE and BE would be sub-

The storage relationship is a collaborative one. There are benefi ts to partnership and dangers in failing to work together.

ject to criminal or civil penalties because they could not identify the individuals for notification and mitigation of the lost PHI. Overall, bad publicity would prevail.

The most important first step is to evaluate the

way off-site record storage vendors (business associ- ates under HIPAA) identify and index each record in their possession. Many vendors do not maintain a detailed, accurate inventory, which places them and

26 November 2010

Providers should negotiate with their off-site storage company to determine the cost of having all individual records inventoried. It is unlikely that a CE who is unwilling to pay to inventory its records will find a truckload of un-indexed records on its


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