I agree with Donna.
At my agency each treatment chart contains a Disclosure Log which becomes a permanent part of that chart and can only be destroyed when the retention period of that chart has lapsed (10 years after date of last service).
Max
Max Dean
Mount Rogers Community Services Board
Data Resources Office
770 West Ridge Road
Wytheville, Va. 24382
(276) 223-3215 (Phone)
(276) 223-3250 (Fax)
[log in to unmask]
Confidentiality Notice
The information transmitted by this e-mail is intended only for the addressee and may contain confidential material. Any interception, review, retransmission, dissemination, or other use of, or taking of any action upon this information by persons or entities other than the intended recipient, is prohibited by law and may subject them to criminal or civil liability. If you receive this communication in error, please contact the Mount Rogers Community Services Board’s Privacy Officer at 276-223-3200. This communication should then be deleted from any computer or network system.
Please consider the environment before printing this e-mail.
-----Original Message-----
From: Virginia Records Officer's Listserv [mailto:[log in to unmask]] On Behalf Of Hoover, Donna S.
Sent: Thursday, February 25, 2010 5:15 PM
To: [log in to unmask]
Subject: Re: GS 18 QUESTION
Upon reviewing GS 18, since the logs referred to do not mention/include the log pertaining to the release of PHI, then a 6 year retention is not necessary. However, any releasing of PHI would require a log be kept due to the patient's right to request an accounting of disclosures per 45 CFR §164.528
Donna S. Hoover, MBA, RHIA
Records Management Services
Woodrow Wilson Rehabilitation Center
HIPAA Privacy/FOIA Officer
PO BOX 1500, W-484
Fishersville, VA 22939-1500
Ph: 540.332.7904 Fx: 540.332.7923
-----Original Message-----
From: Virginia Records Officer's Listserv [mailto:[log in to unmask]] On Behalf Of Emanuel, Caryn
Sent: Thursday, February 25, 2010 2:39 PM
To: [log in to unmask]
Subject: Re: GS 18 QUESTION
I agree with Brian. Keep retention at 2 years.
Caryn Emanuel, MPA, RHIA
Health Information Compliance Manager
Fairfax-Falls Church Community Services Board
Email: [log in to unmask]
703 324-5193, (fax) 703 324-7092
This message is intended only for the use of the addressee and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Thank you!
-----Original Message-----
From: Virginia Records Officer's Listserv [mailto:[log in to unmask]] On Behalf Of Conley, Brian
Sent: Thursday, February 25, 2010 2:37 PM
To: [log in to unmask]
Subject: Re: GS 18 QUESTION
In our case the Logs are just a listing of who came in and when. If treatment is rendered that information is entered in the patient chart covered under 005612 or 005613. Billing information is kept in a separate database/billing system.
The log become redundant as far as patient or billing information is concerned.
Brian A. Conley, Asst. County Archivist
Archives & Records Management Branch
(703) 658-3780
-----Original Message-----
From: Virginia Records Officer's Listserv [mailto:[log in to unmask]] On Behalf Of Harris, Douglas (VDH)
Sent: Thursday, February 25, 2010 2:17 PM
To: [log in to unmask]
Subject: Re: GS 18 QUESTION
Sounds like a good question.
Doug
Douglas R. Harris
Adjudication Officer and Adviser to the State Health Commissioner Virginia Department of Health
(804) 864-7007
-----Original Message-----
From: Virginia Records Officer's Listserv [mailto:[log in to unmask]] On Behalf Of Kendall, Jerome
Sent: Thursday, February 25, 2010 1:38 PM
To: [log in to unmask]
Subject: GS 18 QUESTION
In the matter of GS 18 - 005618:
Logs - Admission, Closing, Crisis, Emergency or Treatment This series consists of any logs or databases established to control, schedule or monitor services provided.
005618
Retain 2 years after event date in electronic logs or last entry in paper-based logs, then destroy in compliance with No. 8 on schedule cover page.
Should the retention on this series be changed to 6 years to make it HIPAA-compliant because of the "Treatment" component?
Jerome Kendall
Records Administrator
Chesterfield County
To UNSUBSCRIBE, change options, or subscribe, please see the instructions at http://listlva.lib.va.us/archives/va-rol.html
(If using Netscape, must have version 6.1 or higher to view the above
page)
To UNSUBSCRIBE, change options, or subscribe, please see the instructions at http://listlva.lib.va.us/archives/va-rol.html
(If using Netscape, must have version 6.1 or higher to view the above
page)
To UNSUBSCRIBE, change options, or subscribe, please see the instructions at http://listlva.lib.va.us/archives/va-rol.html
(If using Netscape, must have version 6.1 or higher to view the above
page)
To UNSUBSCRIBE, change options, or subscribe, please see the instructions at http://listlva.lib.va.us/archives/va-rol.html
(If using Netscape, must have version 6.1 or higher to view the above page)
To UNSUBSCRIBE, change options, or subscribe, please see the instructions
at http://listlva.lib.va.us/archives/va-rol.html
(If using Netscape, must have version 6.1 or higher to view the above page)
|