You need to decommission your legacy system(s) and you’ve chosen data archival as your solution to maintain the integrity of your data and uphold eDiscovery requirements. But how do you determine how long data must be archived for? Consider these 5 Factors:
Patient Demographics: Almost every state has different rules for pediatric patients versus adult patients. In a perinatal situation, you may need to keep that pediatric patient’s records until they’re 21, so it could be 21 years if you had a record from when they were a day old.
State in which care was delivered: State minimums are normally based on their statute of limitations, but there are a handful of states that have specific regulations. This matters if your organization sees patients in multiple states, you have to decide whether you’re going to standardize on the state that has the longest duration or try to do it on a state-by-state basis.
Last chart modification or encounter: What is the time/date that triggers the clock starting to tick, the time you can get rid of this information. Generally, it’s the last time the chart was touched by somebody. Anytime that chart was changed, including a visit, that’s the time the clock starts to tick.
Just to be clear, this is not restricting how much data in an individual chart we need to keep. In other words, if a patient has been seen for a decade, they have a decade worth of data in their chart; if the law says you only need to keep this for seven years, you’re keeping a decade worth of data for seven years from that point-in-time. That’s one of the reasons that data migrations are done at the same time, or in addition to data archival. It’s not clinically relevant, in most cases, what happened ten years ago to a patient. A lot of data is no longer remotely relevant, so you’re wouldn’t bring it over as part of a data migration, whereas from an archival perspective you have to keep it.
Rule of Thumb: “When in doubt archive the information”
One interesting asterisk for all of this is that some states have guidelines for certain types of data that exceed these. An example of this is patient registration and scheduling information in acute scenarios, there are a handful of states that require you keep that specific subset of a patient’s chart forever. This is the high level but it’s always important to dig into the very specific details of this.
Want to learn more about data archival strategy? View our webinar, Exploring Healthcare Data Archival Strategies, on healthsystemCIO.com. Questions? Contact us below: