2019 Indian Health Service
Partnership Conference
Spokane, Washington
PRC RECORDS MANAGEMENT
Area Best Practices
June 11, 2019
OBJECTIVES
•
Distinguish a record from a non-record
•
Understand Records Retention Schedules
•
Encourage retaining PRC records locally
•
General understanding of the records transfer process
•
Understand the disposition of source scanned documents
•
Understand the National Archives Records Administration
(NARA) Strategic Plan for 2022
•
Questions and Answers
WHAT IS A RECORD?
The Federal Records Act (FRA) defines a record as:
All recorded information, regardless of form or characteristics, made or
received by a Federal agency under Federal law or in connection with the
transaction of public business and preserved or appropriate for
preservation by that agency or its legitimate successor as evidence of the
organization, functions, policies, decisions, procedures, operations, or other
activities of the United States Government or because of the informational
value of data in them.
(44 U.S.C. 3301, Definition of Records)
NARA defines Electronic Records as:
Any information that is recorded in a form that only a computer can process.
(36 CFR 1236)
RECORD CATEGORIES
•
NARA defines 2 types of record categories:
•
Program records are records documenting the agency’s
unique, mission-related activities. Examples:
Environmental health project files, purchased/referred
care services patient case files, Tribal health program
files, Health Records/Mental Health Records
•
Administrative Records are records documenting the
agency’s routine housekeeping support activities.
Examples: budget, personnel, supply, housekeeping
WHAT IS A NON-RECORD?
•
Non-record materials are U.S.
Government-owned documents that do
not meet the conditions of a record.
•
Examples:
•
Duplicate copies of documents
•
Catalogs, trade journals, and other reference
material
•
Copies of correspondence
IS IT A RECORD? (1 OF 2)
IS IT A RECORD? (2 OF 2)
NARA TERMINOLOGY (1 OF 2)
National Archives and Records Administration
•
Active records are records that continue to be used with sufficient frequency to justify keeping them in the
office of creation; current records.
•
Cutoff is the breaking or ending of files at regular intervals, usually at the close of a fiscal or calendar year,
to permit their disposal or transfer in complete blocks and, for correspondence, to permit the establishment
of new files.
•
Disposal is the action taken regarding temporary records after their retention periods expire, and
usually consists of destruction/deletion.
•
Disposition is a comprehensive term that includes both destruction and transfer of Federal records to the
National Archives of the United States.
•
Disposition instructions are directions for cutting off records and carrying out their disposition in
compliance with NARA’s regulation. Includes directions for screening out non-record materials and carrying
out their disposal when no longer needed by the agency.
•
Disposition Schedule – see Records schedule
•
Inactive records are those no longer used in the day-to-day course of business, but that may be
preserved and occasionally used for legal, historical or operational purposes.
NARA TERMINOLOGY (2 OF 2)
•
Temporary records are those records that NARA approves for either immediate disposal
or for disposal after a specific time or event.
•
Permanent records are those that NARA appraises as having sufficient value to warrant
continued preservation by the Federal Government as part of the National Archives of the
United States.
•
Records schedule identifies records as either temporary or permanent. It provides
mandatory instructions for the disposition of the records (including the transfer of permanent
records and disposal of temporary records) when they are no longer needed by the agency.
•
Transfer is the process of moving records from one location to another, especially from
office space to off-site storage facilities, from one agency to another, or from an agency
office to an FRC.
•
Unscheduled records are records whose final disposition has not been approved by NARA
and may NOT be destroyed or deleted.
RECORDS RETENTION SCHEDULES
•
A Records Retention Schedule is a
document that provides legal authority for
the final disposition, including destruction
or preservation of the records in an office,
Op-Div, or Agency.
•
AKA Records Disposition Schedule
RECORDS RETENTION SCHEDULES
•
Two types of Records Schedules that
identify retention periods for types of
records
RECORDS RETENTION SCHEDULES
•
General Records Schedule (GRS)
•
Provides retention requirements for records
common among several agencies. Examples:
Accounting, Procurement, Communications,
Printing
•
IHS Records Schedule
•
Provides retention requirements for records
unique to IHS
•
Requires NARA approval before schedules can
be implemented
PRC RECORD RETENTION PERIOD
(1 OF 2)
•
Retention is the length of time a health record must be kept (either
in the department/office or off-site storage) because it is needed for
ongoing business, to document an action, or for statutory reasons.
Note: this is also referred to as a “retention period.”
•
We highly encourage retaining PRC records depending on the
facilities available filing space.
•
Cut off instructions: records should be reviewed annually to
identify closed case files for disposition.
•
Transfer to Storage: facilities should consider the cost of
transferring case files, and the cost of storage versus storing the
case files locally until retention period is reached. Records should
only be transferred when local storage space is at full capacity.
PRC RECORD RETION PERIOD
(2 OF 2)
Retention Period (AUTH: N1-513-92-5):
•
PRC Claims Adjudication File – 6 years, 3
months CHEF Files – 6 years, 3 months
•
Patient Case files /other documents – 5
years
•
Fiscal Intermediary File - 3 years
•
Medical Contract File – 6 years, 3 months
IHS DISPOSITION SCHEDULE
2019 IHS PARTNERSHIP CONFERENCE
15
SECTION 3 – CONTRACT HEALTH SERVICES
ITEM NO. TITLE AND DESCRIPTION OF RECORD DISPOSITION AUTHORITY
3-1 CONTRACT HEALTH SERVICES CLAIMS ADJUDICATION FILE. Case files include appeals of denials for payment for Contract Health Services (CHS) and management determinations
involving, if appropriate, medical records, eligibility for alternate resources, Federal regulations, IHS policies, existing case law and precedents, legal and/or medical opinions, documentation of events involved in each case, and other related documents.
Cut off on close of case. Destroy when 6 years, 3 months old. AUTH: N1-513-92-5
3-2 CATASTROPHIC HEALTH EMERGENCY FUND. These files document the IHS-wide guidance of the management, monitoring and general oversight governing the usage of the Catastrophic Health Emergency Funds for high cost cases affecting IHS Areas and tribally operated facilities. Patient case files include those determined to be a "catastrophic illness" based on conditions that are costly by virtue of the intensity and/or duration of their treatment.
a. Patient case files. b. Other documents.
Return to Medical Records Section for
disposition in accordance with Schedule 3, Item 3-1. AUTH: N1-513-92-5
Cut off at the end of the fiscal year. Destroy when 5 years old. AUTH: N1-513-92-5
3-3 FISCAL INTERMEDIARY FILE. These files document the IHS-wide guidance of the management, monitoring and general oversight governing the usage of the fiscal intermediary contract awarded to operate, on a nationwide basis, a claims processing system for the IHS CHS Program.
Cut off at the end of fiscal year. Destroy when 3 years old. AUTH: N1-513-92-5
3-4 MEDICAL CONTRACT FILE. Case files including copies of public health contracts and related evaluation reports concerned with medical, dental, x-ray, clinical laboratories, contracts with physicians, institutions, and other groups, and related documents.
Cut off on administrative closeout. Transfer to the FRC when 2 years old. Destroy when 6 years, 3 months old. AUTH: N1-513-92-5
