prc records management - cloudinary

2019 Indian Health Service

Partnership ConferenceSpokane, Washington

PRC RECORDS MANAGEMENT

Area Best Practices

June 11, 2019

Presented by Jeremy Woodruff and Grace Baca

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

2018 IHS PARTNERSHIP CONFERENCE 2

WHAT IS A RECORD?

The Federal Records Act (FRA) defines a record as:

All recorded information, regardless of form or characteristics, made orreceived by a Federal agency under Federal law or in connection with thetransaction of public business and preserved or appropriate forpreservation by that agency or its legitimate successor as evidence of theorganization, functions, policies, decisions, procedures, operations, or otheractivities of the United States Government or because of the informationalvalue 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’sunique, mission-related activities. Examples: Environmental health project files, purchased/referred care services patient case files, Tribal health programfiles, Health Records/Mental Health Records

• Administrative Records are records documenting theagency’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 theoffice 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 establishmentof new files.

• Disposal is the action taken regarding temporary records after their retention periods expire, andusually consists of destruction/deletion.

• Disposition is a comprehensive term that includes both destruction and transfer of Federal records to theNational Archives of the United States.

• Disposition instructions are directions for cutting off records and carrying out their disposition incompliance with NARA’s regulation. Includes directions for screening out non-record materials and carryingout 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 bepreserved 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 warrantcontinued preservation by the Federal Government as part of the National Archives of theUnited States.

• Records schedule identifies records as either temporary or permanent. It providesmandatory instructions for the disposition of the records (including the transfer of permanentrecords 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 fromoffice space to off-site storage facilities, from one agency to another, or from an agencyoffice to an FRC.

• Unscheduled records are records whose final disposition has not been approved by NARAand 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



• Two types of Records Schedules that identify retention periods for types of records



• 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


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

• https://www.ihs.gov/dra/recordsmanagement/dispositionschedule2/

https://www.ihs.gov/dra/recordsmanagement/dispositionschedule2/

COST REVIEW

•Cost of Accession request

•Cost of storage

•Cost of Labor

•Cost of shipment

•Cost of record retrieval

•Cost of supplies


SHIPPING SUPPLIES


• Boxes• Standard-size box (14¾” x 12” x 9 ½”)

• NSN 8115-00-1178249

• Clear packing tape • Black felt-tip markers• Shrink Wrap• Pallets

ARCIS (1 OF 2)

• Records can be requested from the FRC electronically usingthe Archives and Records Centers Information System(ARCIS)

• The RMO, HQ will assist with access to ARCIS

• For the complete ARCIS process refer to the resources below

• The OF-11 form is discontinued for IHS

• It is required to complete the ARCIS training modules

• YouTube: https://www.youtube.com/playlist?list=PLugwVCjzrJsX7jEADMCpD3kEL1avVK6Su

• Training home page: https://www.archives.gov/frc/training

• ARCIS Manual: https://www.archives.gov/files/frc/arcis/manual.pdf


https://www.youtube.com/playlist?list=PLugwVCjzrJsX7jEADMCpD3kEL1avVK6Su

https://www.archives.gov/frc/training

https://www.archives.gov/files/frc/arcis/manual.pdf

ARCIS (2 OF 2)


TRANSFERRING RECORDS TO FRC (1 OF 6)

• After cost review and determination made that PRC Records must be transferred

• Create an inventory list of records being transferred

• Submit SF-135 to IHS Area Records Liaison (ARL) for review

• ARL will forward to HQ RMO for final approval



• When you receive notification your SF-135 is approved (Box #2,) you will then forwardto the appropriate FRC requesting their approval to send the inactive records.

• When your approval is received, you will label your boxes with the:

– accession # that has been assigned by NARA. (This will be found in Box #6 a – c. )

– Agency Box #s

• A copy of the completed SF-135 and your inventory list will be placed in Box #1 ofeach accession #.

• All boxes should be taped, placed on palate and shrink wrapped prior to shipment tothe FRC.

Local FRCs differ slightly regarding stacking pallets and the preferred order of boxes onpallets. Please contact the transfer office at your local FRC to confirm proper box order foryour FRC. Pallets should be securely banded with shrink- wrap, steel, plastic, or cordstrapping before shipping.



Tips for Packing the Records

• Do not over pack the boxes. Leave a 1 to 2 inchspace in each box to allow ease of reference. Do notput additional material on the bottom, side, or top ofthe records in the box.

• Mixed media (e.g., computer diskettes, microfilm, orvideocassettes) cannot be stored in the same environment as paper records. Please do not includethese media in the same transfer with paper recordswithout prior approval from the FRC.

Retrieved from: https://www.archives.gov/frc/records-transfer#boxes


https://www.archives.gov/frc/records-transfer#boxes

AREA FRC LIST (1 OF 3)

https://www.archives.gov/frc/locations


https://www.archives.gov/frc/locations

DISPOSITION OF SOURCE SCANNED DOCUMENTS (2 OF 4)


FACILITY SCANNING POLICIES

• Facilities must create a local policy for qualitycontrol before shredding source scanneddocuments.

• It is recommended to keep the source scanned documents for a minimum of 90 days, but no longer than 180 days.

• The goal is to be 100% digitized, and your facilitypolicy should reflect your process.


NARA STRATEGY PLAN FOR 2022

• By December 31, 2022, NARA will, to the fullest extent possible, no longer accept transfers of permanent or temporary records in analog formats and will accept records only in electronic format and with appropriate metadata.

NARA added the phrase “to the fullest extent possible” based on extensivefeedback from both staff and external commenters.

They modified the language of this objective to recognize that NARA may needto accept a limited number of analog records after the December 31, 2022deadline.

IHS RMO HQ is establishing a plan for 2022.

* See HIM Track for medical/patient records.


RESOURCES AND REFERENCES (1 OF 2)

Alaska – Vacant Nashville – Mary Yazzie

Albuquerque – Grace Baca Navajo – Lanelle Anderson

Bemidji – Lenora Bedeau Oklahoma City – Cindy Blue

Billings – Jennifer Gong Phoenix – Jeremy Woodruff

California – Armina JumpingBull Portland – Waleeska Knifechief

Great Plains – Mark Azure Tucson – Sandra Montana


RESOURCES AND REFERENCES (2 OF 2)

• Indian Health Manual, Part 2, Chapter 3

Purchased/Referred Care

https://www.ihs.gov/ihm/pc/part-2/chapter-3-purchased-referred-care/

• Indian Health Manual, Part 5, Chapter 15

Records Management Disposition Schedule

https://www.ihs.gov/ihm/pc/part-5/p5c15/

• National Archives Website

IHS Records Control Scheduleshttps://www.archives.gov/records-

mgmt/rcs/schedules/index.html?dir=/departments/department-of-health-and-human-services/rg-0513


https://www.ihs.gov/ihm/pc/part-2/chapter-3-purchased-referred-care/

https://www.ihs.gov/ihm/pc/part-5/p5c15/

http://www.archives.gov/records-

Questions and Discussion


prc records management - cloudinary

Documents