Practice Management Alert

Getting an expert to review your billing record retention policy will ensure you keep files long enough

If you're in the process of writing or revising your policy on billing record retention, you need to think about storage logistics and timelines - and adequate backup mechanisms in case of disaster.

Here are three main questions you must answer when writing your policy:

1. How long should we store both paper and electronic copies of billing records?

 
2. Where should we store our records - and do we need multiple storage locations?

3. Do we have adequate backup of our computer files and other electronically stored documents?

You should build your billing record retention policy around the answers to these three questions:

1. How long should we store both paper and electronic copies of billing records?
 
Answer: The general rule is that you should retain all medical and billing records for about seven years because that's how long and far-reaching the audit process can be in some instances, says Andrew Cutler with FR&R Healthcare Consulting in Deerfield, Ill. But keep in mind that states' rules vary as to how long you should keep a minor's records after he becomes of legal age.

Try this guideline: "In my opinion, whatever the statute of limitations is for suing on a contract, you should retain [your records] for twice that period of time," says Elliot Oppenheim, MD, JD, LLM Health Law, CEO and president of coMEDco in Santa Fe, N.M. "For instance, in New Mexico you can sue on a contract for up to six years, so I think you should retain [records] for 12 years if you want to be really careful."

Payoff: The amount you pay for record retention will pale in comparison to the cost of a lawsuit if you don't have the records to support your defense, Oppenheim says.

2. Where should we store our records - and do we need multiple storage locations?
 
Answer: With the ease and accessibility of electronic record keeping, practices should move paper storage to electronic copies of all records relating to patients' care and treatment, Oppenheim says. And because CD ROMs require such little storage space, you may want to keep your electronic records indefinitely, he adds.
Don't toss hard copies: Even though you'll have easily accessible electronic records, you should still hold onto a copy of all paper billing records for the appropriate amount of time as indicated by your state's statutes. The point is to always have two separate copies of all records in two separate locations in case a disaster, such as fire or flood, wipes out all your records in a given storage area, Cutler says. So for example, you could keep all your hard copies in the basement of the practice and keep electronic records off-site, he says.

If you keep all paper records, you should pay to keep copies in a separate storage facility. Many record-storage facilities will make microfiche copies of your records and store those off-premises to ensure you have copies in two separate, safe locations, Cutler says.  

3. Do we have adequate backup of our computer files and other electronically stored documents?
 
Answer: Maintaining continual backup of your computer files will ensure a smooth transfer of this information into record storage - and, even more important, it will guard against data loss due to computer problems. "Hard drives fail, files get corrupted," so computer backup is essential, Oppenheim says.

Just as you should keep a separate copy of your billing records off-site, you should keep computer backup off-site as well. Keeping daily backup of your computer files in your information technology office won't cut it if a disaster afflicts your whole building, Oppenheim says.
 
Attorneys and Listservs Rank Among Best Resources

Storing billing records safely and for the legally appropriate length of time is important for two reasons:   1. to make sure your practice can defend a potential lawsuit, and 2. to provide historical information to help with current patient care, Oppenheim says.
 
Consult an expert: To make sure your policy is in line with state rules and hasn't overlooked any necessary components, you should have an attorney or billing consultant read over your final draft, Cutler says.
 
You should certainly seek legal counsel when writing a billing record retention policy, agrees William Brouwer, president of PRIMA Healthcare Management Resources in Visalia, Calif. "You could also consult your certified public accountant" for guidance on storing financial documents,  he adds.
 
Look to listservs: If you don't want to spend a lot of money on expensive consultants and legal advisers, you may be able to obtain helpful information from your healthcare specialty organization's listserv or a general billing listserv, Brouwer says. "Colleagues typically are very willing to share what they have done in their office, and you can also get some pretty state-specific policies" this way, he says. Then you'll only need to pay for an expert to quickly review your final policy.

Editor's note: As a subscriber to Medical Office Billing and Collections Alert, you have free access to our online billing listserv. You can join at www.coding911.com/join.html.