CORPORATE POLICY ON - Society for Human Resource …



Policy on Records ManagementIntroductionIt is the policy of [insert business name], to have in place an effective records management policy addressing appropriate retention procedures.Records, as used in this Policy, refers not just to paper records but to records in any form or medium including but not limited to microfiche, computer tape, diskette, and photographs.ObjectivesAll records will be maintained for the minimum period required by applicable state (Pennsylvania) or federal law or regulation or by contract.[insert business name] will retain records which may substantively affect the obligations of [insert business name] for a period of time which will reasonably ensure the availability of those records when needed.[insert business name] will destroy records regularly and methodically pursuant to a standard policy so as to avoid any implication that records were deliberately destroyed.[insert business name] will maintain a safeguard for all destruction procedures to ensure that the destruction of relevant records is halted immediately upon receipt of notice of investigation or legal process.[insert business name] will ensure that records are appropriately secure and private as provided by law.Records Review and RetentionAnnual ReviewThe Information Systems Director ("Director") who is responsible for implementing this policy, will direct, supervise or conduct (as the case may be) a file review and purge process on at least an annual basis. This process consists of identifying and destroying unnecessary duplicate and multiple copies of documents and reviewing and destroying documents which exceed the required retention period. DestructionIn January of each year, it is. the responsibility of the Director to review the documents of [insert physician practice name] to determine which records have reached their disposal date and to arrange for destruction of documents. ConfidentialityAll medical records, employee records, payroll records, accounting records, building records and credentialing and peer review records are subject to confidentiality restrictions and must be stored securely and destroyed in a manner that ensures confidentiality, such as shredding, mutilation or incineration.DocumentationThe Director will develop a log system or control form to document the following steps in the records management process:Transfer of records to storage on or off site;Identification, control and maintenance of current records and records in storage;Retrieval/return of records to/from storage;Destruction of records and deletion from the records inventory.Conflict with Contractual RequirementsTo the extent that contractual records retention requirements exceed the records retention periods listed in the attached retention schedule or specify the retention of documents not listed in the schedule, the contractual requirements will control. Investigations and LitigationUpon the receipt of notice regarding the initiation of an investigation or the service of legal process, the Director shall cease the destruction of any relevant documents pending further notice that the investigation or litigation has been concluded.SAMPLE RECORDS RETENTION SCHEDULES(Legal and Accounting Review required)Records, as used in this Policy, refers not just to paper records but to records in any form or medium including but not limited to computer tape, diskette or other media.Type of RecordRetention PeriodA. Corporate RecordsPermanentIncluding without limitation:Organizational DocumentsArticles of IncorporationBoard of Directors Meeting MinutesCertificate of Incorporation or OrganizationState Licenses, Certificates and Certifications to do businessCorporate Financial ReportingCorporate Election RecordsExternal Audit Reports and Working papersCorporate Policies and ProceduresIncludes policy and procedure manualsPermanentExecutive Correspondence includingExternal correspondence and Internal memos and correspondence, as applicable4 years after fiscal yearInternal Audit Records10 years after fiscal yearAudit Reports of AccountantsPermanentDestruction History FilesPermanentMiscellaneous Daily Schedule SheetsBilling, Accounts Receivable or Payable DocumentsDaily Closing Reports of Cash Received and Billed Charges PostedPayroll Records, Timecards and Worksheets7 yearsB. Bank RecordsCancelled ChecksPermanentDeposit Slips1 yearBank Reconciliations1 yearBank Statements7 yearsElectronic Transfer Documents7 yearsC. Real Estate RecordsDeedsPermanentMortgage DocumentationPermanentTitle DocumentationPermanentClosing documents (purchase or sale documentation)PermanentD. Loan DocumentsFinancial StatementsPermanentNotes Receivable, Ledgers and SchedulesPermanentTax ReturnsPermanentOther Loan DocumentsPermanentE. Employment RecordsThe following documents should be retained permanently for each active employee:Employment ContractsJob DescriptionCumulative yearly attendance and leave recordEmployment notifications[Five] most recent Employee Performance ReviewsCorrespondence pertaining to leave, promotions and appointmentsCopy of Social Security CardCopies of benefitsTermination/Resignation noticeExit interviewPension Application Pension Withdrawal formPermanentEmployee Files of Former Employees7 years after termination of employmentJob applications, resumes, interview records and notes and related materials, whether or not the applicant is hired1 yearF. ContractsGeneral Business ContractsProvider AgreementsLeases10 years after expiration or termination of the contract or according to its terms, which ever is longerG. Insurance Records and PoliciesInsurance and PoliciesPremium recordsContract modificationsCost or pricing dataContract administration correspondenceProgress or status reportsNotice of changes, delays or corrective actionEnrollment Records and Forms7 years after the Certificate has been withdrawn/retired and 7 years after expiration or termination of the policy/contracts or according to its terms, which ever is longerPolicies Issued to [insert business name]Workers CompensationUmbrellaProperty/General LiabilityFidelity & crimeOther third party policiesPermanent H. Quality ControlQuality Assurance/Performance Improvement or Utilization Management Records, including policies, protocols and procedures and Committee minutes10 years10 yearsI. Legal Files and PapersLitigation files including correspondence, depositions, discovery, responses and pleadings as follows:Major litigationCase by case determination to be made by CounselOther litigationOne year after expiration of appeal or time for filing appealsLegal Memoranda, Opinions and general correspondence from counsel5 years after close of subject matter – thereafter, review for utility and historic valuej. General Correspondence Non-essential correspondence(includes letters of non-essential subject matter which require no further action or reference, such as notes of appreciation or meeting plans, form letter, and duplicate copies of internal correspondence)1 yearCorrespondence for Long Term RetentionLetters that constitute contracts or clarify contractual issuesLetters that constitute official documents or clarify issues thereinLetters relating to licenses or permitsLetters denying or affirming liabilityRetention period applicable to the principle record or documentK. Governmental Health or Other Program RecordsFinancial and statistical recordsDocumentation of compliance with consumer rights requirementsBilling materials, business and accounting records and correspondence referring to specific claimsCorrespondence and telephone logs regarding contact with government bill processors or other government representatives regarding billing issuesEOB FormsContractsRelated documents and records10 years (or as otherwiserequired in the applicable contract or law)L. Marketing RecordsCopies of brochures and print advertisements7 years from the use ofmarketing materialM. Patient / Employee Medical RecordsRecords of Adult PatientsRecords of OB PatientsTen years from the date of the last medical service for which a medical entry is required.Twenty (20) years from date of deliveryRecords of Minor PatientsTen years from the date of the last medical service for which a medical entry is required and at minimum two years after the patient reaches the age of majority ................
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