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GENERAL MANUAL – POLICY/PROCEDURE
Effective Date: October, 2005
Reviewed:
Revised: September, 2010
Issued By:Senior Management/Health Records Committee/Medical Advisory Committee
Approved by:- General Counsel
Title:-
RETENTION AND STORAGE OF RECORDS
Policy Number: I-i-35-48
Key Words: Health Records, Retention, Storage, Records
Stakeholders:
Patients, Staff
Policy Statement:
Purpose
It is the purpose of this policy to ensure that Mount Sinai Hospital records are retained and stored in a
reasonably secure manner and in accordance with legal requirements.
Definitions
A “record” is any information received and/or created in the course of Hospital operations, in any form or
media, including written, printed, photographic or electronic form, but excluding computer programs and
other mechanisms that produce a record.
An “official custodian” has been assigned to each type of record in this policy. This identifies the department,
unit or individual that has responsibility for the storage and maintenance of documents and other materials in
accordance with this policy.
Procedure
1. All records created, captured and managed within Mount Sinai Hospital must be maintained in accordance
with the applicable period set out in the Mount Sinai Hospital Records Retention & Disposal Schedule set
out in Appendix 1.
2. Retention periods are based on applicable legal statutes, professional regulations, generally accepted
industry practices and established Mount Sinai Hospital policies.
3. In the absence of any of the above, records are kept for as long as required by the purpose for which the
information in the record was collected.
4. Records shall not be kept for any longer than set out in the Retention & Disposal Schedule or as consented
to by the patient unless for the purposes of managing legal risks with the approval of the Office of Risk
Management or if the Hospital receives notice of a court action, investigation, assessment, inspection,
inquest, access request or other inquiry prior to the record’s destruction. All non-clinical records of an
administrative nature that have not been addressed in the Schedule should be retained for a period of no
more than two years.
5. Multiple copies of a single record should not be kept as such a practice increases the chances of
unauthorized use and disclosure of confidential information, places an undue financial burden on the
Hospital and results in an inefficient use of space.
6. During the retention period, records must be stored securely by providing adequate physical security,
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GENERAL MANUAL – POLICY/PROCEDURE
Effective Date: October, 2005
Reviewed:
Revised: September, 2010
Issued By:Senior Management/Health Records Committee/Medical Advisory Committee
Approved by:- General Counsel
Title:-
RETENTION AND STORAGE OF RECORDS
technological security and administrative controls to protect against unauthorized use and disclosure and
the record being lost or stolen.
7. Physical controls may include but are not limited to locked filing cabinets, restricted office access and a
manned reception area to control physical access to a records storage area.
8. Technological security may include but is not limited to intruder detection systems, password protecting
documents and encryption. For more information, please refer to the Appropriate Use of Technology and
Information Security policies.
9. Administrative controls may include but are not limited to prohibiting anyone without an MSH badge from
the records storage area, appointment of a staff member with responsibility for your area’s security,
training on your security measures, confidentiality agreements for outside vendors and auditing of access
to electronic records.
10. The adequacy of any particular security measure is based on the sensitivity of the information and the
risks to which it is exposed.
11. Any storage facilities used for long-term storage of records should have adequate security and climatecontrol standards. If the facilities of an outside agency are used, these requirements should be specified
in the contract. Staff may access the Corporate Privacy Officer to ensure these requirements are
appropriately addressed in any storage agreement.
12. All Mount Sinai Hospital records stored electronically shall be subject to an automatic back-up for file
recovery purposes to protect records from loss or damage.
13. All Mount Sinai Hospital records shall be disposed of in accordance with the Secure Disposal of
Confidential Information policy. In respect of all disposed of Hospital health records the names of the
patients to whom the records relate and the date and manner of destruction shall be recorded.
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Appendix 1
Corporate Records
Type of Record
Agreements/Contracts
Leases/Deeds
Hospital Annual Report
Record Format
Retention
Period
Official Custodian
Statute/Regulation
Hard Copy
Hard Copy
Hard Copy
Permanent
Permanent
Permanent
Responsible V.P.
CFO
President & CEO, VP
for Communications
Limitations Act s. 4 and s. 15
Limitations Act s. 4 and s. 15
Hard
Hard
Hard
Hard
Copy
Copy
Copy
Copy
Permanent
Permanent
Ten Years
Permanent
President
President
President
President
Hard Copy
Permanent
Patient Relations
Administrative By-Laws
Medical Staff By-Laws
Hard Copy
Hard Copy
Permanent
Permanent
Executive Correspondence
Hard Copy
Insurance Policies
Minutes:
Board of Directors
Hard Copy
Date of correspondence plus
minimum 2 years up to 15 years.
Depending on the policy
President & CEO
Senior Vice
President, Medical
Senior Management
Corporations Act s. 300
Corporations Act s. 300
Corporations Act s. 300
Corporations Information Act
s. 5(2)
Corporations Act s. 300
Limitations Act s. 4 and s. 15
Corporations Act s. 300
Corporations Act s. 300
Hard Copy
Committees
Documents:
Documents of Incorporation
Register of Directors
Register of Members
Notices under the
Corporations Information Act
Policies
&
&
&
&
CEO
CEO
CEO
CEO
Limitations Act s. 4 and s. 15
CFO
Limitations Act s. 15
Permanent
Corporate Secretary
c/o M. Harpur
Hard Copy
Permanent
Standing Board Committees
Hard Copy
Permanent
Members’ Meetings
Hard Copy
Permanent
CFO
Corporate Secretary
c/o M. Harpur
Senior Management
Lead
Corporate Secretary
c/o M. Harpur
Corporate Secretary
c/o M. Harpur
Corporations Act s. 299(1) and
s. 304
Income Tax Act Regulations
s. 5800(a)
Corporations Act s. 299(1) and
s. 304
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Corporations Act s. 299(1) and
s. 304
Corporations Act s. 299(1) and
s. 304
Type of Record
Record Format
Retention
Period
Official Custodian
Senior Leadership Committee
Hard Copy
Permanent
President & CEO
Quality and Risk Management
Litigation Files
Hard Copy
7 Years
Risk Management/
Legal Services
Medical Advisory Committee:
Meeting Minutes
Hard Copy
Permanent
Subcommittee Minutes
Hard Copy
Permanent
Senior Vice
President, Medical
Senior Vice
President, Medical
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Statute/Regulation
Corporations Act s. 299(1) and
s. 304
Corporations Act s. 299(1) and
s. 304
Corporations Act s. 299(1) and
s. 304
Financial Records
Type of Record
General
Annual Financial Statements
Record Format
Retention
Period
Official Custodian
Hard Copy
Permanent
Finance
Special Contracts or
Agreements necessary to
understanding general ledger
entries
General Journal
Hard Copy
Permanent
Finance
Hard Copy
Permanent
Finance
General Ledger
Hard Copy
Permanent
Finance
Source Documents (i.e.
records integral to the
creation of financial
statements and tax returns)
Bank Reconciliation
Statements
Hard Copy
Six (6) years from the end of tax
year (fiscal period) to which they
relate
Finance
Hard Copy
10 Years
Finance
Bank Statements
Hard Copy
10 Years
Finance
Cancelled Cheques
Hard Copy
10 Years
Finance
Cheque Register
Hard Copy
Permanent
Finance
Duplicates of Charitable
Donations Receipts (Other
than 10 Year Gifts)
Hard Copy
Two years from end of calendar
year to which they relate
Finance
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Statute/Regulation
Income
Income
s. 5800
Income
Income
s. 5800
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Corporations Act s. 302
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Corporations Act s. 302
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Type of Record
Donation Records (10 Year
Gifts)
General Ledger Interface:
Accounts Payable Receipts
Record Format
Hard Copy
Retention
Period
Two years after revocation of
charitable registration
Official Custodian
Finance
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Tax Act s. 230(1)
Tax Act Regulations
Income
Income
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Tax Act s. 230(1)
Tax Act Regulations
Income
Income
s. 5800
Income
Income
s. 5800
Tax Act s. 230(1)
Tax Act Regulations
Hard Copy
10 Years
Finance
Hard/Electronic
Copy
7 Years
Finance
Hard/Electronic
Copy
7 Years
Payroll
T4/T4A Reports
Hard Copy/Disk
7 Years
Payroll
Time Sheets
Hard/Electronic
Copy
7 Years
Payroll
Deduction Register
Electronic Copy
7 Years
Payroll
Patient Accounts:
Patient Ledger Card
Hard Copy
7 Years
Finance
Cash Receipts Register
Hard Copy
7 Years
Finance
Grant Accounts
Payroll:
Payroll Register
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Statute/Regulation
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Type of Record
Record Format
Retention
Period
Official Custodian
Statute/Regulation
Cash Receipts
Hard Copy
10 Years
Finance
Customer Invoices
Hard Copy
7 Years
Finance
Other Billing Invoices
Hard Copy
7 Years
Finance
Bank Reconciliation
Statements
Hard Copy
10 Years
Finance
Bank Deposit Slips/Books
Hard Copy
10 Years
Finance
Patient Valuables
Envelopes/Security Register
Hard Copy
Intercon Security policy requires:
7 Years
Security
Hard Copy
10 Years
Finance
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Hard/Electronic
Copy
Permanent
Finance
Hard Copy
Permanent
Finance
Income
Income
s. 5800
Income
Income
s. 5800
Revenue Journals:
Accounts Receivable Revenue
Reports and Worksheets
Miscellaneous Accounting
Records
Aging Analysis
Profit and Loss Reports
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Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Private Security and
Investigative Services Act
Regulation 434
Tax Act s. 230(1)
Tax Act Regulations
Tax Act s. 230(1)
Tax Act Regulations
Type of Record
Record Format
Retention
Period
Official Custodian
Statute/Regulation
Budget and Bad Debt Analysis
Hard Copy
Permanent
Finance
Income Tax Act s. 230(1)
Income Tax Act Regulations
s. 5800
Procurement Records
Related to the selection of
supplier:
Scanned Copy
7 Years
Contract
Management
Broader Public Sector
Procurement Directive, April 1
2010
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
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A copy of the procurement
justification or the business case
Information regarding all
supplier consultations, including
any requests for information,
undertaken in the development
of the procurement business case
and/or procurement documents;
Evidence that all required
approvals were obtained;
Copies of all procurement
documents used to qualify and
select the supplier;
Where the procurement was
conducted through a VOR
arrangement, information
regarding the second-stage
selection process used to select
the particular vendor of record;
Where the procurement was
single or sole sourced,
documented justification,
applicable exemptions and
associated approvals;
Copies of all advertisements of
procurement documents;
Copies of all successful and
unsuccessful responses,
submissions, proposals and bids
received in response to
procurement documents,
including the conflict-of-interest
declaration and other attached
forms;
Information regarding any issues
that arose during the
procurement process;
Information regarding all





evaluations of submissions,
proposals and bids received in
response to procurement
documents;
Information regarding all vendor
debriefings including written
documentation of the offer of
vendor debriefing;
Copies of all award letters,
notices and posted
announcements;
Information regarding all changes
to the terms and conditions of
the Agreement, including any
changes that resulted in an
increase in the Agreement price;
Risk assessment information and
recommendations, where
applicable;
Information regarding all
protests, disputes or supplier
complaints regarding the
procurement, including disputes
with respect to the Agreement
contents
Copies of the Agreement
See above for hard copy of
agreement under “Corporate
Records”
Related to the management of
the successful Vendor /
resulting Agreement:
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Information regarding the
management of the supplier,
including how the supplier’s
performance was monitored and
managed and, where applicable,
mechanisms used to transfer
knowledge from the supplier to
organization staff;
Contractor screening decisions,
where applicable;
Evidence of receipt of
deliverables.
Scanned Copy in
Contract
Management
System
Scanned Copy
7 Years
Contract
Management and
General Counsel
Broader
Public
Sector
Procurement Directive, April 1
2010
7 years
Contract Owner
Broader
Public
Sector
Procurement Directive, April 1
2010
Payroll/Human Resources Records
Type of Record
Employee Records:
Canada Pension Plan
Contributions
Designated Substance
Exposure Records
Record Format
Official Custodian
Payroll
Hard Copy
Six years following the year for
which they are kept
40 Years
Employees’ Earning Record
Cards
Employer’s Report of Injury/
Disease (Form 7)
General Employment Records
Hard Copy/
Electronic Copy
Hard Copy
Six years following the year for
which they are kept
40 Years
Payroll
Hard Copy
3 years after creation date
HOOPP Records Individual
Contributions
Electronic Copy
7 Years
Human Resources/
Payroll
Income Tax/T4 Forms
Hard Copy/Disk
7 Years
Payroll
Occupational Health and
Safety Records
EHT Records/Billing Forms
Hard Copy
40 Years
Hard Copy
7 Years
Occupational Health
and Safety
Payroll
Payroll Deduction Authorization Forms
Hard Copy
7 Years
Human Resources/
Payroll
Payroll Journal Sheets
Hard/Electronic
Copy
7 Years
Payroll
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Electronic Copy
Retention
Period
Occupational Health
and Safety
Occupational Health
and Safety
Human Resources
Statute/Regulation
Canada Pension Plan (Canada)
ss. 24(2)
Limitations Act s. 4 and s. 15
Ministry of Labour
Employment Insurance Act
(Canada) ss. 87(3)
Workplace Safety and
Insurance Act s. 80
Employment Standards Act
s. 15(5)
Income Tax Act s. 230
Income Tax Act Regulations
s. 5800
Income Tax Act s. 230
Income Tax Act Regulations
s. 5800
Limitations Act s. 4 and s. 15
Income
Income
s. 5800
Income
Income
s. 5800
Income
Income
s. 5800
Tax Act s. 230
Tax Act Regulations
Tax Act s. 230
Tax Act Regulations
Tax Act s. 230
Tax Act Regulations
Type of Record
Record Format
Retention
Period
Official Custodian
Time Cards/Sheets
Hard/Electronic
Copy
7 Years
Payroll
EI Records
Hard Copy
7 Years
Payroll
Union Dues Deduction Sheets
Hard/Electronic
Copy
7 Years
Payroll
WSIB Invoices
Hard Copy
7 Years
Payroll
Minutes of Joint Health and
Safety Committee
Material Safety Data Sheet
Electronic Copy
Current Year plus Minimum 6 years
Hard Copy
Credentials/Medical Staff Files
Hard Copy
Date of Expiry plus Minimum 2
Years
Permanent
Occupational Health
& Safety
Occupational Health
& Safety
Senior Vice
President, Medical
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Statute/Regulation
Income Tax Act s. 230
Income Tax Act Regulations
s. 5800
Employment Insurance Act
s. 87(3)
Income Tax Act s. 230
Income Tax Act Regulations
s. 5800
Income Tax Act s. 230
Income Tax Act Regulations
s. 5800
Limitations Act s. 4 and s. 15
Limitations Act s. 4 and s. 15
Limitations Act s. 4 and s. 15
Quality and Risk Management Records
Type of Record
Quality and Risk Management
Reports:
Patient/Visitor Incident
Report
Accreditation Survey
Recommendations
Patient Concerns
NRC Picker Patient
Satisfaction Survey Results
Disaster Plans
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Record Format
Retention
Period
Official Custodian
Statute/Regulation
Electronic and/or
Hard Copy
Hard/Electronic
Copy
7 Years
Risk Management
Corporate Policy
7-10 Years
N/A
Electronic and/or
Hard Copy
Hard/Electronic
Copy
Permanent
President & CEO, and
Quality and
Performance
Management
Patient Relations
N/A
Intranet and
Hard Copy
10 Years
Quality and
Performance
Management
Risk Management
7-10 Years
Corporate Policy
Corporate Policy
Patient Care Records and Other Materials
NOTE: RECEIPT OF A COURT ORDER OR NOTICE OF MOTION SUPERCEDES THIS RETENTION PERIOD. NO PATIENT RECORD MAY BE DESTROYED
IF SUCH A DOCUMENT HAS BEEN RECEIVED.
Type of Record
Patient Register
- Patient
- Out-Patient
- Emergency
- Operating Room
- Health Records for
inpatients, day surgery,
emergency and medical
daycare patients
Record Format
Retention
Period
Official Custodian
Statute/Regulation
Hard Copy
50 Years
Health Records
Limitations Act s. 4 and s. 15
Microfiche or
micro roll for
records from
1953 – 1991
28 Years from the last visit
Health Records
Public Hospitals Act Regulation
965 20(3)
Adult (18 years and older)
At Least 5 Years After Day on
Which the Image is Created.
Medical Imaging
Public Hospitals Act
Regulation 965 20(4)(a)
Paper only from
1992 to August
15, 2004
Diagnostic Images (excluding
mammograms)
Diagnostic Images
(Mammograms)
Dual electronic
and paper
formats after
August 15, 2004
Electronic or
Hard Copy
Electronic or
Hard Copy
Children (Less than 18 Years)
At Least 5 Years After the Patient’s
18th Birthday.
Adult (18 years and older)
At Least 10 Years After Day on
Which the Image is Created.
Children (Less than 18 Years)
At Least 10 Years After the
Patient’s 18th Birthday.
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Public Hospitals Act Regulation
965 20 (4)(b)
Medical Imaging
Public Hospitals Act
Regulation 965 20(5)(a)
Public Hospitals Act
Regulation 965 20(5)(b)
Type of Record
Dental X-Rays
Pharmacy Records:
Controlled Drug Records
Inpatient and Outpatient
Record Format
Retention
Period
Official Custodian
Statute/Regulation
Hard Copy
10 Years
Dentistry
Hard Copy
2 Years
Pharmacy
Controlled Drugs and
Substances Act s. 63(b)
Narcotic Records
Inpatient and Outpatient
Inpatient and Outpatient
Prescriptions
Record of Inpatient Dispensing
Hard Copy
2 Years
Pharmacy
Electronic Copy
2 Years
Pharmacy
Drug and Pharmacies
Regulation Act s. 156(2)
Drug and Pharmacies
Regulation Act s. 156(2)
Patient Profile – Inpatient
Copy of Physicians’ Orders
Electronic Copy
Hard Copy
Pharmacy
Pharmacy
Limitations Act s. 4 and s. 15
Cash Register Receipts
Drug Store
Communications:
Paging Records
Hard Copy
Permanent
Year of Record plus Minimum Two
Years
7 Years
Pharmacy
Income Tax Act s. 230
Hard Copy
28 Years
Telephone &
Telecommunications
Corporate Policy
Hard Copy
Hard Copy
Electronic Copy
28 Years
28 Years
28 years
Nursing
Nursing
Nursing
Corporate Policy
Corporate Policy
Per K. Parker
Hard Copy
15 Years
Various Clinical Areas
Nursing Unit Records:
Assignment Sheets
Work Schedules
WIPS
Documentation:
Minutes of Committees
Relating to Patient Care
(Other than Standing
Committees of the Board)
The retail out-patient pharmacy closed as of October, 2008.
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