CMS requirement for 'fully funded plant to transfer... records to another hospital... if ceases operation'

[Mabel Adams]

Our compliance people are looking at all the CMS regs to make sure we are in compliance. There is one that says we have to keep source and disposition records of all blood products for at least 10 years (which is normal) but then it says that we also have to have a 'fully funded plan to transfer these records to another hospital or other entity if the hospital ceases operation for any reason.' Does anyone know what your hospital has done for this? Is it just a note in a business plan or procedure or do you have to have an item in a budget or what? Does Medical Records have a role? Who's responsible?

[Malcolm Needs ☆]

Our compliance people are looking at all the CMS regs to make sure we are in compliance. There is one that says we have to keep source and disposition records of all blood products for at least 10 years (which is normal) but then it says that we also have to have a 'fully funded plan to transfer these records to another hospital or other entity if the hospital ceases operation for any reason.' Does anyone know what your hospital has done for this? Is it just a note in a business plan or procedure or do you have to have an item in a budget or what? Does Medical Records have a role? Who's responsible?

Much as I would love to work in the USA, there are times when I am sooooooooooooooooooooooo glad I work under the NHS in the UK, where we don't have to worry about such things!!!!!!!!!!!!!!!!!

[PAWHITTECAR]

Ok Malcolm..no need to rub it in.

[Malcolm Needs ☆]

Tee hee!!!!!!!!!!!!!!

:devilish::devilish:

[tbostock]

This is odd. If you had a "fully funded plan" for something that might never happen, you probably wouldn't be closing your hospital.

[Mabel Adams]

Good point, Terri.

[BankerGirl]

This came up on our inspection this year and I added a paragraph to one of our policies as follows:

All blood bank patient and unit records are backed up hourly to a portable hard drive. In the event that the hospital ceases operation, the records from this hard drive will be transferred to a facility designated by Hospital administration so that the required records will be maintained and accessible.

[catmontgomery]

Our blood bank started scanning and editing all original paper documents not in the computer to M-files. This will help until all documentation is done in our computer (ie temperature logs, completed component tags,etc). Documents are an easy look up when this is done.

[Mabel Adams]

Any backup drive has to have software able to access it, right? For a price someone will always convert the database from something only accessible by the BBIS to an Access database or something. Does anyone do that on an ongoing basis for not just patient data but for final disposition of products? We've only done it for computer system changes and data conversion is always part of the new system implementation. We also have a downtime backup system for patient info but it does not contain donor unit source and disposition info and it writes to several PCs on the network, not to a hard drive. BankerGirl, is your hard drive searchable by unit number for a lookback or is it only searchable by patient ID?

[BankerGirl]

Well, I never tried searching for a unit number until you asked, and the answer is no, it is searchable only by patient name. I guess I will add one more thing to my to do list and back up the unit final disposition to that drive as well. It "prints" in a word file which is definitely searchable. Thanks for asking!

[DOGLOVER]

I'm not sure what my facility has done, however I will check. About I was working in a facility that went bankrupt and closed in 1999. At that time the court mandated where the records all went (Iron Mountain, I think) and it was funded by the court allocating the funds from the bankruptcy proceedings. Interestingly, a week after the closure there were 2 lookbacks which I was called back to look up. At that point nothing had been moved so it wasn't a big deal (paper records). Have never heard from anyone again.