The Business, Medical and Legal needs and requirements for the retention of data by healthcare organizations are becoming increasingly challenging. These challenges are further complicated when the applications that produced that data are retired from production. What strategies are available to organizations to meet these needs?
Your data has value. It is comprised of the facts and figures and records that describe your ongoing business. The capture and processing of data enables a healthcare organization to provide care, conduct business, collect and protect revenue and monitor the quality of both clinical and business processes. The RAC initiative will require a deeper divulgence and mining of data than in the past to protect your revenue from take-backs. Your data also protects your coffers from assaults by litigation. Now more than ever, the value proposition your data provides is critical and ever increasing.
The collection and subsequent “care and feeding” of data and the systems that support it are the responsibility of IT. This is a simple task if all of the data is supported by a single, perpetually running application system, but application systems are regularly replaced. The typical life cycle of an application is about five years. External factors affecting the duration of the application life cycle include:
In addition, the requirements/mandates for access to data are becoming more prevalent and recognized by healthcare organizations for the following reasons:
• Litigation defense
• Maximize revenue collection
• Defend against audits and take-backs
• RAC – Recovery Audit Contractors
• Access to old medical records / history
• Research projects
• Sources of data for EMR
So, how long does data need to be retained? And, how do IT organizations keep simple access to data when the application that produced and supported the data has been replaced and is no longer in production?
Typical Retention Periods
While each healthcare organization defines its policies on data retention based on state laws, regulatory requirements and business needs, retention periods are typically within the following ranges:
Revenue Cycle Data
• PFS data... 7-10 years
- MSP specific... 10 years
- RAC... From October 1, 2007
- Federal Payors... 5 – 7 years
- Private Payors... 6 – 7 years
- Medicaid... 5 years
- “OIG” audits... 10 – 15 years
• Registration... 7 years
• HIM... 7 years+ majority
- Release of Information... 20 years
• Nursing... 7 years
• Pharmacy... 6 - 7 years
• Laboratory... 7-10 years
- Mammograms... 10 years
- X-Rays... 7 years
• Respiratory... 7 years
• Bloodbank... 10 years
• Surgery... 7-10 years
• Neonatal... 21 years+ age of majority
- Fetal Heart Tracings
• Mental Health 7 years
• Accounting & Financial... 6 – 10 years
• General Ledger... Permanent
• Journal Entries... 10 years
• Employee records... 14 years
• Adoption records... Forever
Data Retention Strategies
When applications are replaced or retired, access to the required data for the data retention timeframe becomes problematic for the Information Technology departments supporting the healthcare organizations. Options utilized in the past include:
Detailed conversion to new system
• This is a very complex, expensive undertaking and usually leaves gaps in the data from incomplete data matching. Many vendors no longer allow the conversion of data beyond the MPI information in their new system implementations.
Balance forward conversion
• While a simpler conversion effort, all detail is lost leaving the healthcare organization indefensible for audits, take backs, customer service, follow ups, and litigation.
Spin data to reports, microfiche, imaging
• The detailed data is preserved, but accessing the data by users is very tedious and manipulation (reporting) of the data is very difficult.
• Image storage is very inexpensive and relatively simple for the I.T. team. The image solution does not allow for flexibility in data retrieval and can make reporting very cumbersome and labor intensive particularly for the user department that will have to retrieve the information.
Data Warehouse or convert to a self-developed SQL data base
• Building and maintaining a Data Warehouse is very expensive. One site quoted an estimate of $2m for this effort.
• The in-house option requires current staff, or outside consultant to extract data; hardware and software must be provided; the software must be developed and staff allocated to maintain it The timeframe for completion of such a project can be as long 24 months.
Continue to run the applications
Many organizations, not sure what to do, just do nothing and continue to run the applications. This is extremely risky, but also very common as the issue of data retention often is not addressed or recognized until the IT staff is preparing to “shut down” the retired system. Staff must continue to support the application and its infrastructure. Eventually maintenance is often dropped on the application which quickly goes out of support; followed by support on the platform. If an issue arises or there is a hardware crash, it can be extremely expensive to bring about a full recovery.
A new, innovative solution is now available on the market.
In this solution the platform-dependent data, in its original format, is migrated to an off-site facility for ongoing storage and support. User access to the data is provided via secure internet connection. Custom reports and programs can also be loaded. The data is then maintained and managed for you. Immediate savings and benefits include:
• No conversion is required
• There is no loss of detail or integrity
• Labor/personnel costs are reduced
• Capital expenses are reduced
• Seamless access to original data and formats
This web-based access can be available from any type of database or data source and any platform and on-line access to the data is available 24/7. Potential savings include:
• System Administration
• Operating System Software and Maintenance
• 3rd Party Software and Maintenance
• Facilities space
• Hardware maintenance
• Application software maintenance
• Storage and administration of tapes
• Disaster Recovery
Assessing the Value of Data
How do you assess the value of a specific set of data prior to the retirement of an application system?
Interview the CIO and CFO for strategic direction. Then identify the departments affected by the application retirement. These may include IT – both technical and application support, Risk Management/ Legal to identify legal ramifications, Registration, HIM, Finance and Clinical areas. Also identify the cost to continue to run the applications.
Then interview each department to determine what data is currently available and how the data is accessed. Is the data available through any other means? How far back in history do the departments go into the data (this will help identify the appropriate data retention period)? Identify the cost/loss to be expected if the data was suddenly unavailable.
From this exercise, you will be able to determine:
• A reasonable and feasible date to retire the application system
• An appropriate long term data storage mechanism
• The appropriate process for continued user access to the data
• The number users that will need continued access
The residual value of a retired application system is the data it produced and, through an appropriate access method, its:
A carefully chosen solution appropriate for both the user and the technical environments will maximize these abilities.
About Legacy Data Access, Inc.
Knowing that government regulations require healthcare organizations to store patient data for a period of up to 30 years and that a typical healthcare software application has a life cycle of 3-5 years, Legacy Data Access developed a set of tools and solutions and a state of the art data center to assist healthcare organizations reduce their total cost of ownership while maintaining clinical and financial information over the potential 30 year retention period. Legacy Data Access links legacy environments with web-enabled technologies in order to:
With a singular focus on the healthcare industry, Legacy Data Access stores data from systems that are being retired and provides secure, web-based access to the information. Our hassle-free solutions support financial and clinical processes and strategies by maintaining all detail, reducing costs, improving productivity, and maximizing your ROI.
LDA stores legacy application data from any platform including mainframe, Unix, MUMPS and Windows. LDA’s offerings are designed to handle the data retention needs of healthcare organizations of all sizes, types, and complexities.