Abandoned Records Case Study
September 5, 2019
In a previous PRISM International blog, there was a discussion related to RIM providers responding to issues of abandoned records within a record center. As a follow-up to that discussion, it is important to address that it is not a matter of if – but a matter of when a record center and team will be faced with abandoned client records, and what to do when this happens. As increasing volumes of data are born digitally, clients may perceive stored archival records to be of less value to the business entity. A business possibly maintains closed records based on a mandated retention period. If the business has not accessed stored records for an extended period, the perceived business/clinical value declines drastically.
This actual case review should reinforce the need for solid, legally binding contracts, and standardized operating procedures. When reviewing the critical path of this “real-life” incident, it does reinforce that a plan of action, diligence, and sometimes a plain “stick with it” attitude does prove beneficial in the RIM industry.
Service Proposal
CRMI was asked to provide a proposal to a Pediatric Physician who was closing a practice after 18 years. The physician was joining a large, multidisciplinary practice, and staying in the vicinity. The service proposal included removing all patient files from shelves and indexing files with name, date of birth, and last date of service. Additionally, there were numerous boxes of closed, out of service files to be retrieved, indexed, and stored. This was an enormous undertaking. The project proposal, when presented, was costly for the client (physician). Approval to begin the project was received, and up-front project costs for labor, boxes, and transport were billed immediately. A fifty percent project initiation fee was paid by the physician and the project balance paid promptly at completion. The management plan included the client managing patient requests via a team member in the new practice setting. Those requests would be verified and sent to CRMI for processing. CRMI would manage the retention period as defined by applicable state standards and approved by the physician. A process was defined to comply with the retention periods for the pediatric records and ensure the client would authorize destruction of records when notified by CRMI. Per contract, all services related to patient/authorized requests, ongoing storage, destruction, inquiries, and other health care provider requests would be billed by CRMI monthly. Invoices due upon receipt.
Immediate Management Progress
The operational components of the physician office project were well orchestrated and patient requests were processed smoothly. Initially, no alarm bells were sounded by the CRMI accounting department, and invoices were paid per the terms of the contract. Requests for patient records had been processed according to plans. Caregivers, as identified by the physician client had been notified that CRMI would be managing the patient record requests in the case of routine and/or emergency care. Upon initiation of the project, CRMI acquired a written document from the client indicating that in cases of emergency, CRMI could verify authorized access, scan, and send encrypted documents to the specific requestor. All requests and authorization documents were recorded in the patient file as directed. Five months later the storm began to brew!
The 1st Red Flag came when a local health care provider called the CRMI office indicating they needed a chart for a patient in the Emergency Department (ED) at the hospital. They had been unable to locate the pediatrician (the CRMI client), and indicated it was a matter of extreme urgency. During the conversation with the requesting ED Physician, he indicated he had been unable to reach the client by office phone or mobile number. Understandably, the emergency team was agitated. The request by the Emergency Department Physician was ultimately documented and completed. Later, the incident was reviewed in the monthly CRMI management team discussion regarding customer service initiatives.
At the time of the team meeting there was not an issue for CRMI regarding the client account receivables. Invoices were being paid on time. Operations proceeded to verify the contact information on file to ensure continuity for patient record requests per the agreement. During this verification process came the 2nd Red Flag. It was discovered that the client was no longer affiliated with the larger multidisciplinary practice. The manager of that practice advised CRMI that the physician (CRMI client) had relocated to Florida. No forwarding information was available from the manager. CRMI initiated their own research. The client mobile number was still operational, but now the physician would not return messages left by the operations or accounts receivable team members. Subsequently, CRMI began to have delays or non-payment of invoices. This occurred six months after the initial project was completed. Local health care providers continued to express frustration with the inability to reach the physician. CRMI was caught in the middle of the dilemma and continued to provide requested records.
Aggressive Plan of Action
The Records & Information Management (RIM) team met and determined a more aggressive plan of action was warranted. Since the client would not communicate, nor had the client provided updated contact information, a call was placed to the local State Medical Licensure Board. The case was presented via phone and direction was provided from the advisor of the board. While a medical board does not get involved with collections, it will respond to information regarding the abandonment of patient records. A relocation address for the client to a medical practice in Florida was provided by the board. Contacts with the Florida medical practice confirmed that the physician was no longer with the practice and had only been affiliated with their location for two months. When asked if any other information could be provided, there was a reference to the physician (client) relocating to California.
To bring this saga to a close, a message was placed on the client’s mobile number by the CRMI President indicating two things must immediately occur. First, CRMI should receive a certified check for the full amounts of invoices outstanding within three days. Second, that the local State Medical Board, as well as those of Florida and California had received verbal and written notification of abandonment of medical and business records by the physician. Within twenty minutes of leaving this message on the mobile number, a call was received. The physician client was outraged that this type of action by CRMI would occur. They described the notification of the medical Bboards by CRMI as unprofessional. At the time it seemed like a very “skewed” perception of professional standards on the part of the client. CRMI received full payment in 72 hours via wire transfer.
The contract information received from the client was updated in the CRMI systems and assurance was given that future service invoices would be paid in a timely manner. If all future invoices were not paid in a timely manner, CRMI would immediately notify the medical boards of an abandoned records situation. The client was advised that the contact information would be provided to requesting medical professionals in order to ensure continuity of care as described in the original client contract.
When addressing abandoned records, collections, or other situations within the professional records and information management arena, reacting quickly and concisely is key. Team members should understand and consistently apply standard operating procedures. A documented and legally binding contract is critical to successful closure.
By: Gail Bisbee, RN, BSN, PRISM/SME