Georgia Health Services Network

MEMORANDUM
FROM: TO: DATE: SUBJECT: Sarah Wissing Carolyn Williams, Administrator November 19, 2012 FEASIBILITY REPORT FOR DISCHARGE CHART FILING

Introduction
For the discharge client file storage we currently use a filing system that constitutes of fifty-six boxes labeled alphabetically and organized on top of the current client file cabinets. The system is not functional due to the lack of accessibility and time stamping of the files. HIPAA requires that we keep medical files for a minimum of seven years. The current filing system provides no information for how long we have been storing the files. We also have outgrown the current filing system. The fifty six boxes are full and we have no place to store any additional boxes. Because of this, files are not getting stored, which puts us at a liability if inspected by the state. Several options have been taken into consideration for the office. These are: On site storage, no digital backup On site storage, with digital backup In house, off-site storage, with digital backup Outsourced offsite storage, outsourced digital backup

To determine if any of these systems would be functional for our office, I have conducted thorough research on the legality, ease of implementation, cost, and functionality of each prospective system.

Overview of Alternatives
There are a total of four alternatives to fix the current filing system. Each alternative has been evaluated for feasibility:

Option 1: On Site Storage, No Digital Backup This alternative would satisfy the general preference that the files be stored on site. With this alternative the files would be stored in file cabinets at the Georgia Health office. When a file

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needed to be accessed an employee would pull the physical file because there would be no digital counterpart to the discharge files. Option 2: On Site Storage, with Digital Backup This alternative would also keep the files stored on site. However, with this option, a digital backup file would also be kept. These would be stored on a secure, online cloud storage site maintained by Georgia Health. The physical files would be time stamped and stored in the attic space of the office. This eliminates the need for file cabinets. Option 3: Off Site Storage, with Digital Backup With this system, the files would be secured at a local storage center in time stamped boxes. The files would be accessible through a secure, online cloud storage site so that the physical files would not need to be retrieved when needed for consultation. Both the digital backup and off-site storage would be Georgia Health run. Option 4: Outsourced, Offsite Storage, with Outsourced, Digital Backup This option would involve Georgia Health outsourcing the filing system to a third party company. This company would handle scanning all of the charts so that Georgia Health would have access to the files at all times through a database. They would also handle the secure storage of all of the physical files at an off-site location.

Criteria
Each alternative has been evaluated based on the following four criteria. Each criterion holds weight in the final decision, with cost holding twice the weight of all other criterion. Legality Each alternative has been evaluated for legality. The standards to satisfy HIPAA have been researched and recorded. These standards are: No patient files will be accessible to the general public Files must be stored in a secure manner (locked file cabinet, etc) Online storage must be secure and private

Each of these components must be satisfied to protect Georgia Health from litigation. Ease of Implementation Because of the systems complex nature, the ease at which each alternative can be implemented must be considered. This was done by calculating the number of hours of employee

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labor it would take to implement each option. Training time was also taken into consideration. These were then added together and evaluated. Cost Each of the four options has been evaluated for cost. The initial investment, installation cost, and maintenance cost have each been calculated and added together to form an overall cost analysis. Maintenance was calculated for a five year period. Functionality Each system has been evaluated for functionality. This stipulation analyzes the ease at which the files can be accessed and time stamped. Through a phone interview with Amanda, Candace, and Cathryn, I discerned that the discharge files needed to be accessible from the office. Also, Medicaid requires that discharged client files be kept for a minimum of at least seven years, after which they can be destroyed. Each criterion was analyzed to assess how easily these stipulations could be accomplished.

Method
I approached the research for this project in two steps. First, I gathered the legal requirements that were required for the storage of medical files. Secondly, I evaluated each of the criterions through a series of steps: Legality The first step that I conducted was to evaluate the legal requirements for storing medical files. I did this by using the government website for HIPAA (link found below). The Security Rule stipulation provided critical information. Each option was analyzed for legal risk by comparing the storage type to the criteria of HIPAA and ranked on a scale of 1-5 (five being the most legal risk). http://www.hhs.gov/ocr/privacy/hipaa/administrative/securityrule/securityruleguidance.html Ease of Implementation Ease of implementation was calculated by the following formula: (Training Time + Implementation Time)= Hours of Lost Labor

This formula yields the lost labor time of implementing the project. The lower the value, the better the alternative scored.

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Cost To evaluate the cost of each system, I researched the acquisition, installation, and maintenance cost of each alternative. Because there are many different storage centers and filing cabinets, I took a sample of two from each category and averaged the costs to find an average cost for each component. I obtained a quote from Shoreline Records Storage to estimate the cost of outsourcing. I then added the three components together to get a total cost. Finally, I plotted the points on a graph to determine the most cost efficient option. Functionality Functionality was the simplest to evaluate. I evaluated this by subjecting each of the alternatives to two questions: 1. Can the files be accessed from the office? 2. Can the files be time stamped and destroyed after seven years? Each question was answered to a simple yes or no. If both were answered yes, then the solution passed the functionality test. To further evaluate the functionality, I researched how easily each method could be time stamped and destroyed.

Evaluation
Legality Option 1 was rated a 1 for legal risk. HIPAA certified file cabinets are easily procured from retailers. Option 2 was rated a 3 for legal risk. Storing files on site constitutes minimal risk. Both of the researched digital options meet the HIPAA requirements but when storing files online there is always a chance for a security breach. Option 3 was rated a 5 for legal risk. Storing files off site at a self-storage center constitutes a high risk for potential privacy violations. Self-storage units can be unreliable and are not recommended for medical storage. Option 4 was rated a 3 for legal risk. The companies that outsource medical filing are trustworthy, but there is always risk when choosing to outsource.

Ease of Implementation

Lost Labor Training (hrs) Implementation (hrs)

Option 1 0 12

Option 2 3 42

Option 3 3 46

Option 4 3 0

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60 40 20 0 Option 1 Option 2 Option 3 Option 4 Hours of Lost Labor

Option 1 has the lowest training time. This is because the file cabinets are a continuation of the already in place current client system. The only time that is lost is when the physical files are transferred from the boxes to the cabinets. Option 2 and Option 3 have by far the highest implementation time. This is because of the time it takes to scan the files in order to digitally store them. It is estimated to take 42 hours to scan all of the 500 files to the storage. Each file takes about 5 minutes to scan. It is estimated to take 3 hours to take all of the files to the local storage center for Option 3. This gives Option 3 a completion time of 48 hours including the 3 hours built in for training the employees. Option 4 has zero implementation time because the outsourcing company scans and stores all of the files. Cost

Costs (in dollars) Acquisition Installation Maintenance Total Cost

Option 1 1100 220 1450 2770

Option 2 50 420 1281.47 1751.47

Option 3 97 490 4101.47 4688.47

Option 4 8000 0 8110 16110

Total Cost of Project

$20,000.00 $15,000.00 $10,000.00 $5,000.00 $Option Option Option Option 1 2 3 4
*Maintenance was calculated for a 5 year period * Installation was calculated by multiplying the estimated time of installation*employee hourly wage

Total Cost (dollars)

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Option 1 had the second lowest total project cost. The file cabinets cost an average of $600 a piece, and we would need two to implement the project. We would also have to purchase one more file cabinet within in the five year maintenance period as more clients discharge. Option 2 is the cheapest option. Maintenance is the most expensive portion of the alternative because of the digital storage. The digital storage costs an average of $21.36 per month, so for five years it would cost $1281.47. The acquisition cost includes the fees of the digital storage company and the cost of three sets of files storage boxes. Option 3 was the third cheapest option. The offsite storage would cost an estimated $47 per month ($2820 for 5 years). This added to the $1281.47 cost for digital storage gives you maintenance cost. Option 4 was by far the most expensive option. By calling Shoreline Records Management I obtained a quote that yielded the estimated total cost of $16110 for 5 years. Functionality Each alternative passed the functionality test. In each option the files can be accessed from the office, whether digitally or physically. Option 1 requires the files to be accessed physically. In the other three options, the files are accessed digitally. Option 2 is the easiest to access, because you can not only reference the digital file, but if for some reason the physical file needs to be consulted then it is on site and available to reference immediately. Each alternative can also be time stamped. The easiest to time stamp is Option 4. Shoreline would time stamp and destroy the medical records after a time specified by Georgia Health. In Option 1, the filing cabinets would be organized alphabetically, so an employee would have to hand pick files once a year to shred. Options 2 and 3 would be time stamped by box, and could easily be picked out and destroyed after seven years.

Conclusions
Legal The least legal risk was found in Option 1. Because of the onsite storage the risk is minimal. The files can be contained without any risk to privacy. Options 2 and 4 were both rated a three for average risk because of the online storage component. Security breaches are always a risk when storing files online. Option 3 was rated very high risk because of the unpredictability of self-storage units. Ease of Implementation The easiest system to implement would be Option 4. Other than 3 hours of training, no employee time is taken up. Options 2 and 3 would take up the most time because of the initial scanning of the files. This process would be very time consuming and would take a significant amount of time to implement (approximately 42 hours). Option 3 would also include 3 hours of employee time to transfer the boxes to the storage center. Option 1 ranked in the middle for ease

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of implementation. The files must be transferred into the file cabinets from the boxes, but the time is only estimated to be 12 hours. Cost The most cost efficient alternative was Option 2. The acquisition and maintenance costs are lower than any other option. Option 1 would be the second cheapest alternative. The file cabinets cost about $600 a piece but would be cheaper than having to pay a monthly storage fee as you would in Option 3. Option 4 was by far the most expensive, outweighing the second most expensive option (Option 3) by more than $11000. Functionality Options 4 scored highest for functionality. Because it is outsourced, no employee time is used to timestamp or dispose of files. Options 2 and 3 are tied for a close second. Each could be easily time stamped without any complications. Option 1 takes the most effort to time stamp, because an employee would have to hand select out files to shred, rather than be able to select entire boxes to dispose of.

Recommendation
I recommend that we implement Option 2, on-site filing with digital backup. Not only is this the most cost efficient method it also ranks very high in functionality and constitutes very little legal risk. While it does require significant implementation time, once the system is running it will require very little upkeep. Option 3 constitutes too much of a legal risk to be a functional system. Self-Storage units are not recommended by HIPAA guidelines. Option 4 would easily be the choice except for the cost. For a small business such as Georgia Health, it is simply not cost effective to implement such a system.

Bibliography
"Georgia Health Discharge Files." Telephone interview. 28 Oct. 2012. "Health Information Privacy." Health Information Privacy. U.S. Department of Health & Human Services, n.d. Web. 01 Nov. 2012. http://www.hhs.gov/ocr/privacy/index.html "How It Works." Leaders in EMR Backup Solutions for Medical Records Storage and Medical Record Retrieval; Proven Backup. Proven Backup, n.d. Web. 29 Nov. 2012. <http://www.provenbackup.com/products/how-it-works/.>

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"Lateral File Cabinet, Stak-N-Lok - 100 Series." Office Lateral File Cabinet. N.p., n.d. Web. 29 Nov. 2012. <http://www.furniture-online.com/product/SN100BN/Office-Lateral-File-Cabinet--DatumBINDER-SIZE-Lateral-Medical-File-Cabinet.html>. "My Vault Pricing Plans." My Vault : Pricing. N.p., n.d. Web. 29 Nov. 2012. <http://www.myvaultstorage.com/pricing.php>. "Shoreline Medical Records." Telephone interview. 20 Nov. 2012. "Walton Security Storage(U-Haul Neighborhood Dealer)." U-Haul: Locations: Self Storage in Monroe GA. N.p., n.d. Web. 29 Nov. 2012. <http://www.uhaul.com/Locations/Storage-nearMonroe-GA-30655/048503>.