Survey Report 2008 - Storage and Disposal of Health Organisations

This is a short report on an online survey conducted with 10 Health organisations between April and July 2008. The survey sought to identify the nature of arrangements and the cost of storing non-current [1] paper records and the level of implementation of records retention and disposal authorities.

The basis of the survey was provided by the Ministerial Memorandum M2007-08 (Efficient and Cost Effective Management of Records) which requires Area Health Services and agencies to respond to such requests from State Records for information on records storage arrangements, costs and potential savings. In addition, section 12(4) of the State Records Act 1998 requires each agency to report on its records management program in accordance with arrangements made with State Records.

The survey was designed to provide State Records with necessary baseline data on the

quantities of non-current records stored by health organisations
the costs of storage, and
how many boxes of non-current records had been sentenced for eventual disposal.

The survey was quantitative and provided results and information which will be applied to the Disposal Implementation Improvement Program to assist health organisations to undertake disposal projects aimed at improving practice and making savings, through the destruction of records and the transfer of designated State archives to State Records.

Survey pool

The survey was distributed to 10 health organisations, including 8 Area Health Services. We received a 100% response rate to the survey.

State Records would like to thank all public offices for their cooperation and participation in the survey. The information we have gathered will be very useful to the Disposal Implementation Improvement Program.

Identifying non-current records

The survey pertained only to non-current records stored by health organisations, that is only those records which were no longer required for current business. Identifying non-current patient/medical records did pose some issues for survey participants.

Determining whether an administrative record is non-current, is a fairly straight-forward process; non-current administrative records are consulted infrequently, are no longer required for current business, and are generally retired from the current records system to another location. Determining if a patient/medical record is non-current is not as simple.

Generally non-current patient/medical records are those records which are no longer required for the treatment of patients and have not been accessed within the last 10 years, that is, the patient has not re-presented for treatment. For Group A hospitals (ie. ‘teaching’ hospitals; principal referral, paediatric and acute care hospitals) the re-presentation period is extended out from 10 years to 15 years. Thus, if the patient has not re-presented for treatment in the 10 – 15 years since last presentation, then the record can be culled from the active filing system and sentenced for disposal. Non-current patient records are generally removed from the active filing system and located in another storage location. However in some rural based facilities, non-current records have not been culled out and are located within active records systems. For such circumstances, the questionnaire provided a means for calculating approximately how many non-current patient/medical records are held.

Records storage

On 1 January 2008, health organisations stored a total of 596,068 boxes of non-current paper records. This includes 147,895 boxes of administrative records (25%) and 448,173 boxes of patient/medical records (75%). The total cost of this storage is estimated at $2.7 million per annum; $657,903 (25%) on the storage of administrative records and $2 million (75%) on the storage of patient/medical records.

It should be noted that a number of organisations had difficulty in providing accurate information about costs for records storage. Generally, where an organisation receives an invoice for a service such as the storage of records, information about upfront costs were provided. However, where an organisation owns or leases premises, records staff were usually unable to provide information on costs for storage. For these situations, State Records applied a standard commercial storage rate to records stored at warehouse-type facilities owned / leased by organisations and in office accommodation located within medical facilities. It is likely that estimates for storage costs are conservative.

From the information provided, we learned that the majority of non-current paper records are stored in offsite storage – 50% at commercial storage providers and 18% in warehouse facilities owned / leased by the organisation. 32% of non-current paper records are stored in office accommodation.

The survey data revealed that most health organisations use a mix of storage options and that health organisations have generally moved paper administrative and patient/medical records to cheaper offsite storage and generally only store a small quantity of non-current paper records onsite.

	Commercial storage	Warehouse storage	Office accommodation	Total
Administrative records	48, 660 (33% of admin records stored)	52,170 (35% of admin records stored)	47,065 (32% of admin records stored)	147,895 boxes of admin records
Patient/medical records	246,931 (55% of patient records stored)	58,810 (10% of patient records stored)	142,432 (32% of patient records stored)	448,173 boxes of patient records

Commercial storage

All health organisations use commercial storage to store non-current records, with most organisations using such storage to store both administrative and patient/medical records. Health organisations use commercial storage facilities located in metropolitan Sydneyand regional/rural locations.

Facilities owned / leased by the organisation

7 health organisations use warehouse storage owned or leased by the organisation to store non-current records. Such facilities can include de-commissioned buildings or hospitals or outbuildings.

Warehouse storage is predominately located in regional/rural locations. Interestingly, one Area Health Service, due to its geographical spread stores non-current records in warehouse storage in both Sydney and regional/rural locations.

The quantities of records held in warehouse storage are generally much smaller than the quantities in commercial storage.

Office accommodation

9 health organisations store boxes of non-current records in storage space/s within their office accommodation. This type of storage space may include unused office space or unused space in hospital/medical buildings, basements, or carparks. It is likely that some office accommodation used to store records is less than ideal for the long term storage of records.

The quantities of records held in office accommodation are generally much larger than those stored in warehouse storage.

Other storage locations

The survey sought to identify if non-current records were stored in temporary storage locations other than commercial storage facilities, warehouse facilities or in office accommodation. Survey participants answered:

5 organisations use shipping containers as a temporary storage location
3 organisations use demountables, and
4 organisations advised that they use a range of buildings (including sheds, disused buildings such as former Nurses’ Homes, and cooler rooms) as temporary storage locations.

Implementation of records retention and disposal authorities

Health organisations have been authorised to use general retention and disposal authorities for the disposal of records, including two specific general retention and disposal authorities for health organisations (Public Health Services: Patient/Client records (GDA 17) issued in 2004 and Public Health Services: Administrative Records (GDA 21) issued in 2005.

Using authorised disposal authorities and sentencing records establishes a disposal date for the record or a ‘trigger’ for its physical destruction or transfer to the archives. Without such triggers, records remain in storage for unlimited periods of time.

Organisations which have sentenced records have provided a mechanism for their ongoing management. We were interested to learn how many non-current administrative and patient/medical records in storage are sentenced and thereby have the triggers in place for their ongoing management and eventual disposal.

The results in this section of the survey are of interest. Only 31% of non-current administrative records in storage have been sentenced, whereas 58% of non-current patient/medical records have been sentenced. It should be noted that two Area Health Services have sentenced all non-current patient/medical records.

The results indicate that there is a low level of sentencing of non-current administrative records in storage. This has a potential to impact on cost effective storage for health organisations.

Without sentencing, health organisations cannot plan how long administrative records have to be stored, cannot dispose efficiently of time expired records and cannot manage or reduce storage costs. Until sentenced, these administrative records can not be disposed of nor can storage costs be reduced.

A failure to sentence administrative records held in storage also has an impact on good records management. Health organisations which have sentenced records located in storage have provided a mechanism (disposal triggers) for the ongoing management of records and their eventual disposal. These organisations are able to plan their storage needs, including

undertaking regular destruction of records which have been retained for the correct retention period and have now expired
planning current and future storage needs, including anticipating growth in storage accumulations
regular and timely transfer of records, as State archives, to State Records, and
minimising costs.

In contrast, the survey results demonstrate that in general, health organisations have a high level of sentencing of patient/medical records. This is an interesting result considering the nature of the patient/medical record. Generally, patient/medical records are sentenced once the 10 – 15 year period after last presentation has lapsed. An added complexity for sentencing is the potential for a patient to re-present for treatment requiring the record to be reactivated, and thus the ‘disposal trigger’ re-calculated. The generally high level of sentencing indicates that most health organisations are working well on managing the retention and disposal of the health record.

It is likely that many of the unsentenced records in storage are due to poor sentencing practices in the past, with many organisations failing to sentence records before they transfer them to storage, thus resulting in a sentencing backlog. The recent administrative changes in the health sector may have also had an impact on rates of sentencing.

Accumulations of unsentenced records in storage

All survey participants have accumulations of unsentenced records in storage. These accumulations range from very small quantities to significant quantities. 49% of records in storage have not been sentenced.

Reducing accumulations

It is clear that improvements can be made by health organisations through the application of general retention and disposal authorities to records, particularly to administrative records. This has the potential to reduce storage costs and make cost savings across Government.

Raising the level of implementation of disposal authorities will require resources (staff and budget allocations) to address the accumulations in storage that are unsentenced. In order to address these issues, some organisations will need to establish large-scale projects to deal with unsentenced records, including recalling boxes of records from storage so that they can be sentenced accurately. The main barriers to such projects are the large costs involved (retrieval of records from storage, office space to undertake sentencing work, and staff costs) and the lack of experienced sentencing skills amongst personnel.

Essentially, health organisations will need to identify those records requiring sentencing and then undertake projects to sentence and dispose of these records. Sentencing will often result in immediate disposal of some time-expired records and will set a trigger for the management of other records.

It is also important that health organisations retain records for the appropriate periods of time prescribed in the general retention and disposal authorities. In attempting to reduce costs of storage through disposal, it is not preferable that health organisation seek a ‘quick fix’ by disposing of records earlier than retention periods and creating potential risks for the organisation. An added issue for health organisations is the unpredictable nature of the patient/medical record and the potential re-activation of the records.

With an appropriate sentencing strategy, regular disposal programs and sensible storage strategies, health organisations can be sure that they are retaining the records they need and are allocating the appropriate resources to managing and storing those records.

Next steps

The survey findings show that there are potential gains to be made by health organisations

undertaking sentencing at the point of creation (for administrative records particularly)
planning and managing records storage
tackling unsentenced accumulations of records, and
planning and managing disposal programs.

State Records has commenced working with NSW Health to improve the level of disposal implementation in health organisations.

[1] Non-current records are those records that are required infrequently for the conduct of day-to-day business and have been transferred from an organisation’s office space to a secondary storage area (in-house or off-site) or to a commercial storage facility.

Published December 2008

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