Closing Hospital Records Considerations – A Brief Checklist

The reality of today’s healthcare ecosystem is that many hospitals are closing. According to Chartis, over 450 rural hospitals were at risk of closingbefore COVID-19 hit. The pandemic has put even more financial pressure on hospitals, putting the risks of closure even higher. If and when a hospital decides to close, there are several considerations administrators should understand and meet statutory retention requirements while providing continuity of care for their patients. We also detail a closing checklist related to these records considerations and budget ranges and the variables that drive it.

Closing Hospital Records Considerations

  • Retention requirements vary by state and by record type from one to more than 25 years. The primary driver of retention length is the age of the patient at time of service and last date seen. This is a complex subject, as it even varies between storage media.
  • Each hospital has a unique mix of patients and media for storing data. For example, an average hospital has a combination of hardcopy and digital records that varies at the department level. Depending on when the hospital stopped producing hard copy medical records, the retention of the paper will vary.
  • Most hospitals have multiple digital systems, both electronic medical record (EMR) software(s) and business records software(s). Every software has a different export process and cost associated with it.
  • There are typically both medical and business records to account for. These have different requirements and applications for records requests after closure.
  • Release of Information is one of the most important ways the hospital can ensure continuity of care for its patients after closure. This responsibility exists until the last record meets its retention, decadesin the future. Therefore, records can’t be treated as a storage problem. They must be efficiently organized to optimize retention and access.

Closing Checklist

  • Notify State Board of Health of intended close date and formulate closure plan
  • Contract with Custodial Records Management (CRM) provider to pack up, inventory, and manage hardcopy and digital, medical and business records through the statutory retention, including Release of Information (ROI) in a HIPAA complaint environment. Current laws restrict what, if anything patients can be charged for copies of records, and this must be addressed prior to contracting with the Custodial Records Provider.
  • Notify patients of facility closure based on state and facility type requirements. This notification should include the direct contact information of the Records Custodian.
  • Pay for Custodial Records services as part of the closing cost of the hospital (often funded through the sale of assets)
  • Authorize transfer of information from hardcopy sources and electronic systems to Records Custodian

It is overwhelming for a hospital to understand what they are required to do, let alone what is best for their patients and then develop a means to provide that in the midst of a radical change like a closure. Sadly, many choose to do very little, and the community suffers for it. It is not just about patients  needing access to their medical records. This also impacts former employees in need of personnel records and former medical staff that require credentialing information to move on in their careers. The hospital ownership itself may also be limited in recovering revenue owed to the hospital or find themselves unable to adequately defend against potential litigation unless the records are properly managed after the facility closes.

We designed our business to help healthcare providers understand the requirements and develop a strategy to efficiently meet them while providing continuity of care for their patients. This means our team guides the hospital through a series of questions to help them develop a strategy and an all-in upfront cost for the solution. When they are ready to move forward, we provide contact information for the hospital to announce to their patients for ROI requests, coordinate the transfer of the hardcopy records, coordinate with the EMR software(s) to export the data into our open source system, then provide HIPAA-compliant ROI services for patients as they need records. When the statutory retention is met for all records, we destroy them. The hospital pays for everything in advance, so they don’t have to think about the records again, and their patients never pay for access. Hospital staff and professionals can all walk away, with peace of mind knowing their records are cared for.

Depending on a series of variables included below, a hospital can expect to pay anywhere from $100,000-$1,000,000 to walk away from their records with no further involvement in patient contact and no additional cost. For example, a 25-bed rural hospital with three electronic systems and 2000 standard boxes of records would cost about $350,000 for them to walk away. If you would ever like to discuss a specific example, I can give you a ballpark on the cost in about

There are several variables that drive the price, including

  • Location for transport
  • Logistics for packing records
  • Hardcopy storage volume
  • Digital storage volume
  • Digital system(s)
  • Retention (largely driven by pediatrics mix)
  • Expected release of information (ROI) volume

For more information, check out our Solutions Brief here. If you need more information or would like to speak with one of our experts regarding your hospital’s closing, contact us today.



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