December is a good time for compliance officers to get out their document and records retention policy and review their electronic and paper information to determine what to keep and purge. Not only should compliance officers go through the information stored in their offices, but they should also check any information that has been sent to off-site storage to determine whether it can be disposed of.
Why have a document and records retention policy?
Developing and maintaining a document and records retention policy is one of the factors of an effective compliance program.
The Health Care Compliance Association and Office of Inspector General’s Measuring Compliance Program Effectiveness: A Resource Guide mentions record retention four times. According to the guidance, compliance officers should validate the organization’s standards, and policies and procedures, including a record retention policy and that key documents—such as exclusion screening records and documentation of corrective action during investigations—are maintained in accordance with that policy.