Vendor-neutral archive (VNA) vendors can develop algorithms for meaningful image and report data retention. In the radiology world, the VNA is the system responsible for life cycle management. It has algorithms for data retention and communicating this information to PACS and other systems using vendor neutral standards for communication -- (IOCM-Image Object Change Management).
Dr. Neelam Dugar is a consultant radiologist at the Doncaster & Bassetlaw Hospitals NHS Trust, U.K., and informatics adviser to the Royal College of Radiologists.
The U.K. Information Governance Alliance (IGA) provides guidance to National Health Service (NHS) organizations on retention of patients' health records. They updated their guidance on retention of health records in 2016. Radiological images and reports are classed as a "general health record" in their code of practice.
According to the principles of the Data Protection Act, personal information should be fairly and lawfully processed and processed in line with the data subjects' rights, and it must be adequate, relevant and not excessive, secure, accurate and up-to-date, and processed for limited purposes. Also, it must not be kept for longer than necessary, and should not be transferred to other countries without adequate protection.
Prior to the digital storage of images, the retention of radiology film packets was governed by simple rules of choosing the most suitable of the following dates: eight years since the patient's last visit to the x-ray department, the patient's 26th birthday, or exceptions rules for retention extension (e.g., screening mammography, obstetric ultrasound, etc.).
The IGA 2016 guidance requires adults imaging and report records to be retained "eight years since discharge or patient last seen" in the NHS organization that stores the data. For pediatric imaging and reports, data should be retained until the patient's 26th birthday or eight years since the last visit, in the absence of any exceptions.
Exceptions that require extension of retention period include Creutzfeldt-Jakob disease diagnosis -- 30 years since death, cancer diagnosis 30 years since death, transplantation 30 years since death, continuity of care purpose (in some long-term disease, e.g., slow-growing tumor, chance of recurrence, etc.), 30 years since last visit, screening mammography 10 years since study acquisition date, obstetric ultrasound 26 years since study acquisition date.
To have a robust algorithm for data retention within a VNA, it is important that the VNA receives and stores the date of the patient's last visit to the organization, date of birth, date of death, and date of imaging study acquisition. Data retention and destruction should be governed by the last visit to the organization (ward, accident and emergency, outpatients, or x-ray), and not just the x-ray department. It should be possible for NHS trusts to send visit information to the VNA using standard HL7 messaging.
The IGA guidance deals with the retention of records, but records are not necessarily retained to support clinical management of patients. Some of the retention is related to medicolegal requirements, such as 30 years after death, etc. Hence, it may be sensible to have guidance on how long records need to be kept online, and when they can be taken offline but retained. The film-packet rule of eight years since the last visit to x-ray department can be used to move records offline, as they have worked for many years when no digital record existed.
The full IGA document can be found here.
Dr. Neelam Dugar is a consultant radiologist at the Doncaster & Bassetlaw Hospitals NHS Trust, U.K., and informatics adviser to the Royal College of Radiologists (RCR). This article was written in her personal capacity, and her views and ideas are not necessarily shared by the RCR.
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