In a previous article we went through some tips on record keeping within the pharmacy; in today's post, we're going to dig a little deeper into records kept off-site, including those kept by a third-party vendor.
I have managed a pharmacy that had probably never cleaned these records out, and so when I finally got into the online account at Iron Mountain there were almost 500 boxes in storage. I pulled a sample of 10 boxes just to see what they were (it was difficult to tell from many of the descriptions previous employees had put on the boxes) and we had daily logs from over 20 years ago, prescriptions at least 15 years old (including controlled substances prescriptions), and invoices around the same age.
First off - don't do that! Why is it a problem? Here are two big reasons, although I'm sure we could come up with more:
It is expensive to maintain records you do not need (like paying every month to store 15 year old invoices).
In the case of a lawsuit, if you then attempt to destroy old records, it could be considered Spoliation of Evidence.
Basically, as soon as a record can be legally thrown out, if you keep it, it goes from a requirement to a liability. So get rid of them!
Record keeping is easier said than done, though, especially for a busy store with limited time. Here are some tips to efficiently manage records and save time:
Clearly label all boxes
This should be obvious, but boxes need to be clearly labeled so that not only you but other staff members (like a future manager) can easily identify what it is. For invoices, maybe you can put "C3-5 Invoices 4/19-10/19," or prescriptions "Non-control Rx 4/19-10/19."
Basically, you shouldn't have to dig through the box to figure out what's in it. In the case of the 500 boxes, for example, because the descriptions sent to Iron Mountain were vague, the only recourse is to pay for them to pull all 500 boxes, put them in a storage unit where I can go through them, and then separate the ones to be destroyed. Thankfully they provide this level of service (for an extra fee of course), but even so, it was an avoidable hassle and time wasted that I could have spent expanding our pharmacy services.
Sign up for the vendor's online account
If your off-site vendor doesn't have an online account to track everything, you really should shop around. I would have never known there were so many boxes in storage without the account, because the only other records were paper records we had on-site that had passed through numerous managers. to make matters worse, we had switched vendors over that time period, meaning boxes were transferred to Iron Mountain from another company.
Because of all of this, the 500 boxes were what was left after I marked all the boxes I knew could be destroyed from our paper records.
If you must use paper logs to track boxes, get a standardized log with complete information
Do yourself and your future staff a favor and document the boxes well enough they will be easy to tell the vendor to destroy them without having to bring them back into the pharmacy. Mark a destroy date on them and be sure it is done on time (see #4).
Need a log? Check out this one available for download.
Don't store controlled substances records off-site
Yes I know you technically can do it, but why would you want to? Federal law only requires 2 years of records to be kept, and even in states that are stricter than this, it usually doesn't end up being that many boxes. I could still fit all of mine into a small walk-in closet.
Most pharmacies have the space, so keep controlled substance records on-site, and if you need more room, ship out non-controlled records. Even outside of the DEA, Board inspectors want to see those records more often than their non-controlled cousins, and you can help them get what they need faster by having those records ready to go when they come to inspect.
Dispose of them on time
I want to say it one more time to be sure the point sticks: records kept past their destroy date are a liability to you and the company.
For both financial and risk management reasons, get rid of them!
While this post is focused on ensuring you do so for off-site records, the same goes for on-site records. I like to go through the filing cabinet at least once a year (I usually do it at the beginning of the year) to clean it up, and at least every 6 months for boxes kept on-site.
Keywords: record keeping, liability, archived records, record
