ALCOAST 102/21 - MAR 2021 COVID-19: HEALTH RECORD DISPOSITION DELAYS DUE TO COVID-19 PANDEMIC

R 151243Z MAR 21
FM COMDT COGARD WASHINGTON DC
TO ALCOAST
BT
UNCLAS
ALCOAST 102/21
SSIC 6000
SUBJ:  COVID-19: HEALTH RECORD DISPOSITION DELAYS DUE TO
COVID-19 PANDEMIC
A. Coast Guard Medical Manual, COMDTINST M6000.1 (series)
B. Disposition of Health Records, COMDTINST M6150.4 (series)
C. DOD Health Record Lifecycle Management, DODI 6040.45
1. REF (A) through (C) provide policy guidance for health
record disposition. The COVID-19 pandemic has significantly
impacted the CG Central Cell Records Processing Center’s
(RPC) ability to meet these requirements. The most significant
constraint has been the closure of the National Archives Records
Administration’s (NARA) National Personnel Records Center (NPRC),
the organization that has been digitizing the CG Service Treatment
Record (STR) for electronic archiving. NARA NPRC also stores CG
archived paper health records after the record is cut-off, which
is when a service member (SM) separates or retires from service.
Due to the COVID-19 pandemic, NARA suspended reproduction and
digitization services in March 2020. Additionally, NPRC, the
entity that stores the archived health records, has been closed
and is not accepting shipments of records.  
2. HSWL SC Central Cell RPC has ceased processing of records
due to these closures. This is significant for individual SMs,
as the CG is unable to electronically upload STRs into the Health
Artifact Imagine Management System (HAIMS) document management
system, which is a system that is interfaces with the VA Veterans
Benefit Management System (VBMS). BMS is the electronic document
storage information system that enables the VA claims process. 
3. CG SMs separating or retiring are encouraged to get and/or
make a copy of their STR and file for VA benefits as per
processes outlined at the VA/DoD eBenefits Portal:
https://www.ebenefits.va.gov/ebenefits/homepage. Additionally,
those members separating or retiring within 90-180 days can
utilize the VA Benefits Delivery at Discharge (VA BDD)
enumerated at:
https://www.benefits.va.gov/BENEFITS/factsheets/general/
BDDFactSheet.pdf.
4. The following recommendations are applicable to all SMs,
regardless of when they decide to file a disability claim with
the VA:
   a. Make/obtain a personal copy of the CG health record prior
to separation.   
   b. Personally ensure all care notes from health care providers
that do not work within a CG clinic are provided to the respective
health record custodian for inclusion in CG health record. SMs may
encounter difficulty in obtaining these records after they separate
or if too much time has passed.
   c. Contact a Veteran's Service Organization for assistance in
navigating the VA claims process.
5. As per REF (A), health records are the property of the Federal
government, thus, SMs must not maintain custody of their original
health record. 
6. HSWL Service Center is sourcing alternative means for health
record digitization to enable electronic archiving within HAIMS;
however, lead time for implementation is expected to be, at a
minimum, 5 months.
7. For general policy and procedural questions, contact the
HSWL SC Medical Administration Division health records management
team: D05-SMB-CGHealthRecords@uscg.mil.
8. POC: CDR Leah Preston, HSWL Service Center Medical
Administration Division, 757-628-4362, Email:leah.m.preston@uscg.mil
9. RADM Dana L. Thomas, Director Health, Safety and Work-Life
(CG-11), sends.
10 Internet release is authorized.