ALCOAST 076/24 - FEB 2024 DIGITIZATION AND LONG-TERM STORAGE OF PAPER HEALTH RECORDS UPDATE

R 121627Z FEB 24 MID600117180332U
FM COMDT COGARD WASHINGTON DC
TO ALCOAST
BT
UNCLAS
ALCOAST 076/24
SSIC 6000
SUBJ: DIGITIZATION AND LONG-TERM STORAGE OF PAPER HEALTH RECORDS
UPDATE
A. COMDT COGARD WASHINGTON DC 061835Z SEP 23/ALCOAST 315/23
B. Paper Health Records Data Digitization Procedural Guidance,
EHRAPMO-PG-23-002
C. HIPAA Privacy Rule, 45 CFR 164.524
1. This ALCOAST provides an update to REF (A) to inform service
members and healthcare staff of updated efforts to digitize legacy
paper health records and clarify the prioritization process for
personnel requests to obtain copies of health records. This
information is provided to increase patient awareness and assist
communication between patients and healthcare staff to best support
our servicemembers.
2. STATUS OF THE PAPER HEALTH RECORD DIGITIZATION PROCESS: The
effort to digitize paper health records began in November 2022 and
is scheduled to conclude in April 2024. As of December 2023, most
paper health records from clinics, sick bays, and Unit Record
Custodians were collected, cataloged, and backed-up, and the
originals consolidated at a central repository in accordance with
REF (A). A small portion of CG Paper Health Records remains under
the Defense Health Agency (DHA) custody until arrangements can be
made to transfer them to the Coast Guard service for digitization
processing. Paper health record digitization has taken longer than
expected due to the complexity of record preparation prior to final
upload into the Health Artifact and Image Management Solution
(HAIMS). After digitization and upload to HAIMS, all paper records
are placed into long-term storage until such time as DHA authorizes
final disposition. Prior to final disposition, an audit must be
passed to ensure all records have been fully digitized.
3. AVAILABILITY OF HEALTH RECORDS FOR DELIVERY OF CARE: Healthcare
providers across the USCG healthcare enterprise have established
processes to view complete patient health records to deliver care.
These processes also include requests for specific parts of a health
record required for ongoing care. This guidance was previously
promulgated to clinics via REF (B). The guidance can be found on the
following website:
(Copy and Paste URL into Browser)

https://uscg.sharepoint-mil.us/:b:/s/cg9/3/3/eHRa/EeEqffHxdDFOowMVV
4xV5pgBmkUe_SLG1h3HTp769LCikQ?e=Ye7v0Q

Provider access to patient health records is not impacted.
4. PRIORTIZATION OF REQUESTS FOR COPIES OF HEALTH RECORDS: Due to
the increasing number of patient requests for partial and complete
paper health records, a prioritization scheme has been developed to
deliver the most urgent records first and to comply with REF (C).
All initial requests for records, including members in white spaces,
must go through the servicing clinic. The clinic's requests are
assigned a priority as described in each category below. Members
requesting a copy of their paper health records do not need to
specify a particular priority. The priority will be assigned based
on the nature of the request. The priority categories are:
a. PRIORITY 1: Records for those members who have separated or
retired from the Coast Guard. A Health, Safety, and Work-Life
Service Center surge team has been formed and is augmenting
contracted efforts in support of expediting completion of this
priority group.
b. PRIORITY 2: Records for those members who are expected to
separate from the Coast Guard within 180 days. An additional
COMDT (CG-9333) reservist-lead surge team is currently being formed
to augment contracted efforts in support of expediting completion of
this priority group.
c. PRIORITY 3: Records for those members requesting to access
their health information that are not within 180 days from
separating from the Coast Guard.
5. PROCESS TO INITIATE A REQUEST FOR A COPY OF PAPER HEALTH RECORDS:
When a request for a copy of a paper health record is generated, the
paper health record is retrieved at the central repository. Before
the record can be delivered to the requestor it must be prepared for
release, which requires a page-by-page quality review to protect
patient privacy and comply with applicable federal records law.
Guidance promulgated in REF (A) remains in effect and all members
should work with their servicing clinic to initiate a request for a
copy of their paper health record. Timeframes identified in REF (A)
for digitizing files in response to member requests are now
superseded by the revised priority groupings defined in this update.
Patients should only contact their servicing clinic for requests.
Otherwise, delays may occur in retrieving your record.
6. POC: LCDR George Cabanas. For prioritization status updates and
questions, email the paper records prioritization team at
SMB-HealthRecords@uscg.mil.
7. RADM Dana L. Thomas, Assistant Commandant for Health, Safety,
& Work-Life (CG-1K), sends.
8. Internet release is authorized.