CMS Pub. 100-01, ch. 7, § 30.30

This schedule identifies those records accumulated by the contractor in administering the

Medicare program and outlines the disposal schedule for each type of record.

A freeze has been imposed on the destruction of Medicare records. No paper Medicare records

can be destroyed unless they are electronically imaged. If Medicare records are not imaged, the

original paper document must be retained. A contractor who images paper Medicare records:

A. Must always be able to demonstrate the imaged version is an exact copy of the paper

document,

B. Document the steps taken to image the original document,

C. Establish and implement a certification/quality assurance process to ensure the imaged

information is an identical replication of the paper document in every way,

D. Retain the scanned image as the “recordkeeping copy” for the required retention period,

and

E. Maintain accessibility and the ability to read the document in accordance with changes in

technology.

The methods used in imaging files may vary with the contractor. These variations depend on the

type of equipment used and methods used to prepare documents for imaging. All imaged

documents shall be tamper proof. Once an image is verified as an exact copy of the original

paper document, only then can the original paper document be destroyed and the imaged copy is

certified as the “recordkeeping copy”.

Certifying images as an exact copy of the paper document means there is a "quality assurance"

process in place that verifies that the images are good. Each contractor is responsible for

establishing their own "quality assurance" procedures.

Below is an example of a certification/quality assurance process.

1. The staff member performing the actual scan will:

a. Observe that all pages successfully pass through scanner and that image displayed

on the imaging software preview screen appear accurate.

b. Affix a sticker marked “Scanned” to the top page, write the current date on the

sticker and place on top of a pile of scanned material.

2. The staff member(s) responsible for these records will have immediate access to the

images, from their desktops, using the imaging software. They will have 30 days to

use and review the images. If any problem is detected, the paper will be retrieved and

rescanned. After 30 days, the paper copies are subject to proper disposal.

A contractor is authorized to cut off and transfer Medicare claims records and other records to

inactive storage earlier than is prescribed in the disposal schedule shown below when the records

are contained on microform. (See §§40.3 and .50ff. for guidelines on retention and disposition

guidelines on microform copies of the following records.)

The term "cut off" means the transfer of records to an inactive files area when there is no more

than one reference to a file drawer per month. See §§30.70 for guidelines regarding the

disposition of non-claims material not transferred to inactive storage.