CMS Pub. 100-01, ch. 7, § 30.30.1.4

Paper

Since imaging can be used to replace paper documents, only when the image will be identical to

the paper, you must image/scan both the front and the back of every document.

There is an exception: Once the back of a claim form is imaged, you do not have to image

the back of the rest of the documents imaged on that particular machine, as long as the

backs are identical and a certified statement is kept on file stating “the remainder of the

backs of the claim forms are identical”. However, if the back of a claim form differs in any

respect, it must be imaged.

The contractor must retain the paper records until their certification/quality assurance process

(see below) has been completed and the imaged information (the recordkeeping copy) is verified

as an identical replication of the paper document. Only then can the paper records be destroyed.

If a scanned document is not identical to the paper document, that paper document must be

retained until the freeze is lifted.

Imaged/Scanned Records

Due to the freeze prohibiting the destruction of Medicare records, do not destroy any images of

claims records. They are the recordkeeping copy and must be retained until CMS notifies you

the freeze is lifted. Once the freeze is lifted, revert back to the normal disposition instructions in

§30.30.2.

Sample Quality Assurance Procedure

Certifying images as an exact replication 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 quality

assurance process.

Standard Procedures for Document Imaging Quality Assurance

1. The staff member(s) 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.