How Long Should We Retain Patient Safety Work Product?
HIPAA may also apply, in which case the retention period would be the greater of the HIPAA retention policy or the following recommended Patient Safety Work Product (PSWP) retention policy:
Compliance audits and investigations related to PSWP
Contracts leases and supporting documentation when PSQIA provisions apply
Life of agreement/lease/equipment, plus 6 years (unless contract specified longer retention)
Authorization for release of PSWP
PSWP Policies and procedures, manuals
6 years after expiration
Training records: attendance lists, instructors, dates/times, curricula
Research Records related to PSWP (note that special restrictions apply to research with PSWP—check with CHPSO before proceeding):
Contracts with study sponsors and principal investigators, including related documentation; human subject search records
30 years after completion of the research
Other research reports
PSWP itself does not have a mandatory retention period. However, if you destroy PSWP and a court decides that the documents were not, in fact, protected, the court could reach out to CHPSO for the documents.
Also, note that the above retention policies are based on the law as it applies to PSOs. For example, you may want to increase retention period for PSWP policies and procedures to be as long as your other retention periods for documents useful for defense in a liability case, as destroying the policy after 6 years may leave you without documentation of the state of the PSES at the time of the event, and thus make it difficult to safeguard your legal protections.
“Ask CHPSO” is a regular column in the bimonthly Patient Safety News and is intended to provide answers to common inquiries. If you have a question, please contact us at (916) 552-2600 or email@example.com. All inquirers will remain anonymous.