Back in 1986, when I started in private practice, everybody kept counseling files for 7 years. I don’t think anybody knew where the number came from. Nonetheless, it felt like a community standard for a long time.
Since I’m on the lmhp board I happen to know that there is a draft set of regulations winding slowly through the department of Health that may eventually get a public hearing and might eventually be accepted as an approved update to the standards that we operate under now. The current regulations for licensed mental health practitioners does not include any mention of the length of time one should retain records at all.
The draft regulation suggest keeping records for 5 years after the completion of services. It does not make a distinction between adults and children. I think it likely that these regulations will make it through the regulatory approval process so you might conside it as a benchmark.
I recall that the draft regulations also ask that the professional make a record of destroyed records, and that that information about what records were destroyed be retained for another 10 years.
But wait, there’s more. Licensed clinical social workers who are Medicare providers apparently are advised to retain records for a minimum of six years. I recall finding that tidbit buried somewhere on the center for Medicare services website a couple of years ago when I was doing some research on the topic.
But wait, there’s even more. I understand that there is a set of draft regulations for Medicaid providers now similarly winding its way through the regulatory process. I seem to recall record retention numbers in those regulations as asking Medicaid providers to retain records for 7 years.
So, one might easily say that if you see a mix of cases overtime that might include Medicaid policy holders, seven years might be the number to shoot for. But at this point it’s all unofficial.
- This reply was modified 1 year, 6 months ago by Terry Moore. Reason: fix typos from voice recognition on phone