The Commonwealth of Pennsylvania’s Record Management Program was established to control the creation, use, maintenance, preservation, and disposition of state agency records. Management Directive 210.5, the State Records Management Program, requires state agencies to identify all records and establish retention and disposition guidelines through the use of a Records Retention and Disposition Schedule (RRDS) found at Office of Administration web site.
The overall objective of the Department of Human Services (DHS), Office of Income Maintenance (OIM), record retention policy is to provide a way to reconstruct a file through the use of the physical record, eCIS record, scanned documents, and case narratives. Accurate record retention should allow someone unfamiliar with the case to determine the actions taken and reasons for those actions.
NOTE: Case narratives must contain sufficient details about CAO actions, including client contacts and discussions, to permit reconstruction of why eligibility decisions and/or changes were or were not made.
OIM established existing record retention guidelines prior to the passage of the Health Insurance Portability and Accountability Act (HIPAA) of 1996. HIPAA requires that certain documents be retained for six years, with few exceptions, from the date of the document creation or the date when the document was last in effect, whichever is later. Discussions with the Office of General Counsel determined the impact of HIPAA regulations and other document retention laws on the OIM record retention schedule. Because OIM is subject to HIPAA, and these regulations require the longest period of retention and encompass the most forms, HIPAA guidelines were used to establish current OIM record retention guidelines as discussed in this chapter.
Revised July 31, 2024, replacing September 19, 2012