Health and Counseling Records

ID	Title	Description	Creator / Responsible Unit	Retention Period	After Retention
H1	Controlled Drug Administrative Records	Records documenting the receipt and control of controlled drugs by University Health Services personnel. This series may include but is not limited to: inventories, logs, and related documentation and correspondence.	University units that create the records	10 years after released from all audits	Dispose - Could this be added to the University Archives?
H2	Immunization Incomplete Log	Incomplete immunization logs from University Health Services. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)).	University units that create the records	Immunizations, or refusal of, shall be reported to the Michigan Care Improvement Registry (MCIR). 10 years after last date of service for patients 18 years or older. For minors, 10 years after patient reaches age 18.	Dispose - Could this be added to the University Archives?
H3	Laboratory Records	Records documenting orders and results of laboratory tests. This series may include but is not limited to: test results and related documentation and correspondence. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)).	University units that create the records	10 years after last date of service for patients 18 years or older. For minors, 10 years after patient reaches age 18.	Dispose - Could this be added to the University Archives?
H4	Patient Appointment Records	Records documenting time and date of and reason for patient appointments. This series may include but is not limited to; appointment books and databases, and related documentation and correspondence. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)).	University units that create the records	1 year	Dispose - Could this be added to the University Archives?
H5	Counseling Records	Records documenting the interactions of the Counseling Center with its clients. This series may include but is not limited to: case notes, test results, treatment plans, referrals, evaluations, case summaries, and related documentation and correspondence. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)). Please also consult applicable guidelines from the American Psychological Association. See also: H7 (Medical Records) and H8 (Mental Health Records).	University units that create the records	7 years after last date of service for patients 18 years or older. For minors, 7 years after patient reaches age 18.	Dispose - Could this be added to the University Archives?
H6	Immunization Records	Records documenting immunizations received on campus. This series may include but is not limited to: immunization records, and related documentation and correspondence. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)). Please also consult applicable guidelines from the American Psychological Association.	University units that create the records	Immunizations or refusal of, shall be reported to the Michigan Care Improvement Registry (MCIR). 10 years after last date of service for patients 18 years or older. For minors, 10 years after patient reaches age 18.	Dispose - Could this be added to the University Archives?
H7	Medical Records	Records documenting medical treatment and history. This series may include but is not limited to: medical charts, name, medical history, accidents reports, and related documentation and correspondence. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)). See also: H5 (Counseling Records) and H8 (Mental Health Records).	University units that create the records	10 years after last date of service for patients 18 years or older. For minors, 10 years after patient reaches age 18.	Dispose - Could this be added to the University Archives?
H8	Mental Health Records	Records documenting mental health counseling, including substance abuse counseling. This series may include but is not limited to: psychiatric and/or psychological information, notes of practitioner, diagnosis and treatment, referral letters, and release of information agreement. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)). See also: H5 (Counseling Records) and H7 (Medical Records).	University units that create the records	7 years after last date of service for patients 18 years or older. For minors, 7 years after patient reaches age 18.	Dispose - Could this be added to the University Archives?
H9	Substance Abuse Program Administration Records	Records documenting the administration of substance abuse programs for students. This series may include but is not limited to: attendance rosters, compliance status, reports and related documentation and correspondence. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)).	University units that create the records	10 years for all records other than statistical reports. Statistical reports retained permanently - transferred to University Archives after no longer useful to University unit(s).	Dispose - Could this be added to the University Archives?
H10	HIPAA Records	Health Insurance Portability and Accountability Act (HIPAA) documents include but are not limited to: notice of privacy practices, risk assessments and analyses, Business Associate Agreements, incident and breach documentation, logs recording access to and updating of PHI, records of PHI disclosures including authorizations for the disclosure of PHI and accounting of disclosures, IT system security reviews, HIPAA privacy and security policies. Confidentiality: Comply with 20 U.S.C. 1232g (Family Educational Rights and Privacy Act (FERPA) of 1974) regarding confidentiality of student records. Comply with 42 USC 1320d-2(d)(2) (Health Insurance Portability and Accountability Act (HIPAA)).	University units that create the records	6 years for all records except policies. For policies, when superseded.	Dispose - HIPAA documents can only be disposed with permission of the HIPAA Privacy Officer.

Updated June 23, 2022