The purpose of this memorandum is to provide ADAP and PrEP-AP enrollment workers guidance for the document retention policy for client files.
Document Retention Policy:
All files and documentation in the ADAP Enrollment System (AES) must be retained for a period of six years, includingall electronic and hard copy documents stored at the enrollment site prior to AES. The Health Insurance Portability and Accountability Act (HIPAA) requires covered entities to retain records for six years which includes ADAP and PrEP-AP. (45 C.F.R. § 164.530(j).) Enrollment sites must continue to upload documentation in AES and the information will be stored in AES. Continuing to maintain the hardcopy is optional, but once these files have reached the retention timeframe, they may be destroyed by following the updated document retention timeframe.
ADAP and PrEP-AP files must be destroyed in a manner that makes them impossible to reconstruct. Paper-based records cannot be disposed in garbage containers. Documents must be shredded, preferably with a crosscut shredder, and properly disposed of in a confidential destruction waste bin. Enrollment sites can use their preferred offsite paper shredding vendor with OA approval.
If you have any questions regarding the contents of this management memorandum, please contact your ADAP advisor.
Sandra Robinson, MBA
ADAP Branch Chief
California Department of Public Health