Keeping copies of medical records has benefits

Q: I see patients in an outpatient clinic attached to a hospital. I keep a copy of the patient's most recent clinic note in a locked file cabinet until I have completed the follow-up of the tests ordered. I am the only person with access to this locked file. The hospital has a system of electronic records, though it is sometimes difficult to access specific test results with it. The patient's clinic note is shredded once I have completed the follow-up. Is this practice permissible by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)rules?

A: Assuming you are not violating any hospital policy, the approach taken here does not violate HIPAA. You are the treating physician keeping a handy record of a study in a secure environment and destroying it after use. A concern is that the EHR is difficult to access, which might raise other continuity-of-care issues to be addressed at the hospital.