Navigating Public Health Department Data Migration: To Import or Not to Import Your Patient Health Records?

Written by Nicole K. Sowers

Transitioning to a new Electronic Health Record (EHR) system is a significant step for any healthcare health department. One crucial decision you’ll face is whether to import your data from your previous EHR. While having all community historical health data readily available might seem appealing, it’s essential to carefully consider the implications.

According to the HIPAA Retention Requirements post by The HIPAA Journal, while there are no specific HIPPA retention laws for medical records, each state has laws for healthcare record retention. The HIPAA Journal article gives several great state examples of retention laws if you’re interested. For example, some states require medical records to be retained for a minimum of seven years after the last patient encounter.

**Before diving in, a crucial disclaimer:** Always consult your state’s healthcare data retention laws. These regulations dictate how long you must maintain patient records and understanding them is paramount before making any data migration decisions. You can typically find these regulations on your state’s Department of Health website or through legal counsel. 

Do You Really Want to Import All Your Old Data?

The allure of complete data transfer can be strong, but consider the potential drawbacks. Importing everything means including records of closed cases and patients seen many years ago. This can lead to clutter and increased storage needs within your new EHR.

Purging and Filtering

Explore whether your previous EHR provider allows you to purge outdated records or filter data by specific periods. This can help streamline the migration process.

Starting Fresh

Some health departments opt for a clean slate, choosing not to migrate data at all. Instead, they securely store old records for future access, complying with data retention requirements. This approach can simplify the transition and minimize potential data inconsistencies. Secure storage options, which can include encrypted digital archives or physical storage, are vital for maintaining compliance with regulations like HIPAA.

Deciding to Migrate Your Data? 

Key Considerations

If you decide data migration is the right choice for your health department, you’ll need to address several key aspects:

Access to Your Data

• Self-Extraction: Can you independently extract your records from your previous EHR? This allows you to generate reports and verify data accuracy before the transition. Ensure you do this while you still have access to your old system. You will need to understand the format of the data export and, if needed, find assistance to analyze your old data. 
• Vendor-Provided Data: If your previous vendor will provide the data, initiate the request early. Data exports can take time, so proactive communication is essential. Contact your vendor to understand their data export process and estimated timeline.

Ending Access to Your Previous EHR

Whether your agency uses a phased approach for moving your staff from the old system to the new system, or chooses to go all-in on the new system at one time, will depend on many factors including your available resources and contractual access to the old system. The AMA Ed Hub provides this illustration to help you think about planning the transition at a high level:

Consider your access period

• Immediate Termination: If you will lose access to your old EHR before fully transitioning to the new one, plan for temporary workarounds. This might involve using paper documentation for a brief period.
• Dual Access Period: If you will have simultaneous access to both systems, develop a clear transition strategy. Consider:
  • Adding all new patients to the new EHR.
  • Continuing documentation for patients nearing program completion in the old EHR.
  • Transferring active patients to the new EHR.
  • This phased approach can help minimize disruption and ensure a smooth transition 

No Right or Wrong Answer

Ultimately, the decision to migrate data depends on your health department’s specific needs and circumstances. There’s no one-size-fits-all solution. Weigh the pros and cons carefully, and don’t hesitate to seek guidance from your new EHR provider.

References:

• edhub.ama-assn.org/steps-forward/module/2820544. Accessed 25 Feb. 2025.
• “EHR Data Transfer – 6 Steps to Successfully Move Data to a New EHR.” MediQuant, 7 Aug. 2024, www.mediquant.com/ehr-data-transfer/.
• www.hipaajournal.com/hipaa-retention-requirements/. Accessed 25 Feb. 2025.