What You Need to Know about Archiving X-Ray Film

When it comes to archiving and records management, X-ray films pose a huge challenge.  There are two reasons for this:  (1) While not normally thought of as “permanent records” according the U.S. National Archives, X-rays are “frequently scheduled for very long retention periods, often as long as 75 years and, in some cases, even longer;” and, (2) because “film-based materials are vulnerable to damage from inappropriate storage environments, special precautions are needed to keep them in good condition until authorized for disposal.

The explosion of digital x-ray images and digital x-ray scanners over the past couple of decades has the preservation of film less necessary, since the film can be relatively easily scanned and stored in safe digital environments.  While many organizations opt to store digital images on-site in enterprise servers, an abundance of off-site options, particularly cloud based, vendor neutral options, are now available.

Sorting Out Your Film Archiving Strategy

For medical x-ray film we may consider two types of storage:  (1) clinical storage; and, (2) long-term storage.  Each plays a fundamentally different role, with most clinical storage today already converted to digital, as a result of clinical conversion to digital x-ray machines.  But, the fact remains that there is a need for long-term storage of existing film that pre-dates the digital x-ray machines.

X-ray film falls under the requirements of medical record retention.  Therefore, you must investigate and comply with all relevant federal and state laws and regulations regarding the retention of medical records. Hospital radiology records, including copies of reports, films, scans, and other image records, should be kept for five years, in compliance with Medicare regulations.

Additionally, all records and images produced by radiologists should be kept for the retention period required by law or regulation of the state in which your practice resides.  If your state has no required retention period, then records and images should be kept at least for the maximum period that the state’s statute of limitations allows for the filing of medical malpractice actions. Some states have specific retention periods for mammograms, so make sure you check out this requirement separately.

Optimally, medical records – and this includes medical x-ray film – should be kept for whichever period is longer—the statute of limitations or the prescribed retention period.  How long data will be retained is a significant factor in determining a healthcare organization’s archiving strategy.  In fact, many healthcare organizations tend to err on the side of retaining data longer than the law requires.   The state of California requires all pediatric files to be saved for 30 years past maturity. This is where digital storage can be a huge benefit.

Regardless of what long-term, DICOM enabled storage your organization decides to go with, the film that you plan to retain should be digitized.  Digitized images are generally acceptable for record archiving and storage unless otherwise specified by state or federal law. One caveat:  Microfilming and digitization are not appropriate for chest radiographs used to detect pneumoconiosis or other dust retention respiratory diseases, and for mammograms. The selection of other image storage techniques depends on the quality of the image in the alternative format.

Of Note:

Some states have laws requiring that hospitals or physicians try to contact the patient before his or her records are destroyed. For instance, in Maryland, after the death of a physician, the estate must forward a notice to the patient before records are destroyed or transferred; if the patient cannot be located, a notice must be published in a local newspaper about the date and location of the disposal. In Colorado, the patient must be notified before any records or x-rays are destroyed. In Hawaii, if a health care provider stops operations, he or she has to make arrangements for the retention and preservation of the records for the prescribed period, subject to health department approval. In Tennessee, records must be sent to the local department of health when a practice or hospital is closed. In Florida, the physician’s estate must keep patients’ records for one year from the date of death.

Bottom Line

You may have different retention rates for clinical x-ray files and long-term storage files.  Ensure that you follow the law in your area for long-term retention.   Some states may require some types of images to be stored for very long periods of time.  Cloud storage of digitized / scanned x-ray images generally provides cost-effective long-term storage, with the added benefit of easy access when needed.

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