Health information from the closed location will be entered
into the new system only upon patient return, therefore access
to the MPI and the health information must be preserved.
Patient identifiers from one of the previous facilities may be
used, or an entirely new set of identifiers may be implemented
as of a certain date, such as the date of the merger. If an entity
decides to implement new identifiers, it must decide whether to
renumber all existing records, renumber the past few years’ records, or simply link them in the MPI. The cost of renumbering
all existing records may outweigh the benefit.
All components of the health record must be available for
continuity of care purposes during and after the transition. Unit
records must be maintained if required by state licensure. The
new entity should discuss the requirements for unit records
with state licensing authorities. After that discussion, it may
want to develop a plan to unite all existing records or only the
past few years’ records or establish a new unit record system as
of a certain date, such as the effective date of the merger, for returning patients.
It may be cost prohibitive to unite all existing records. Organizations should consider destroying all records beyond the mandatory retention period prior to the merger or acquisition.
Mergers and Acquisitions Resulting in Two or More
Locations with a Single License
A merger or acquisition resulting in two or more locations and a
single license may require consolidating records into a unit record and creating a single MPI with a single patient numbering
system, depending on the types of care offered at each site and
state licensing requirements. Patient health information must
be available at all sites. This will necessitate the transportation
of paper records and access to all electronic systems.
If all sites provide acute care, health information must be
available at any site when the patient presents. If one or more
of the locations provides only skilled nursing, long-term care,
rehabilitation, or subacute care, it may not be necessary to establish a unit record.
In order to promote patient safety and facilitation of a longitudinal health record, combining health records from a variety of
settings is recommended.
If information systems will be consolidated, it may be efficient
to consolidate HIM functions into a single department as well. If
all HIM functions will be consolidated into a single department,
appropriate plans must be made for displaced staff members. If
there will be more than one HIM department, it must be determined which functions will be located at each site.
Mergers and Acquisitions Resulting in Two or More
Locations with Separate Licenses
If the new entity will operate from more than one location under separate licenses, the facilities must determine whether the
HIM function will be consolidated into a single department, a
central department with one or more satellite locations, or two
or more independent departments. Planning should address
compliance with all regulatory and licensure requirements for
each licensed facility.
When two or more facilities are involved in a merger or acquisition, all HIM requirements should be reviewed to ensure compliance with state licensure and regulatory requirements, accrediting standards, and Medicare Conditions of Participation
Appendix A in the online version of this practice brief, available in the AHIMA Body of Knowledge at www.ahima.org, provides a checklist of information management activities; appendix B provides a checklist when setting up a new clinic.
To ensure availability of health information to all authorized
users, health records must be consolidated or linked in the MPI.
A minimum of five years of MPI data should be maintained.
A record retention policy that includes logs, indexes, and registers must be developed and implemented to meet the needs
of patients and other legitimate users and ensure compliance
with legal, regulatory, and accreditation requirements. If health
information from closed facilities will be stored for a period of
time, its integrity and confidentiality must be preserved, and it
must be readily accessible for patient care.
The compatibility and functionality of existing information
systems should be assessed, and a plan should be formulated
for the integration of systems to the extent possible. Such integration may be essential for the organization to successfully
meet the demands of integrated delivery systems. Existing databases should be maintained in an accessible form to meet anticipated future needs.
With their expertise in health information systems and understanding of user needs, HIM professionals can make significant
contributions to the evaluation and integration of these systems. ¢
1. Sassano, Paul. “From the M&A Front: Address Tax Considerations Early in the Process.” December 2009. www.
Centers for Medicare and Medicaid Services. “Hospitals
Interpretive Guidelines and Survey Procedures.” www.cms.
The Joint Commission. 2011 Comprehensive Accreditation
Manual for Hospitals. Oakbrook Terrace, IL: Joint
Lillie, Celine M. “Legal Issues in Closing a Medical Record
Department.” Journal of AHIMA 64, no. 5 (May 1993): 28–29.
Pinder, Ray. “Mergers and Acquisitions: They Could Happen to
You.” Journal of AHIMA 73, no. 3 (Mar. 2002): 58–59.
Piotti, Debora S. “Joining Forces.” For the Record 5, no. 26