Are you up to standard? Designating a successor custodian

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If the last four years have taught us anything, it’s that there is nothing certain but the uncertain. This important lesson applies to many aspects of our lives, including the responsibility of regulated members to manage patient health information through their designation as custodians under the Health Information Act (HIA) and Health Information Regulation.

When acting as a custodian, a regulated member must have policies and procedures in place in order to remain compliant with CPSA’s Patient Record Retention standard of practice. These must include an information sharing or information manager agreement (if applicable), establishment of processes to manage patient health information responsibly and clarification of the roles of all involved parties.

The careful management of patient health information is an important responsibility that must be maintained, no matter what circumstances are encountered. That is why all custodians are required to designate a successor custodian and must attest to having a successor in place on CPSA’s renewal information form during annual renewal each year. This requirement supports the retention and accessibility of patient records, regardless of unforeseen circumstances that may prevent a custodian from fulfilling their duties.

Successor custodians

Under the Patient Record Retention standard of practice, all custodians are required to designate an appropriate successor custodian. When determining who to designate, it is important to remember that not everyone is eligible for this role.

A successor custodian:

• Must be eligible to be a custodian under the Health Information Regulation (per section 2(2));
• Must be located near enough to the original custodian’s practice (in cases where they are not already working within the practice) to ensure patients continue to have reasonable access to their records, and;
• Can be an eligible entity (as designated in section 2(1) of the Health Information Regulation).

Taking the step to identify a successor custodian is just one of the many ways that our regulated members support continuity of high-quality care and access to health information for their patients. More than just supporting patients, it shows consideration for your colleagues by minimizing the strain of assuming custodial responsibility and strengthening the efficiency of the profession as a whole.

Learn more about complying to this requirement by visiting the following links:

• Patient Record Retention standard of practice
• Advice to the Profession: Physicians as Custodians of Patient Records
  • This document contains links to multiple agreement templates that you may need within your role as custodian.

Questions? Contact Chantelle Dick, Standards of Practice Advisor, at chantelle.dick@cpsa.ab.ca.