University at Buffalo (UB)
To maintain files for an appropriate period of time on all residents/fellows who were trained in an accredited residency/fellowship training program. This policy refers only to records that have a legal, operational or historic value.
Documents maintained, stored and destroyed by the Office of Graduate Medical Education. Programs may not store any of these documents listed in Table 1 with the exception of the Final Summative Evaluation.
Paper | Minimum Retention Period | Resource |
|---|---|---|
| Benefit Elections | Termination + 6 years | ERISA (Employee Retirement Income Security Act) |
| Biographic Data (To include Social Security Number) | Termination + 6 years | NYS Retention and Disposition Schedule Ref # 90001 |
| COBRA Election Notice and application (STD and FMLA) | Effective date + 6 years | ERISA (Employee Retirement Income Security Act) |
| Direct Deposit Forms | Termination + 3 years | NYS Retention and Disposition Schedule Ref # 90032 |
| ECFMG Certificate | Termination + 6 years | NYS Retention and Disposition Schedule Ref # 90001 |
Employment Contract | Termination + 6 years | NYS Retention and Disposition Schedule Ref # 90001 |
| ERAS/Other System Applicant data for underrepresented minority research | Publication Date + 3 Years | HRP-072-SOP-IRB Records Retention |
| ERAS Application – matched candidates uploaded to Forms/Files in MedHub | Termination + 6 years | SUNY Record Retention and Disposition Schedule – Ref # 22303 |
Marriage Certificates | Termination + 6 years | NYS Retention and Disposition Schedule Ref # 90001 |
| Medical School Diploma | Termination + 6 years | NYS Retention and Disposition Schedule Ref # 90001 |
| Moonlighting Permission | Termination + 6 years | NYS Retention and Disposition Schedule Ref # 90001 |
Passports, DS-2019, I-94, I-644 and any other visa documentation | Termination + 3 years | NYS Retention and Disposition Schedule Ref # 90031 |
| Primary Source Verification | 5 years | NYS Retention and Disposition Schedule Ref # 90001 |
| Tax Withholding Certificates | Termination + 4 years | NYS Retention and Disposition Schedule Ref # 90016 |
Paper | Minimum Retention Period | Resource |
|---|---|---|
| Final Summative Evaluation | Permanent | ACGME Common Program Requirements V.A.2.a).(2).(a) |
| I-9 Form and supporting documentation | Termination + 3 years | NYS Retention and Disposition Schedule Ref # 90031 |
| Leave of Absence/Family Medical Leave Records | Termination + 6 years | |
| Malpractice records | Permanent | ACGME Expectations for Content of Resident and Fellow Files |
| Pre-employment drug testing, background investigation | Termination + 7 years | SUNY Records Retention and Disposition Schedule – Health Records Ref # 22235 |
| USERRA Leave Records | Termination + 6 years | |
| Verification of required certifications | Termination + 6 years | NYS Retention and Disposition Schedule Ref # 90001 |
| Employee Health Patient Records | Termination + 7 | SUNY Records Retention and Disposition Schedule – Health Records Ref # 22235 |
| Employee Health Workers’ Compensation Claims | Termination +18 years | NYS Retention and Disposition Schedule Ref # 90015 |
Employee Health | Termination + 40 years |
The training program is responsible for recording, maintaining, storing and destruction of the following documents as applicable.
| Program File Paper or Electronic | Minimum Retention Period | Resource |
|---|---|---|
| Final Summative Evaluation | Permanent | ACGME Common Program Requirements V.A.2.a).(2).(a) |
| Low score reports | Permanent | ACGME Expectations for Content of Resident and Fellow Files |
| Records of the resident’s/fellow’s rotations, training experiences, and procedures, as applicable to the specialty | Permanent | ACGME Expectations for Content of Resident and Fellow Files |
| Training verification – start/end dates of training | Permanent | ACGME Expectations for Content of Resident and Fellow Files |
| Transfer Information (Competency-based evaluations) | Permanent | ACGME Expectations for Content of Resident and Fellow Files |
| Paper or Electronic | Minimum Retention Period | Resource |
|---|---|---|
ERAS Application | Unmatched Applicants | SUNY Student Record Retention Schedule Ref # 22304 |
Interview documents
Visa status attestations | Unmatched Applicants 1 year + 1 day after match or final date of selection of candidates | SUNY Student Record Retention Schedule Ref # 22304 |
| Matched Applicants Termination + 6 years | SUNY Record Retention and Disposition Schedule Ref # 22303 | |
As required in the Employment On-Boarding Policy:
College Diploma/Transcript for MD Degree or equivalent (recommended) | Program responsibility to maintain while active in training.
GME Office responsibility to destroy termination | SUNY Record Retention and Disposition Schedule Ref # 22303 |
The entire file should be kept for residents/fellows who do not complete the program or who are not recommended for board certification. In addition, in the event of a litigation hold, no files may be destroyed regardless of the disposal schedule until notification has been received that the case has been resolved.
Each training program should identify a staff member to serve as a Data Steward who will take responsibility for the storage, management and disposition of appropriate documentation related to training residents and fellows.
In order to prevent a potential breach of protected or confidential information, it is recommended that the minimum retention period guidelines be followed for each type of document that is stored. This will greatly reduce UB’s vulnerability and liability in the event of a loss of information.
The preferred method of disposing of paper documentation is shredding. Do not recycle any documents containing sensitive or protected information.
Electronic deletion of data is more complicated. Hard drives/networks must be “sanitized”. This will require assistance and support from your Information Technology department. A simple “delete” process done at your workstation does not suffice to permanently delete electronic data. Be aware that backup copies of the data may also be stored and will need to be addressed. Program staff may not delete any electronic data from MedHub or alternate residency management systems.
Maintain a Record Disposal Document to record the date of disposal, description of the records identified and method of destruction. If sending paper records for shredding, a confirmation from the vendor is required that destruction of the records has been completed.
Working offsite on mobile devices such as laptops, tablets and smart phones is commonplace. However, sensitive data may only be accessed on UB-approved mobile devices via secure VPN connection and within the remote desktop application. As a general rule, you are not permitted to download category 1 or category 2 data to your personal mobile devices.
All requests for information prior to 1998 should go directly to the program director’s office or the hospital medical staff office.
All verification of training or malpractice coverage requests must be submitted electronically with a signed release. No requests are accepted by phone, fax or email.
Contact your residency program director's office for:
Contact the Federation of State Medical Boards for training verification in the following programs:
Established: 2004
GMEC Approved Date: September 21, 2021