SEPT 09, 1994

This Special General Memorandum (SGM) reiterates policy and procedures established by the Public Health Service (PHS) Information Resource Management Manual Chapter 11, "Records Management and Disposition," and the Federal Information Resources Management Regulations (FIRMR) Bulletin B-l, "Electronic Records Management" regarding purchasing filing equipment and the comparison of various media for information storage and retrieval.  Filing equipment includes, micrographic equipment and other media transfer equipment, such as optical disk storage.

The Indian Health Service {IHS) Records Management Officer must be consulted in the planning stage of the life cycle design of filing equipment, such as optical disk.  No such equipment shall be purchased without the appropriate involvement of the IHS Records Management Officer. Such consultation will ensure that National Archive and Records Administration (NARA), General Services Administration, Office of Management and Budget, and PHS records management and information resources management requirements are fully addressed and that records are properly maintained, scheduled and disposed.

Optical Disk is a non-contact random-access disk tracked by optical laser beams and used for mass storage and retrieval of digitized text and graphics.  Optical disk systems lack standardization within the industry.  The systems are hardware and software dependent and use of the medium depends on the uncertain availability of equipment (and vendor) in the future.  There is no clear track record on legal admissibility of documents stored on optical disk.  However, microfilmed images are accepted in most judicial matters.  Manufacturers claim that optical disks have a life expectancy of only 10 years.  Microfilm will last for 10 to 100 years.

Optical disks have advantages in certain applications, especially those requiring faster retrieval time and simultaneous access.

However, since optical disk systems are more expensive, lack standardization, and involve uncertain legal admissibility, microfilm is the better choice, especially those involving inactive records required for long-term or permanent retention.

At present, the IHS is required to, maintain an individual's medical record for 30 years.  In the new IHS Records Disposition Schedule, a proposed disposition of 75 years has been submitted to the Archivist of the United States.

The IHS will be required to maintain and have available an individual's medical record for 75 years after the date of last activity.  This can be accomplished by transferring the medical record information to microfilm, and transferring the inactive records to the Federal Record Center.

The FIRMR does not consider optical disk as an acceptable media for transfer of permanent records to NARA.

I expect your full cooperation and participation in consulting the IHS Records Management Officer in the planning stage of purchasing filing equipment within your organization.  Your efforts will contribute to a records program that ensures the efficiency, security, and integrity of IHS operations.

Questions regarding this SGM or the Records Management Program may be referred to the IHS Records Management Officer, Headquarters West, Albuquerque, New Mexico, on (505) 837-4272.

Refer to:
OAM/DAS/GSB/RMS