Griffith v. Aultman Hosp. — Mar. 2016 (Summary)

DISCOVERY OF MEDICAL RECORDS

Griffith v. Aultman Hosp.
No. 2014-1055 (Ohio Mar. 23, 2016)

The Supreme Court of Ohio held that the physical location of patient data is not relevant to the determination of whether that data qualifies as a “medical record” under the statute setting forth procedures by which a patient may obtain a copy of his or her medical record.  This litigation arose as a result of a son’s request for a copy of his father’s complete medical record, after the father died in the intensive care unit of the hospital.  The initial medical record given to the son did not contain cardiac-monitoring data, which was not kept in the medical records department.  The hospital argued that because the data was not kept within the medical records department it did not fall under the statutory definition of a medical record.  The court disagreed, reasoning that the Ohio legislature did not limit the definition of medical record in the statute to data held in the medical records department.  As such, the physical location of the data was not relevant.  Instead, the court ruled that the definition of what qualifies as a medical record focused on “whether a healthcare provider made a decision to keep data that was generated in the process of the patient’s health care treatment and that pertained to the patient’s medical history, diagnosis, prognosis or medical condition.”  The court then reversed the lower court’s ruling in favor of the hospital and remanded the case back to the trial court for further proceedings consistent with the court’s opinion.