Griffith, Exr. v. Aultman Hospital

Summary

The Supreme Court of Ohio held that data qualifies as a medical record under R.C. 3701.74(A)(8) when it pertains to a patient’s medical history, diagnosis, prognosis, or medical condition, is generated during healthcare treatment, and the healthcare provider decides to keep or preserve it. The physical location or department in which the data is stored is not determinative. The court reversed the Fifth District’s judgment and remanded for further proceedings to determine whether the hospital had produced the patient’s entire medical record.

Holdings

1. A medical record includes patient data in any form that pertains to the patient's medical history, diagnosis, prognosis, or medical condition and that a healthcare provider generated and decided to keep or preserve in the process of the patient's healthcare treatment.
2. The physical location or department where patient data is kept is not relevant to whether the data qualifies as a medical record under R.C. 3701.74(A)(8).
3. For purposes of R.C. 3701.74(A)(8), maintain means that the healthcare provider made a decision to keep or preserve the data.
4. R.C. 3701.74 does not require a patient or the patient's representative to state a reason for requesting medical records.
5. The hospital did not establish on the record that there was no genuine issue of material fact regarding whether it had produced Howard Griffith's entire medical record.

Questions Presented

1. What data qualifies as a medical record under R.C. 3701.74(A)(8)?
2. Whether the physical location or department in which patient data is stored determines whether it is a medical record.
3. What does the term maintain mean in R.C. 3701.74(A)(8)?
4. Whether a patient requesting medical records under R.C. 3701.74 must state a reason for the request.
5. Whether Aultman Hospital established on summary judgment that it had produced Howard Griffith's entire medical record.

Disposition

reversed_and_remanded