Rebecca A. Wiese and Tyler D. Wiese, Individually and as the Natural Parents and Natural Guardians of RDW, a Minor v. Riverton Memorial Hospital, LLC, a Delaware Business Entity

Summary

The Wyoming Supreme Court considered whether electronic medical-record audit trails constitute health care information under the Wyoming Hospital Records and Information Act. The court held that audit trails qualify as health care information and concluded that genuine issues of material fact existed regarding whether Riverton Memorial Hospital complied with the Act. It reversed the summary judgment ruling and remanded for further proceedings.

Holdings

1. Audit trails qualify as health care information under the Act because they contain information identifying or associated with a patient and relating to the patient's health care, including the content, timing, authorship, alteration, deletion, and access of electronic medical-record entries.
2. Summary judgment for the hospital was improper because a genuine issue of material fact existed as to whether the hospital made a good-faith effort to locate the patient's Centricity electronic record and corresponding audit trail before stating that the information did not exist or could not be found.
3. The plaintiffs' pending motion to compel and motion for joint inspection were no longer moot after reversal of summary judgment and had to be addressed by the district court on remand.

Questions Presented

1. Whether audit trails associated with electronic medical records constitute health care information under the Wyoming Hospital Records and Information Act.
2. Whether a genuine issue of material fact existed concerning whether the hospital complied with the Act by making a good-faith effort to locate the patient's Centricity electronic record and corresponding audit trail before informing the plaintiffs that the information did not exist or could not be found.
3. Whether the district court erred by ruling on summary judgment while the plaintiffs' motions to compel discovery and for a joint inspection remained pending.

Disposition

reversed_and_remanded