3400, Client Records Management

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Revision 26-2; Effective Sept. 1, 2026

Grantees must have an organized and secure client record system. The grantee must make sure records are organized, readily accessible and available to clients upon request with a signed release of information. Records must be kept confidential, secure and:

  • safeguarded against loss and use by unauthorized people;
  • secured by lock when not in use and inaccessible to unauthorized people; and
  • maintained in a secure environment in the facility and during transfer between clinics, home and office visits.

Written consent is required for the release of personally identifiable information. Written consent is not required when personally identifiable information is necessary to provide services to the client or as required by law with appropriate safeguards for confidentiality. If the client is a minor, the minor’s parent, managing conservator or guardian must authorize the release per Chapter 32 of the Texas Family Code, federal law or regulations. Emancipated or married minors authorize the release of their own information. HIV information should be handled per federal and state law.

If the client is a minor, the minor’s parent, managing conservator or guardian must authorize the release per Chapter 32 of the Texas Family Code, federal law or regulations. Emancipated or married minors authorize the release of their own information. 

When information is requested, grantees should release only the specific information requested. Information collected for reporting purposes may only be disclosed in summary, statistical or other format that does not identify clients. Upon request, clients transferring to other providers must be provided with a copy or summary of their record to expedite continuity of care. Electronic records are acceptable as medical records.

Grantees, providers and subrecipients must maintain all records that pertain to client services, contracts and payments for the period specified by HHSC. Requirements about time limits for submitted claims are in TAC Title 1, Part 15, Chapter 354, Rule 354.1003. Requirements for medical record maintenance are in TAC Title 22, Part 9, Chapter 163. Grantees must follow contract provisions, maintain medical records for at least seven years after the contract closes, and follow the retention standards of the appropriate licensing entity. All records of services must be accessible to HHSC representatives to examine at any reasonable time as required by law.