Updated November 2026 · Southern New Hampshire
Mental health records shredding for NH therapists, counselors and treatment programs
How New Hampshire therapists, counselors, psychiatric practices and substance use programs can destroy old client records without cutting corners: psychotherapy notes, 42 CFR Part 2 records, retention, and closing a practice. Then the options and the prices, including a witnessed session for small practices that want to see it done.
99¢ per pound at our Tewksbury drop-off, witnessed sessions at $1.99 per pound. Certificate of Destruction on every job.
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Quick answer
Mental health records shredding has to protect two things HIPAA treats with extra care: psychotherapy notes, defined at 45 CFR 164.501, and substance use disorder records under 42 CFR Part 2, whose section 2.16 requires written policies for destroying paper records so patient identifying information is non-retrievable. Confirm the retention period with your licensing board first, then destroy only what has expired. New Hampshire Document Shredding shreds at its Tewksbury office for 99 cents per pound at drop-off or $1.99 per pound witnessed ($100 minimum), plus $34.90 in per-job fees, with a Certificate of Destruction and a Business Associate Agreement on request.
Why mental health records shredding is different from other medical shredding
Every medical record is private. Mental health records carry a different kind of weight. A client told you things they may never have said to a spouse, an employer or a parent, and the paper you hold reflects that. If a page from a therapy chart ends up in a parking lot, the harm is not a stolen credit card. It is a person’s trust, and sometimes their job or their custody case.
The law reflects this. Under HIPAA, psychotherapy notes are a separate category. The definition at 45 CFR 164.501 covers notes recorded by a mental health professional that document or analyze the contents of a counseling session and are kept separate from the rest of the medical record. It excludes medication records, session start and stop times, treatment modalities and frequencies, test results, and summaries of diagnosis, functional status, treatment plan, symptoms, prognosis and progress.
That separation matters in practice. Under 45 CFR 164.508(a)(2), most uses and disclosures of psychotherapy notes need the client’s specific authorization, with narrow exceptions such as use by the clinician who wrote them. Notes held to that standard while you are using them deserve the same care on the day they are destroyed.
Our medical shredding service covers the general HIPAA picture for practices of every kind. This page is for the offices where the stakes on each page run higher.
HIPAA does not name a single disposal method. HHS says paper PHI should be shredded, burned, pulped or pulverized so it is essentially unreadable and cannot be reconstructed, and that covered entities may not simply abandon PHI or put it in containers the public can reach.
What a mental health practice should shred
Paper in a therapy or counseling office is not limited to the chart. These are the groups that come through our door most often from behavioral health offices. Shred each of them only after its retention period has run.
Psychotherapy notes
Process notes, session impressions and working notes kept apart from the official record. Many clinicians keep these in a separate notebook or file. They are the most sensitive pages in the building.
The clinical record
Intake forms, assessments, treatment plans, progress notes, discharge summaries and correspondence with other providers. This is the part of the record your retention rules apply to most directly.
Billing paper
Superbills, claim forms, explanations of benefits, payment records and copies of insurance cards. They pair a client’s name with a diagnosis code, which is enough to cause harm.
Front desk paper
Sign-in sheets, appointment books, phone message slips, waitlist forms and printed schedules. These look harmless until you remember that the name of the office alone says something about the client.
Releases and legal copies
Signed releases of information, copies of records sent to courts or attorneys, and evaluation reports. Keep originals as long as your rules require and shred the working copies.
Media
Old laptops, external drives, USB sticks and session recordings on disc. These hold the same information on a smaller object. Our hard drive destruction service quotes them per item and physically destroys them.
You do not need to pull staples, paper clips or file folders. Take out three-ring binder hardware and hanging-folder frames. Anything that is not paper goes in a separate bag, labeled, and is quoted separately.
42 CFR Part 2: substance use disorder records
If your program provides substance use disorder treatment and is federally assisted, its records fall under 42 CFR Part 2 as well as HIPAA. HHS describes Part 2 as an added layer of confidentiality for those records. Many counseling practices in New Hampshire never touch Part 2. Some programs live inside it every day. Know which one you are before you write your disposal policy.
Section 2.16 is the part that matters for shredding. It requires a Part 2 program, or another lawful holder of patient identifying information, to have formal written policies that protect that information. For paper records, the policies must address destroying them, including sanitizing the hard copy media associated with paper printouts, so the patient identifying information is non-retrievable.
For electronic records, the same section requires policies for destroying them, including sanitizing the electronic media they are stored on. In plain terms, a Part 2 program needs a written rule for how paper is shredded and how old drives are handled, and it needs to follow it.
HHS and SAMHSA announced a final rule changing Part 2 on February 8, 2024. It was published in the Federal Register on February 16, 2024, and HHS says regulated entities had to comply by February 16, 2026. Among other changes, it applies the HIPAA breach notification requirements to breaches of Part 2 records.
That last change is the one to remember at disposal time. A box of Part 2 records that leaves your office readable is now the kind of event that can trigger breach notification, in the same way a box of HIPAA records can. A shredding procedure you can document is the best defense.
| Record type | Rule | What is special | What it means at disposal |
|---|---|---|---|
| General PHI in the clinical record | HIPAA Privacy and Security Rules | Reasonable safeguards through disposal (45 CFR 164.530(c)) | Shred paper so it cannot be read or reconstructed. Keep a certificate |
| Psychotherapy notes | HIPAA, 45 CFR 164.501 and 164.508(a)(2) | Kept separate from the record. Most uses need specific authorization | Smallest circle of handling. Many clinicians choose a witnessed session |
| SUD records from a federally assisted program | 42 CFR Part 2, section 2.16 | Written policies for destroying paper and sanitizing media. Breach notice applies | Follow your written policy exactly and file proof of destruction |
| Electronic records and old devices | HIPAA 164.310(d)(2)(i), Part 2 section 2.16 | Disposal policy for hardware and media | Physical destruction, quoted per item, with a certificate |
Retention before destruction: confirm with your licensing board
The worst shredding mistake a practice can make is destroying a record too early. A client returns after eight years, a board complaint arrives, a court asks for the file, and the only answer is a certificate showing it was shredded last spring. Shredding is the easy part. Deciding when is the part that needs care.
HIPAA itself does not set a retention period for clinical records. Its documentation rule, 45 CFR 164.530(j), requires you to keep your written policies and certain required records for six years from creation or from the date they were last in effect. That covers your disposal policy and its paperwork, not the chart.
Retention for the clinical record comes from your license, state law, your payer contracts and your malpractice carrier. In New Hampshire, clinical mental health counselors, clinical social workers, marriage and family therapists and pastoral psychotherapists are licensed by the Board of Mental Health Practice under the Office of Professional Licensure and Certification. Psychologists, psychiatrists and nurse practitioners answer to their own boards.
Rules for minors often run longer, because the clock may start at the age of majority rather than the last session. Records tied to a court matter, a custody evaluation or a pending complaint should be held until counsel says otherwise, whatever the general schedule says.
We are a shredding company, not your licensing board, so we will not tell you a number of years. Confirm the period with your board and your professional liability carrier, write it into your policy, and apply it file by file. Our guide to disposing of old medical records covers the retention-first approach in more detail.
| Ask | About | Why it matters |
|---|---|---|
| Your licensing board | Minimum retention for adult and minor client records, and rules for closing a practice | Board rules apply to your license directly |
| Your malpractice carrier | How long they want records kept for defense | Often longer than the legal minimum |
| Payers and contracts | Audit look-back periods in insurance and agency contracts | A payer audit needs the record that supports the claim |
| Counsel | Any litigation hold, subpoena or complaint | A hold overrides the schedule until it is released in writing |
| Your own policy | The period you chose and who approves destruction | Keep this documentation six years under 45 CFR 164.530(j) |
Closing or retiring from a practice
Retirement, a move out of state, or the death of a solo clinician all raise the same question: who keeps the records, and for how long. Shredding everything on the way out the door is almost never the right answer. Records that are still inside their retention period need a custodian. Only the ones that have expired should be destroyed.
- Check your board’s rules. Your licensing board may have requirements for notifying clients and arranging access to records when a practice closes. Read them before you send a single letter.
- Name a records custodian. A colleague, a group practice or a records storage service holds the active files and answers requests for the rest of the retention period. Put the arrangement in writing.
- Sort by retention date. Separate files that must be kept from files that have expired. Flag minors, court-involved clients and anything under a hold. When in doubt, keep.
- Shred the expired files. Box them, seal them and bring them to our Tewksbury office, book a pickup, or book a witnessed session if you want to see every page go. Bag old drives separately.
- File the certificate and the list. Keep the Certificate of Destruction with the list of files destroyed and hand a copy to the custodian. If a former client asks later, the answer is on paper.
A closing practice often has both paper and equipment to clear: filing cabinets, a laptop, an external backup drive, a printer with a drive inside it. Plan them together so one trip covers everything and one certificate covers the paper.
Shredding options for therapy and counseling practices
All shredding happens at our office at 1215 Main Street, Unit 115, Tewksbury, MA, about 15 minutes south of the Salem and Pelham line by I-93 or Route 38. There is no truck at your curb. The three ways in differ in who carries the boxes and who watches.
Witnessed session
Book a time, bring your boxes and stand beside the shredder while every page goes in. $1.99 per pound with a $100 job minimum, plus $34.90. Many solo clinicians choose this for psychotherapy notes. Read more about witnessed shredding.
Drop-off
Walk in Monday to Friday, 10 a.m. to 5 p.m. No appointment. Paper is weighed at the counter and shredded the same business day. 99 cents per pound plus $34.90. See drop-off shredding.
Pickup
A driver collects your sealed boxes and brings them to our office for shredding. Same shredding rates plus a zone fee of $129.95, $159.95 or $199.95. Best for group practices and programs with volume. See off-site shredding.
| Banker’s boxes | Drop-off | Witnessed | Zone 1 pickup | Zone 2 pickup | Zone 3 pickup |
|---|---|---|---|---|---|
| 2 (about 60 lb) | $94.30 | $154.30 | $224.25 | $254.25 | $294.25 |
| 4 (about 120 lb) | $153.70 | $273.70 | $283.65 | $313.65 | $353.65 |
| 8 (about 240 lb) | $272.50 | $512.50 | $402.45 | $432.45 | $472.45 |
Every total includes the $14.95 HIPAA filing fee and the $19.95 environmental fee. Zone 1 covers border towns such as Salem, Pelham, Windham and Plaistow, Zone 2 greater Nashua and Manchester, and Zone 3 the Seacoast and points farther north, confirmed when you book. Pickups assume ground-level or elevator access. The full list is on our shredding rates page, and our post on medical shredding cost works through more practice examples.
A worked example for a solo counselor
Take an illustrative solo counselor in Derry who has checked retention with her board and her carrier. She has three banker’s boxes of expired clinical records and one smaller box of psychotherapy notes from the same years, about 120 pounds in all. She wants to see the notes destroyed herself.
Splitting the job, with the records at the drop-off counter and the notes in a separate witnessed session, would mean two sets of per-job fees. Bringing all four boxes to one witnessed session costs 120 pounds at $1.99, or $238.80, plus $34.90, for $273.70. Dropping all four off without watching would cost $153.70. For many clinicians the extra $120 is worth it to see every page go. For others, sealed boxes at the counter and a certificate are enough. Either choice is defensible if your policy says which one you use and why.
Before you shred: a check for every box
Run each box through the same questions before it is sealed. It takes a minute per box and it is the record you will want if anyone ever asks why a file is gone.
Seal each box with tape across the lid once it passes the check, and write only a box number and “shred” on the outside. Never write a client name on the box. A label that says “Smith, J., 2014 to 2017” tells a stranger more than you want them to know.
While the boxes wait, keep them locked. A closet with a key, a locked office or the trunk of your car on the morning you drive down. The weakest point in most practices is not the shredder. It is the week the sealed boxes sit in a hallway.
From the moment you hand boxes over at the counter or to the driver, they stay in locked handling until they are shredded at our office. Our page on chain of custody shredding explains each handoff.
A one-page disposal policy for a small practice
HIPAA expects written policies, and Part 2 programs need a written policy that names how paper and media are destroyed. For a solo or small group practice, one page is enough if it answers these points.
- Who approves destruction. Usually the clinician of record or the practice owner.
- The retention periods you follow and where they come from: your board, your carrier, your contracts.
- How psychotherapy notes are stored separately and how they are destroyed.
- Whether your program is covered by 42 CFR Part 2 and, if so, how section 2.16 is met.
- Where paper waits before shredding, and that it is locked.
- Which vendor shreds, by which method, and that a Business Associate Agreement is on file.
- How old drives and devices leave the practice.
- Where certificates and destruction logs are kept, and for how long.
A Business Associate Agreement is available on request before your first job. Ask for it when you book, sign it, and file it with the policy. Training matters too. HHS says workforce members who dispose of PHI must be trained on your disposal procedures, and that includes the part-time front desk person who empties the shred bin.
If something does go wrong, New Hampshire’s breach notice law, RSA 359-C:19 to 359-C:21, sits alongside the HIPAA and Part 2 breach rules. Our page on the NH data breach law explains the state side. For the federal checklist, see our guide to HIPAA shredding requirements.
Each job ends with a certificate of destruction that records your practice, the date and what was destroyed. File it with the box list from your check. Together they answer the question a board investigator or a former client may one day ask.
Frequently asked questions
Do psychotherapy notes need special handling when shredded?
HIPAA does not set a separate shredding method for psychotherapy notes, but it treats them as a protected category under 45 CFR 164.501 and 164.508(a)(2), so most uses need the client’s specific authorization. Handle them in the smallest circle you can. Many clinicians keep them in sealed boxes and book a witnessed session so the notes never leave their sight before they are destroyed.
How long should I keep client records before shredding?
Confirm the period with your licensing board. In New Hampshire, counselors, clinical social workers and marriage and family therapists are licensed by the Board of Mental Health Practice, and other professions have their own boards. Check your malpractice carrier and payer contracts too. Records of minors and anything under a hold often need to be kept longer.
Does 42 CFR Part 2 apply to my practice?
Part 2 covers substance use disorder treatment records from federally assisted programs. Many private counseling practices are not Part 2 programs, while many treatment programs are. If you are not sure, ask your compliance advisor. If it applies, section 2.16 requires written policies for destroying paper records and sanitizing media so patient identifying information is non-retrievable.
Can I watch my records being shredded?
Yes. Book a witnessed session at our office at 1215 Main Street, Unit 115, Tewksbury. You stand by the shredder while every page goes in, and the Certificate of Destruction is signed in front of you. It costs $1.99 per pound with a $100 job minimum, plus $34.90 in per-job fees. Two boxes of about 60 pounds come to $154.30.
Do you sign a Business Associate Agreement?
We do. A Business Associate Agreement is available on request for covered entities and business associates. Ask for it when you book, before your first job, and keep the signed copy with your disposal policy. It applies whether you use drop-off, pickup or a witnessed session at our Tewksbury office.
What should I do with records when I retire?
Check your licensing board’s rules on closing a practice first. Name a records custodian for files still inside their retention period, sort out the files that have expired, and shred only those. Keep the Certificate of Destruction with a list of what was destroyed, and give a copy to the custodian so former clients can get an answer later.
Do I need to remove staples or folders?
No. Staples, paper clips, binder clips, rubber bands and file folders can stay. Remove three-ring binder hardware and hanging-folder frames. Put old laptops, drives, USB sticks and discs in a separate labeled bag, because media is quoted per item and physically destroyed apart from your paper.
Do you shred at my office?
We do not. All shredding happens at our office in Tewksbury, Massachusetts, about 15 minutes south of the New Hampshire line. You can drop boxes off on a weekday between 10 a.m. and 5 p.m., book a pickup where a driver brings sealed boxes to our office, or book a witnessed session and watch the shredding yourself.
Sources
- 45 CFR 164.501, HIPAA definitions including psychotherapy notes (eCFR) (checked November 2026)
- 45 CFR 164.508, uses and disclosures that need an authorization (eCFR) (checked November 2026)
- 42 CFR 2.16, security for records and notification of breaches (eCFR) (checked November 2026)
- HHS, Fact Sheet: 42 CFR Part 2 Final Rule (checked November 2026)
- HHS, What HIPAA requires when covered entities dispose of PHI (checked November 2026)
- NH Office of Professional Licensure and Certification, Board of Mental Health Practice (checked November 2026)
Book a drop-off, pickup or witnessed session
Confirm what has reached the end of its retention period, seal the boxes and choose how they reach us. Every job is shredded at our Tewksbury office and ends with a Certificate of Destruction. A Business Associate Agreement is available on request.
New Hampshire Document Shredding
1215 Main Street, Unit 115, Tewksbury, MA 01876. Route 38 near I-495, about 15 minutes from the Salem and Pelham line. Free parking out front.
Monday to Friday, 10 a.m. to 5 p.m. Pickups and witnessed sessions outside these hours by appointment.
- Drop-off: 99¢ per pound, walk in on weekdays
- Pickup: same rates plus a zone fee, by appointment
- Witnessed: $1.99 per pound, $100 minimum, by appointment
New Hampshire Document Shredding · 1215 Main Street, Unit 115, Tewksbury, MA 01876 · (978) 636-0301 · Monday to Friday, 10 a.m. to 5 p.m.