De-identification standards

De-identification standards

De-identification standards

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HIPAA De-identification - The Anonymity Shield

To prevent patient re-identification, HIPAA provides two pathways to de-identify Protected Health Information (PHI), rendering it exempt from most HIPAA rules. This allows data to be used for research, public health, and other secondary purposes.

  • Safe Harbor Method: A prescriptive checklist approach. Key identifiers to remove include:
    • Names, Social Security Numbers, Medical Record Numbers
    • Geographic subdivisions smaller than a state (most zip codes)
    • All elements of dates except the year
    • Full-face photos & biometric identifiers (fingerprints)
    • Vehicle, device, or license plate numbers

⭐ Under Safe Harbor, the first 3 digits of a ZIP code can be retained only if the resulting geographic unit contains > 20,000 people. Otherwise, it must be converted to 000.

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De-identification Methods - Pick Your Path

HIPAA provides two routes to de-identify protected health information (PHI), removing its link to an individual. This allows data to be used for research, public health, or operations without compromising privacy.

  • Safe Harbor Identifiers Removed:
    • All names, initials, and contact information (phone/fax numbers, email, URLs).
    • All geographic subdivisions smaller than a state.
    • All elements of dates (except year) related to an individual.
    • All identifying numbers (SSN, medical record, license, etc.).
    • Biometric identifiers, full-face photos.

High-Yield Fact: Under the Safe Harbor method, data is not considered de-identified if the covered entity has actual knowledge that the remaining information could be used alone or in combination with other information to identify the individual.

The Safe Harbor 18 - The No-No List

Under the HIPAA Privacy Rule, the Safe Harbor method requires the removal of all 18 specific identifiers for Protected Health Information (PHI) to be considered de-identified. This allows the data to be used for research, public health, or other purposes without violating patient privacy.

  • Direct Personal Identifiers
    • Names
    • Social Security numbers
    • Medical record, health plan, or account numbers
    • Certificate or license numbers
  • Contact & Digital Information
    • Telephone & fax numbers
    • Email, IP addresses, & URLs
  • Geographic Data
    • All geographic subdivisions smaller than a state (e.g., street, city, county).
    • Exception: First 3 digits of a ZIP code are permitted if the area contains > 20,000 people.
  • Dates & Ages
    • All date elements (except year) related to an individual.
    • All ages over 89.
  • Biometric & Unique Identifiers
    • Biometric identifiers (fingerprints, voiceprints)
    • Full-face photos & comparable images
    • Vehicle or device serial numbers
    • Any other unique identifying code.

⭐ A covered entity is not considered to have de-identified information if it has actual knowledge that the remaining information could be used, alone or in combination with other information, to identify an individual.

High‑Yield Points - ⚡ Biggest Takeaways

  • HIPAA's Safe Harbor method requires removing 18 specific identifiers to de-identify Protected Health Information (PHI).
  • Key identifiers include names, all geographic subdivisions smaller than a state, and all elements of dates (except year).
  • Ages over 89 must be aggregated into a single category.
  • The alternative is the Expert Determination method, where a statistician certifies a very small re-identification risk.
  • Re-identification of de-identified data is a significant HIPAA violation.

Practice Questions: De-identification standards

Test your understanding with these related questions

A 79-year-old male presents to your office for his annual flu shot. On physical exam you note several linear bruises on his back. Upon further questioning he denies abuse from his daughter and son-in-law, who live in the same house. The patient states he does not want this information shared with anyone. What is the most appropriate next step, paired with its justification?

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Flashcards: De-identification standards

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The Beers criteria are used to reduce potential inappropriate prescribing and harmful polypharmacy in the _____ population

TAP TO REVEAL ANSWER

The Beers criteria are used to reduce potential inappropriate prescribing and harmful polypharmacy in the _____ population

geriatric

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