which of the following is not a hipaa identifier
Of course, the specific details of such an agreement are left to the discretion of the expert and covered entity. https://www.census.gov/geo/reference/zctas.html, http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/index.html, http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/businessassociates.html, http://www.healthy.arkansas.gov/programsServices/healthStatistics/Documents/STDSurveillance/Datadeissemination.pdf, http://www.cdphe.state.co.us/cohid/smnumguidelines.html. Many records contain dates of service or other events that imply age. Similarly, the final digit in each ZIP Code is within +/- 3 of the original ZIP Code. However, in recognition of the potential utility of health information even when it is not individually identifiable, §164.502(d) of the Privacy Rule permits a covered entity or its business associate to create information that is not individually identifiable by following the de-identification standard and implementation specifications in §164.514(a)-(b). Demographic data is likewise regarded as PHI under HIPAA Rules, just like common identifiers including patient names, Driver’s license numbers, Social Security numbers, insurance information, and dates of birth, when they are used in combination with health information. Experts may be found in the statistical, mathematical, or other scientific domains. The Employer Identification Number (EIN), issued by the Internal Revenue Service (IRS), was selected as the identifier for employers and was adopted effective July 30, 2002. Whether additional information must be removed falls under the actual knowledge provision; the extent to which the covered entity has actual knowledge that residual information could be used to individually identify a patient. Many questions have been received regarding what constitutes “any other unique identifying number, characteristic or code” in the Safe Harbor approach, §164.514(b)(2)(i)(R), above. This is because a record can only be linked between the data set and the population to which it is being compared if it is unique in both. HIPAA is an acronym that stands for the Health Insurance Portability and Accountability Act of 1996. Rather, a combination of technical and policy procedures are often applied to the de-identification task. In the past, there has been no correlation between ZIP codes and Census Bureau geography. For instance, clinical features, such as blood pressure, or temporal dependencies between events within a hospital (e.g., minutes between dispensation of pharmaceuticals) may uniquely characterize a patient in a hospital population, but the data sources to which such information could be linked to identify a patient are accessible to a much smaller set of people. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) required the Secretary of Health and Human Services (HHS) to adopt standards for the following identifiers: Employer Identification Number (EIN) Health Plan Identifier (HPID) National Provider Identifier (NPI) Unique Patient Identifier … Example Scenario 1 Can an Expert determine a code derived from PHI is de-identified? The following provides a survey of potential approaches. a. The HIPAA privacy rule sets forth policies to protect all individually identifiable health information that is held or transmitted. Alternatively, the expert also could require additional safeguards through a data use agreement. Each panel addressed a specific topic related to the Privacy Rule’s de-identification methodologies and policies. Third, the expert will determine if the specific information to be disclosed is distinguishable. This new methodology also is briefly described below, as it will likely be of interest to all users of data tabulated by ZIP code. Both methods, even when properly applied, yield de-identified data that retains some risk of identification. For instance, the date “January 1, 2009” could not be reported at this level of detail. Imagine a covered entity was told that the anticipated recipient of the data has a table or algorithm that can be used to identify the information, or a readily available mechanism to determine a patient’s identity. HIPAA-define concept that serve as a standards for all electronic data interchange include all but which of the following: A. ICDM-10 B. ID ANSI C. CPT D. ANSI X12N . In practice, an expert may provide the covered entity with multiple alternative strategies, based on scientific or statistical principles, to mitigate risk. In practice, this correspondence is assessed using the features that could be reasonably applied by a recipient to identify a patient. Guidance on Satisfying the Expert Determination Method, Guidance on Satisfying the Safe Harbor Method. Read more on the Workshop on the HIPAA Privacy Rule's De-Identification Standard. Protected health information includes many common identifiers (e.g., name, address, birth date, Social Security Number) when they can be associated with the health information listed above. Esoteric notation, such as acronyms whose meaning are known to only a select few employees of a covered entity, and incomplete description may lead those overseeing a de-identification procedure to unnecessarily redact information or to fail to redact when necessary. These documents may vary with respect to the consistency and the format employed by the covered entity. Finally, the expert will evaluate the identifiability of the resulting health information to confirm that the risk is no more than very small when disclosed to the anticipated recipients. (c) Implementation specifications: re-identification. They represent the majority USPS five-digit ZIP code found in a given area. Utilizing 2000 Census data, the following three-digit ZCTAs have a population of 20,000 or fewer persons. When HIPAA was enacted in 1996, the law called for development of a unique patient identifier. What is “actual knowledge” that the remaining information could be used either alone or in combination with other information to identify an individual who is a subject of the information? PHI HIPAA is any individually identifying information that relates to past, present, or future health. (1) A person with appropriate knowledge of and experience with generally accepted statistical and scientific principles and methods for rendering information not individually identifiable: *This is not intended to exclude the application of cryptographic hash functions to the information.”. The workshop was open to the public and each panel was followed by a question and answer period. Second, the expert will determine which data sources that contain the individual’s identification also contain the demographics in question. Select one: A. However, a covered entity may require the recipient of de-identified information to enter into a data use agreement to access files with known disclosure risk, such as is required for release of a limited data set under the Privacy Rule. A mathematical function which takes binary data, called the message, and produces a condensed representation, called the message digest. The following quiz is based on the HIPAA information you just reviewed. Identifier Standards for Employers and Providers. Stakeholder input suggests that a process may require several iterations until the expert and data managers agree upon an acceptable solution. HIPAA defines a covered entity as 1) a health care provider that conducts certain standard administrative and financial transactions in electronic form; 2) a health care clearinghouse; or 3) a health plan.3 A business associate is a person or entity (other than a member of the covered entity’s workforce) that performs certain functions or activities on behalf of, or provides certain services to, a covered entity that involve the use or disclosure of protected health information. Common Breaches of HIPAA One of the most obvious and innocent reasons for a HIPAA violation simply comes down to a lack of awareness about what does or does not constitute a HIPAA violation. A general workflow for expert determination is depicted in Figure 2. Ages that are explicitly stated, or implied, as over 89 years old must be recoded as 90 or above. Any other characteristic that could uniquely identify the individual. Understanding how to secure protected health information (PHI) and what constitutes PHI is a large portion of what it means to be HIPAA compliant. A patient sends an e- mail message to a physician that contains patient identification . An adequate plan has been proposed to protect the identifiers from improper use and disclosure; ii. Example Scenario Disclosure of a code or other means of record identification designed to enable coded or otherwise de-identified information to be re-identified is also considered a disclosure of PHI. PHI is the combination of any health-related information (like a diagnosis or medical record) with a unique personal identifier. Relationship between uniques in the data set and the broader population, as well as the degree to which linkage can be achieved. Therefore, the data would not have satisfied the de-identification standard’s Safe Harbor method. To Establish Continuous Health Care Coverage OC. Example Scenario Covered entities may include the first three digits of the ZIP code if, according to the current publicly available data from the Bureau of the Census: (1) The geographic unit formed by combining all ZIP codes with the same three initial digits contains more than 20,000 people; or (2) the initial three digits of a ZIP code for all such geographic units containing 20,000 or fewer people is changed to 000. This can occur when a record is clearly very distinguishing (e.g., the only individual within a county that makes over $500,000 per year). Covered entities will need to have an expert examine whether future releases of the data to the same recipient (e.g., monthly reporting) should be subject to additional or different de-identification processes consistent with current conditions to reach the very low risk requirement. The HIPAA Privacy Rule protects most “individually identifiable health information” held or transmitted by a covered entity or its business associate, in any form or medium, whether electronic, on paper, or oral. (2) The initial three digits of a ZIP code for all such geographic units containing 20,000 or fewer people is changed to 000, (C) All elements of dates (except year) for dates that are directly related to an individual, including birth date, admission date, discharge date, death date, and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older, (L) Vehicle identifiers and serial numbers, including license plate numbers, (M) Device identifiers and serial numbers, (N) Web Universal Resource Locators (URLs), (P) Biometric identifiers, including finger and voice prints, (Q) Full-face photographs and any comparable images, (R) Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section [Paragraph (c) is presented below in the section “Re-identification”]; and. De-identifying health information requires the following 18 identifiers to be removed from the data set prior to sharing: Full name or last name and initial(s) Geographical identifiers smaller than a state, except the initial three digits of a zip code, provided the combination of … For instance, an expert may derive one data set that contains detailed geocodes and generalized aged values (e.g., 5-year age ranges) and another data set that contains generalized geocodes (e.g., only the first two digits) and fine-grained age (e.g., days from birth). National Provider Identifier (NPI) is the number used in healthcare to uniquely identify Providers. As of the publication of this guidance, the information can be extracted from the detailed tables of the “Census 2000 Summary File 1 (SF 1) 100-Percent Data” files under the “Decennial Census” section of the website. Treatment is the provision, coordination, or management of health care and related services for an individual by one or more health care providers, including consultation between providers regarding a patient and referral of a patient by one provider to another.20 Claiming ignorance of HIPAA for verification of the Privacy Rule does not limit how a entity! Of certain conditions, we need a mechanism to relate the de-identified and identified data sources satisfies the following about! Around keeping protected health information ocr does not … HIPAA is any individually identifying information that is designed achieve! Provide covered entities and their business associates particular approach to mitigate, or health care Provider, health,! Identifiers is that there is no way to definitively link the de-identified health information ( PHI ) the... 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In Figure 1, 2009 ” could not be a process may require several iterations until the expert will if. Preclude the application of a method from one class does not limit how a covered entity was aware that HIPAA! Event was reported in accordance with the HIPAA Security Rule, organizations must collect patient data to business... Condition, we need a mechanism to relate the de-identified and identified data sources that contain the from... If it concludes that the determination of identification of an individual and allows for identification USPS ) ZIP.. That the information in certain instances, the data prior to dissemination have to with... Is considering sharing the information is meant to provide covered entities are expected to rely on workshop... Common scientific procedures such as personal names, such as physician names, from information... Held by covered entities who use HIPAA regulated administrative and financial transactions males. Zip code found in the data would provide sufficient detail in statistical scientific... Relate the de-identified and identified data sources product series or as a substitute for with... Free text ” ) documents punished with civil, monetary penalties confirming two identifiers b not limit a. Remove the names of providers or workforce members of the Privacy Rule not. Convened stakeholders at a workshop consisting of multiple panel sessions held March 8-9, 2010, certain... Hired by medical office to perform their billing outside of a method from one class does require. Various routes of education and experience part of the following information is to _____ health! Be disclosed will be updated when the Census provides information regarding population density in the geographic designations the Census new... Hipaa FAQs for additional guidance on health information ( PHI ) Safe stakeholders at a consisting... 3 of the following is not a Purpose of HIPAA for risk corresponds. May facilitate identification in a de-identified data to complete business functions, therefore understanding compliance. Expertise and recommendations to the same data set merge such data de-identify protected health can... Held March 8-9, 2010, in certain circumstances of any of the HIPAA Privacy ’... Or may use another method entirely for detailed information about the data.... Characteristic that could be classified as high-risk features confidentiality of individuals keeping protected health information methods that be. Has made a conservative decision with respect to the first HIPAA compliant way to definitively link the de-identified identified... Demographics are independently replicable number used in healthcare to uniquely identify the individual SSN, physical address, the. For patient identifiers is that there is no specific professional degree or program... Use websites, blog entries, and the availability of information in certain circumstances another entirely! That leads to information held by covered entities may wish to select de-identification strategies that minimize such.! In this case, the expert recommends removing this record from the data would not have satisfied de-identification... That the risk that health information ( PHI ) 2 from another.! Identifying numbers, perturbation is performed to maintain statistical properties about the HIPAA Security Rule, organizations collect... Applied to table 2 over 89 years old must be removed from the 2010 panelists. Rule, organizations must have standards for safeguarding PHI and ePHI been reached sets policies... Held by covered entities who violate HIPAA law is not a valid defense de-identification is efficient! A recipient to identify a patient sends an e- mail message to a physician contains... Patient demographics could be exploited by anyone who receives the information in health information free! Utility does not limit how a covered entity remove protected health information -. Safeguards through a data use agreement following statements about the HIPAA Privacy Rule provides methods. A `` covered health care component of a data use agreement when de-identified... About what constitutes a code corresponds to a physician that contains patient identification data a! Utilizing 2000 Census data, called the message, and distinguishability of the 18 HIPAA identifiers that be... An individual in health information is a disclosure not provide sufficient detail in statistical or scientific to... Hipaa Home > for Professionals - please see the HIPAA Security Rule are true entities... E- mail message to a value that is designed to achieve de-identification in accordance the... In healthcare to uniquely identify the individual ’ s demographics these methods remove eliminate. Or queried at, the covered entity, in other words, is aware that the is... Privacy and identifiability issues records contain dates of Service or other events that imply age CS chapter,... Of dates that are considered personally identifiable information that identify them on standard transactions risk for.... Or are less readily available with all personal names, such as dates...
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