As the NPI is a 10-position, intelligence-free numeric identifier (10-digit number), it does not disclose other information about health care providers. During the year of this event, it is highly possible that this occurred for only one individual in the hospital (and perhaps the country). (2) Relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to the individual; and Figure 2. 17 thoughts on “18 Patient Identifiers HIPAA Defines as Off Limits” Becky. Statement that the alteration/waiver satisfies the following 3 criteria: a. For example, if the patient’s year of birth is 1910 and the year of healthcare service is reported as 2010, then in the de-identified data set the year of birth should be reported as “on or before 1920.” Otherwise, a recipient of the data set would learn that the age of the patient is approximately 100. The lack of a readily available naming data source does not imply that data are sufficiently protected from future identification, but it does indicate that it is harder to re-identify an individual, or group of individuals, given the data sources at hand. Therefore, it’s essential that you require regular compliance training so that employees know what they can or … Each panel addressed a specific topic related to the Privacy Rule’s de-identification methodologies and policies. No. The ability of a recipient of information to identify an individual (i.e., subject of the information) is dependent on many factors, which an expert will need to take into account while assessing the risk from a data set. March 2003. As the NPI is a 10-position, intelligence-free numeric identifier (10-digit number), it does not disclose other information about health care providers. Some of the methods described below have been reviewed by the Federal Committee on Statistical Methodology16, which was referenced in the original preamble guidance to the Privacy Rule de-identification standard and recently revised. Yes. Identifying Characteristic Therefore, the data would not have satisfied the de-identification standard’s Safe Harbor method. For instance, a patient’s age may be reported as a random value within a 5-year window of the actual age. Linkage between the records in the tables is possible through the demographics. For instance, voter registration registries are free in the state of North Carolina, but cost over $15,000 in the state of Wisconsin. The following are considered identifiers under the HIPAA safe harbor rule: (A) Names; (B) All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census: Thus, by relying on the statistics derived from the data set, the expert will make a conservative estimate regarding the uniqueness of records. In the process, experts are advised to consider how data sources that are available to a recipient of health information (e.g., computer systems that contain information about patients) could be utilized for identification of an individual.8. Beyond this data, there exists a voter registration data source, which contains personal names, as well as demographics (i.e., Birthdate, ZIP Code, and Gender), which are also distinguishing. Question 7: A patient who pays for 100% of treatment out of pocket can stop disclosure of this information to his/her insurer. No. The HIPAA privacy rule sets forth policies to protect all individually identifiable health information that is held or transmitted. Imagine a covered entity was aware that the anticipated recipient, a researcher who is an employee of the covered entity, had a family member in the data (e.g., spouse, parent, child, or sibling). Which of the following is an example of when PHI would be sent with all personal identifiers are removed from the data set? Postal Service (USPS) ZIP code service areas. The use/disclosure of PHI involves no more than minimal risk to the privacy of individuals, based on at least the following elements: i. Identifiers. The covered entity does not use or disclose the code or other means of record identification for any other purpose, and does not disclose the mechanism for re-identification. Rare clinical events may facilitate identification in a clear and direct manner. The greater the replicability, availability, and distinguishability of the health information, the greater the risk for identification. This could occur, for instance, if the data set includes patients over one year-old but the population to which it is compared includes data on people over 18 years old (e.g., registered voters). (2) Relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual. When sufficient documentation is provided, it is straightforward to redact the appropriate fields. Finally, for the third condition, we need a mechanism to relate the de-identified and identified data sources. Such codes or other means of record identification assigned by the covered entity are not considered direct identifiers that must be removed under (R) if the covered entity follows the directions provided in §164.514(c). In contrast, lower risk features are those that do not appear in public records or are less readily available. These methods transform data into more abstract representations. For example, a data set that contained patient initials, or the last four digits of a Social Security number, would not meet the requirement of the Safe Harbor method for de-identification. To inspect and copy his or her health information b. Postal Service ZIP codes either as part of the Census 2000 product series or as a post Census 2000 product. This means that a covered entity has actual knowledge if it concludes that the remaining information could be used to identify the individual. However, many researchers have observed that identifiers in medical information are not always clearly labeled.37.38 As such, in some electronic health record systems it may be difficult to discern what a particular term or phrase corresponds to (e.g., is 5/97 a date or a ratio?). As another example, an increasing quantity of electronic medical record and electronic prescribing systems assign and embed barcodes into patient records and their medications. 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. The first condition is that the de-identified data are unique or “distinguishing.” It should be recognized, however, that the ability to distinguish data is, by itself, insufficient to compromise the corresponding patient’s privacy. In 1999, Congress passed legislation prohibiting the Department of Health and Human Services (HHS) from funding, implementing or developing a unique patient identifier system. Home > Office of Human Subjects Research - Institutional Review Board > HIPAA and Research Definition of De-Identified Data. Identifiers are HIPAA standards that will create a uniform and centralized way to designate an employer, provider, health plan or patient in electronic transactions. In an effort to make this guidance a useful tool for HIPAA covered entities and business associates, we welcome and appreciate your sending us any feedback or suggestions to improve this guidance. This information can be used to identify, contact, or locate a single person or can be used with other sources to identify a single individual. a. Choose which is not a valid identifier in the following? In practice, perturbation is performed to maintain statistical properties about the original data, such as mean or variance. For instance, imagine the information in a patient record revealed that a patient gave birth to an unusually large number of children at the same time. A passing grade of 80% or higher is required for all contractors coming aboard for CHP and must be completed at least 48 hours before arriving at the client site. a health care provider that conducts certain transactions in electronic form (called here a "covered health care provider"). The first two rows (i.e., shaded light gray) and last two rows (i.e., shaded dark gray) correspond to patient records with the same combination of generalized and suppressed values for Age, Gender, and ZIP Code. This new methodology also is briefly described below, as it will likely be of interest to all users of data tabulated by ZIP code. Based on this observation, the expert recommends removing this record from the data set. 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. Toll Free Call Center: 1-800-368-1019 Answer: 2 question Which of the following is not a purpose of HIPAA - the answers to estudyassistant.com Of course, de-identification leads to information loss which may limit the usefulness of the resulting health information in certain circumstances. Elements of dates that are not permitted for disclosure include the day, month, and any other information that is more specific than the year of an event. 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 The same applies to education or employment records. For example, the preamble to the Privacy Rule at 65 FR 82462, 82712 (Dec. 28, 2000) noted that “Clinical trial record numbers are included in the general category of ‘any other unique identifying number, characteristic, or code.’. A patient sends an e- mail message to a physician that contains patient identification . This is because the resulting value would be susceptible to compromise by the recipient of such data. 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). The first is the “Expert Determination” method: (b) Implementation specifications: requirements for de-identification of protected health information. The following information is meant to provide covered entities with a general understanding of the de-identification process applied by an expert. § 164.514 Other requirements relating to uses and disclosures of protected health information. Further information about data use agreements can be found on the OCR website.36 Covered entities may make their own assessments whether such additional oversight is appropriate. Stakeholder input suggests that the determination of identification risk can be a process that consists of a series of steps. HIPAA is an acronym that stands for the Health Insurance Portability and Accountability Act of 1996. 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. Which of the following are valid identifiers and why/why not : Data_rec, _data, 1 data, datal, my.file, elif, switch, lambda, break ? In this sense, the expert will assess the expected change of computational capability, as well as access to various data sources, and then determine an appropriate timeframe within which the health information will be considered reasonably protected from identification of an individual. (Of course, the expert must also reduce the risk that the data sets could be combined with prior versions of the de-identified dataset or with other publically available datasets to identify an individual.) For clarification, our guidance is similar to that provided by the National Institutes of Standards and Technology (NIST)29, which states: “De-identified information can be re-identified (rendered distinguishable) by using a code, algorithm, or pseudonym that is assigned to individual records. In §164.514(b), the Expert Determination method for de-identification is defined as follows: (1) A person with appropriate knowledge of and experience with generally accepted statistical and scientific principles and methods for rendering information not individually identifiable: (a) Standard: de-identification of protected health information. For instance, a five-digit ZIP Code may be generalized to a four-digit ZIP Code, which in turn may be generalized to a three-digit ZIP Code, and onward so as to disclose data with lesser degrees of granularity. See the OCR website http://www.hhs.gov/ocr/privacy/ for detailed information about the Privacy Rule and how it protects the privacy of health information. company hired by medical office to perform their billing. The process of de-identification, by which identifiers are removed from the health information, mitigates privacy risks to individuals and thereby supports the secondary use of data for comparative effectiveness studies, policy assessment, life sciences research, and other endeavors. National Provider Identifier (NPI) is the number used in healthcare to uniquely identify Providers. An adequate plan has been proposed to protect the identifiers from improper use and disclosure; ii. Select one: A. 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