Health Information Management

HIPAA Q&A: You've got questions. We've got answers!

HIM-HIPAA Insider, February 24, 2014

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Submit your HIPAA questions to Associate Editor Jaclyn Fitzgerald at jfitzgerald@hcpro.com and we will work with our experts to provide you with the information you need.
 
Q: Some organizations consider any medical record number to be PHI. Others believe the medical record number is not a personal identifier—unless the Social Security number is the medical record number—because anyone who would intercept that number would have no way of identifying the patient based on the number alone. I work for a software vendor, so the medical record number means nothing to us. However, we need to be able to have a way to differentiate between records when working with our clients who sometimes send us medical record numbers (with no other PHI included) via the Internet. Is this acceptable?
 
A: A medical record number is considered PHI. The HIPAA Privacy Rule lists the medical record number as a patient identifier. It is not likely that a person could use the medical record number alone to re-identify a patient. However, if other data such as diagnosis and birthdate are included with the medical record number, transmitting PHI via the Internet is not recommended unless it is encrypted.
 
In the end, it’s important to assess the risk and protect PHI accordingly. If the transmission is intercepted, it would be considered a breach of unsecure PHI, which in this case would be reportable to the covered entity, assuming you represent a business associate.
 
Editor’s note: Chris Apgar, CISSP, president of Apgar & Associates, LLP, in Portland, Ore., answered this question for HCPro’s Briefings on HIPAA newsletter.

 



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