Health Information Management

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

HIM-HIPAA Insider, September 15, 2014

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Submit your HIPAA questions to Editor Jaclyn Fitzgerald at jfitzgerald@hcpro.com and we will work with our experts to provide you with the information you need.

 
Q: I understand that a patient's insurance identification number (ID) is considered individually identifiable health information. Is disclosure of a patient's name and his or her ID without any reference to provision of healthcare a breach of PHI, or is it simply an incident that could lead to identity theft?
 
A: If the patients' names and IDs were not secure and the information was breached, this constitutes a breach of unsecure PHI. Covered entities are required to assume notification is required and conduct a four-factor risk assessment to determine the risk to the patients. After you conduct the risk assessment, if you determine the risk to the patients is low, you do not need to notify patients. Click here for more information about breach notification requirements.
 
A breach of patient names and health plan IDs could lead to medical identity theft Black market criminals who collect information about individuals over time may pick up this breached electronic information. They may be able to collect enough information to commit medical identity theft (e.g., filing false Medicare and Medicaid claims).
 
Editor’s note: Chris Apgar, CISSP, president of Apgar & Associates, LLC, in Portland, Oregon, answered this question for HCPro’s Briefings on HIPAA newsletter.



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