Health Information Management

HIPAA Q&A: De-identifying pill bottles

HIM-HIPAA Insider, March 26, 2012

Q. Some of the medications we receive for our assisted living residents are in blister packs. After the pack is emptied, the labels are easily torn off and shredded. However, some medications are received in a multidose pill bottle. Is using a felt-tip marker an acceptable means to de-identify these labels before placing the bottles in the trash?

A. Yes. Obliterating patient identification (including name and medical record number) with a permanent marker is a good way to protect patient privacy before disposing of these containers.

Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, a nationally recognized expert on patient privacy, information security, and regulatory compliance, answered this question. She is associate executive director of Health Information Management (HIM) at Scott & White Healthcare in Temple, TX. Some of her publications were used as a basis for the Health Insurance Portability and Accountability Act of 1996 privacy regulations.


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