HIPAA Q&A: You’ve got questions. We’ve got answers!
HIM-HIPAA Insider, April 7, 2014
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In last week’s HIPAA Q&A, our HIPAA expert mentioned that it was appropriate to send emails containing PHI as long as your organization’s server is secured. In instances where a server is not secured, patients should be de-identified. For example, you could refer to someone as "the patient in room 301-A" because a room number is not considered an identifier under HIPAA. In response, one of our readers submitted a follow-up question about identifiers.
Q: My organization views a patient’s room number as an identifier because we think this is information that someone could use to identify the patient. Please explain why this is not considered an identifier? A: A patient’s room number is not considered “identifiable” under the HIPAA Privacy Rule. PHI is considered identifiable if it contains any one of 18 identifiers of individuals and their family members, employers, or household members, including:
- Names
- Geographic subdivisions smaller than a state
- All elements of dates (except for year) for birth, admission, discharge, and death
- All ages over 89, including year
- Telephone numbers
- Fax numbers
- Email addresses
- Social Security numbers
- Medical record numbers
- Health plan beneficiary numbers
- Account numbers
- Certificate/license numbers
- Vehicle identifiers
- Device identifiers
- URLs
- IP addresses
- Biometric identifiers, including fingerprints and voiceprints
- Full-face photographas
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