Health Information Management

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:

  1. Names
  2. Geographic subdivisions smaller than a state
  3. All elements of dates (except for year) for birth, admission, discharge, and death
  4. All ages over 89, including year
  5. Telephone numbers
  6. Fax numbers
  7. Email addresses
  8. Social Security numbers
  9. Medical record numbers
  10. Health plan beneficiary numbers
  11. Account numbers
  12. Certificate/license numbers
  13. Vehicle identifiers
  14. Device identifiers
  15. URLs
  16. IP addresses
  17. Biometric identifiers, including fingerprints and voiceprints
  18. Full-face photographas
While a room number may help a facility’s staff to identify a particular patient, it’s not likely that anyone outside the organization could identify a specific patient based on the room number. Most healthcare organizations regularly move patients from room to room, so I don’t have any concerns about room numbers being patient-identifiable information. The organization may choose to treat the room number as an identifier, but it is not required by HIPAA.
 
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.
 
Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS,vice president of health information at Baylor Scott & White Health in Temple, Texas, answered this question for HCPro’s Briefings on HIPAA newsletter.



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