HIPAA PHI: A Brief Review of 18 Identifiers and Definition of PHI

When I work with colleagues on matters related to the EHR, I have to redact identifying data from documents or screenshots in the EHR.
This post defines a few key terms related to this kind of work and lists resources.

Eighteen identifiers must be redacted from documents or screenshots.

Terms

Electronic protected health information (ePHI) refers to any protected health information (PHI) that is covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA)

Resources

HHS

The U.S. Department of Health & Human Services (HHS) website lists methods  two methods to achieve de-identification in accordance with the HIPAA Privacy Rule. 

  • I have copied from the HHS website the 18 identifiers using the “Safe Harbor” method for de-identification.
  • The following identifiers of the individual or of relatives, employers, or household members of the individual, are removed:

(A) Names

(B) All geographic subdivisions smaller than a state, including street address, city, county, precinct, ZIP code, and their equivalent geocodes, except for the initial three digits of the ZIP code if, according to the current publicly available data from the Bureau of the Census:
(1) The geographic unit formed by combining all ZIP codes with the same three initial digits contains more than 20,000 people; and
(2) The initial three digits of a ZIP code for all such geographic units containing 20,000 or fewer people is changed to 000

(C) All elements of dates (except year) for dates that are directly related to an individual, including birth date, admission date, discharge date, death date, and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older

(D) Telephone numbers

(L) Vehicle identifiers and serial numbers, including license plate numbers

(E) Fax numbers

(M) Device identifiers and serial numbers

(F) Email addresses

(N) Web Universal Resource Locators (URLs)

(G) Social security numbers

(O) Internet Protocol (IP) addresses

(H) Medical record numbers

(P) Biometric identifiers, including finger and voice prints

(I) Health plan beneficiary numbers

(Q) Full-face photographs and any comparable images

(J) Account numbers

(R) Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section [Paragraph (c) is presented below in the section “Re-identification”]; and

(K) Certificate/license numbers”

More Resources

UC Berkely: HIPAA PHI: List of 18 Identifiers and Definition of PHI

The University of Michigan, Michigan Medicine Wiki,  ePHI and Sensitive Regulated Data

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Created and maintained by Raf Rizk, MD | Division of Gastroenterology | Michigan Medicine

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