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Governance, Risk, Audit & Privacy · Advanced

HIPAA De-identification

Methods by which health information is rendered not individually identifiable and no longer PHI: Safe Harbor or Expert Determination.

Definition

Safe Harbor requires removing 18 specified identifiers (such as names, geographic subdivisions smaller than a state with limited ZIP exceptions, dates except year, and contact numbers) and having no actual knowledge that remaining data could identify individuals. Expert Determination requires a qualified expert to determine the risk of re-identification is very small. De-identified data is not subject to HIPAA.

Example

A research dataset removes names, full dates, and ZIP codes under Safe Harbor.

Exam tip

Know both methods; a limited data set is different and still PHI requiring a data use agreement.

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