IIHI HIPAA Definition and Its Importance in Healthcare

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The Health Insurance Portability and Accountability Act (HIPAA) is a crucial piece of legislation in the United States that aims to protect the confidentiality, integrity, and availability of individually identifiable health information.

HIPAA is a federal law that sets national standards for the protection of sensitive patient health information. This includes any information that can be linked to a specific individual, such as their medical history, test results, or demographic data.

The HIPAA law requires healthcare providers, health plans, and healthcare clearinghouses to implement administrative, technical, and physical safeguards to ensure the confidentiality, integrity, and availability of protected health information (PHI).

On a similar theme: What Are Hipaa Rules

Protected Health Information (PHI)

Protected Health Information (PHI) refers to any health information that includes one or more of the 18 elements identified by HIPAA. These elements make medical information identifiable.

HIPAA defines PHI as any health information that includes any of the 18 elements identified by HIPAA and maintained by a covered entity. This information can be used to identify a person.

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To qualify as PHI, the health information must be transmitted or maintained in some form, such as electronic media, paper documents, or any other medium. This means that if you remove all identifiers, the information is no longer PHI.

The 18 identifiers that make medical information identifiable are listed by HIPAA. Some of these identifiers include names, dates of birth, social security numbers, and medical record numbers.

Here are the 18 identifiers listed by HIPAA:

  • Names (full name or last name and initial)
  • All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes
  • All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, and date of death
  • Telephone numbers
  • Fax numbers
  • Email addresses
  • Social Security Numbers
  • Medical record numbers
  • Health plan beneficiary numbers
  • Account numbers
  • Certificate/license numbers
  • Vehicle identifiers, such as serial numbers and license plate numbers
  • Device identifiers and serial numbers
  • Web Universal Resource Locators (URLs)
  • Internet Protocol (IP) address numbers
  • Biometric identifiers, including finger, retinal, and voice prints
  • Full face photos and any comparable images
  • Any other unique identifying number, characteristic, or code

PHI is created or received by a healthcare provider, health plan, employer, or healthcare clearinghouse and relates to the past, present, or future physical or mental health or condition of a person. It also identifies an individual or can be used to identify an individual.

18 Identifiers

HIPAA defines 18 identifiers that create Protected Health Information (PHI) when linked to health information. These identifiers can be used in combination with other health information to identify an individual.

Worth a look: Hipaa Phi Identifiers

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The 18 identifiers include names, all geographic subdivisions smaller than a State, such as street address, city, county, precinct, zip code, and their equivalent geocodes. This means if you have a patient's street address, it's considered PHI.

Names are also considered PHI, including full names or last names and initials. For example, if you have a patient's full name and their medical record number, it's PHI.

All elements of dates, except year, are also considered PHI, including birth date, admission date, discharge date, and date of death. This includes all ages over 89 and all elements of dates (including year) indicative of such age.

Phone numbers, fax numbers, and electronic mail addresses are also PHI identifiers. This means if you have a patient's phone number and their lab test results, it's PHI.

Social Security numbers, medical record numbers, health plan beneficiary numbers, and account numbers are all considered PHI identifiers. This includes certificate/license numbers, vehicle identifiers, and serial numbers, such as license plate numbers.

Device identifiers and serial numbers, web Universal Resource Locators (URLs), and Internet Protocol (IP) address numbers are also PHI identifiers. Biometric identifiers, including finger and voice prints, are also considered PHI.

For another approach, see: What Information Is Protected in Hipaa

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Full face photographic images and any comparable images are also PHI identifiers. Any other unique identifying number, characteristic, or code is also considered PHI.

Here is a list of the 18 identifiers:

  1. Names
  2. All geographic subdivisions smaller than a State
  3. All elements of dates (except year)
  4. Phone numbers
  5. Fax numbers
  6. Email addresses
  7. Social Security numbers
  8. Medical record numbers
  9. Health plan beneficiary numbers
  10. Account numbers
  11. Certificate/license numbers
  12. Vehicle identifiers and serial numbers
  13. Device identifiers and serial numbers
  14. Web Universal Resource Locators (URLs)
  15. Internet Protocol (IP) address numbers
  16. Biometric identifiers
  17. Full face photographic images
  18. Any other unique identifying number, characteristic, or code

Examples and Non-Examples

Our practice may use and disclose your individually identifiable health information (IIHI) for various purposes, but with certain restrictions.

We may use your IIHI to bill you directly for services and items, or to operate our business.

You have the right to request that we restrict our disclosure of your IIHI to only certain individuals involved in your care or the payment for your care.

Here are some examples of how we may use and disclose your IIHI, categorized by purpose:

  • Business Operations: Our practice may use and disclose your IIHI to operate our business.
  • Payment and Billing: We may use your IIHI to bill you directly for services and items, or to bill and collect payment for the services and items you may receive from us.
  • Research and Care: Our practice may use and disclose your IIHI for research purposes in certain limited circumstances, or to provide care to you.

Examples of PHI Identifiers

Names are a key identifier that makes information PHI. This includes full names, last names with initials, and even just last names.

According to HIPAA, there are 17 other identifiers that make medical information identifiable. These include:

  • Street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code
  • All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, and date of death
  • Telephone numbers, fax numbers, and email addresses
  • Social Security Numbers, medical record numbers, health plan beneficiary numbers, and account numbers
  • Certificate/license numbers, vehicle identifiers, and serial numbers
  • Device identifiers and serial numbers, Web Universal Resource Locators (URLs), and Internet Protocol (IP) address numbers
  • Biometric identifiers, including finger, retinal, and voice prints, and full face photos and any comparable images
  • Any other unique identifying number, characteristic, or code

These identifiers can be used in combination with other health information to identify an individual, making it PHI under HIPAA.

Non-PHI Examples

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In many cases, medical information isn't considered PHI because it lacks necessary identifiers. For instance, a piece of paper found on the ground with a person's name and admission date is not PHI because it doesn't list the name of a hospital and may not represent a person's medical treatment.

A lost piece of paper with a person's name and admission date is not PHI because it's unclear if the admission date refers to a hospital stay or something else entirely.

Sometimes, medical information is not PHI because it's not attached to any identifiers. For example, an X-ray of a hand without any attached information is not PHI because it's impossible to know to whom it belongs.

In the radiology department, an X-ray of a hand is not considered PHI if no information is attached to the image.

Non-PHI examples can be confusing, but they're essential to understanding what does and doesn't qualify as PHI.

Managing PHI

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Managing PHI requires a solid understanding of what constitutes Protected Health Information (PHI) under HIPAA. This includes understanding what is and isn't PHI, and reinforcing this information regularly to ensure it remains private and secure.

Employee training is essential in educating staff on what constitutes PHI and how to handle it properly. Posters and email reminders can also be used to reinforce the details and ensure compliance.

Under HIPAA, any organization or individual handling PHI regularly is considered a covered entity and must follow the regulation's security and privacy rules. Providers, insurers, and healthcare clearinghouses are all considered covered entities.

A business associate under HIPAA is a third party that handles PHI on behalf of a covered entity. This can include health information exchanges (HIEs) that transmit PHI on behalf of healthcare providers.

To ensure telehealth services are secure, consider implementing measures such as encryption and secure communication protocols. This will help protect patient data and maintain trust in online healthcare services.

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Here are some key points to consider when managing PHI:

• Covered entities must follow HIPAA's security and privacy rules.

• Business associates must also comply with HIPAA regulations.

• PHI includes a wide range of patient data, including medical records and billing information.

• Employees must be trained on handling PHI properly to ensure compliance.

• Regular reminders and reinforcement are necessary to maintain a secure and private environment for PHI.

By understanding and following these guidelines, you can help ensure the secure handling of PHI and maintain compliance with HIPAA regulations.

HIPAA and PHI

HIPAA and PHI are crucial concepts in the healthcare industry, and understanding them is vital for protecting patient data. HIPAA stands for the Health Insurance Portability and Accountability Act, which protects patients from inappropriate disclosures of their protected health information (PHI).

Covered entities under HIPAA include providers, insurers, and healthcare clearinghouses, as well as business associates that handle PHI on their behalf. This means that any organization or individual that handles PHI regularly must follow HIPAA's security and privacy rules.

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PHI is defined as medical information that includes at least one identifying piece of information, such as names, phone numbers, or dates of birth. Examples of PHI include patient records with names, appointment dates, and expected procedures, as well as lab test results with names and dates of birth.

The HIPAA Privacy Rule governs how hospitals, ambulatory care centers, and other healthcare providers use and share PHI. It gives patients certain rights with respect to their information, including the right to make written requests to amend PHI that a covered entity maintains.

Organizations cannot sell PHI unless in specific circumstances, such as for a public health purpose or for research, but only for reimbursement of costs. Business associates that sign HIPAA business associate agreements are legally bound to handle patient data according to the HIPAA Privacy and Security Rules.

Here's a summary of the key differences between PHI, PII, and IIHI:

HIPAA rules regulate both paper and electronic data sets equally, but there are differences between the two formats. For example, covered entities must respond to patients' requests for access to their data within 30 days for paper records, but HIPAA rules state that if the provider is using health IT, the patient should be able to get the records faster.

45 CFR § 160.103 - Definitions

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Protected Health Information (PHI) is a crucial aspect of HIPAA, and understanding its definition is essential. According to HIPAA, PHI includes individually identifiable health information (IIHI) that is transmitted by electronic media, maintained in electronic media, or transmitted or maintained in any other form or medium.

PHI is not just limited to electronic records; it also includes paper documents stored in physical locations. This means that any health information that can identify a person, regardless of the format, is considered PHI if it's handled by a covered entity.

To qualify as PHI, IIHI must be transmitted or maintained in some form. If it's not handled by a covered entity, it's not considered PHI, even if it's sensitive information.

Here are the 18 elements identified by HIPAA that can make health information PHI:

  • Past, present or future physical or mental health or condition of a patient
  • Provision of healthcare to an individual
  • Past, present, or future payment for the provision of healthcare to an individual until 50 years following the date of death of the individual

These elements are the foundation of what makes health information PHI. Remember, not all IIHI is PHI, but all PHI is IIHI.

Compliance and Enforcement

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HIPAA compliance and enforcement are crucial for healthcare organizations. HIPAA rules require covered entities to defend against threats to protected health information (PHI) that can be reasonably anticipated.

The OCR announced enforcement discretion for Community Based Testing Sites for COVID-19 testing on April 9, 2020. This means that these sites were temporarily exempt from certain HIPAA requirements.

Covered entities must implement technical, administrative, and physical safeguards to protect PHI. These safeguards include firewalls, encryption, access controls, and other technology to prevent unauthorized access.

Here are the three types of safeguards:

  • Technical safeguards: firewalls, encryption, access controls, and other technology.
  • Physical safeguards: locking up physical records, keycards, and other access controls on electronic devices containing PHI.
  • Administrative safeguards: policies that limit PHI access to certain people, safety awareness training, and other people-based approaches to security.

HIPAA rules don't specify the types of technology needed, but covered organizations must take action to keep hackers and malware from gaining access to patient data.

Compliance

Compliance is a critical aspect of protecting Protected Health Information (PHI). HIPAA compliance and security require covered entities to defend against threats to PHI that can be reasonably anticipated.

To achieve this, covered entities must implement technical, administrative, and physical safeguards to protect PHI. These safeguards include using firewalls, encryption, access controls, and other technology to secure electronic devices containing PHI.

Take a look at this: 3 Hipaa Safeguards

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Physical safeguards, on the other hand, involve locking up physical records, using keycards and other access controls, making screens unreadable to anyone except the user, and other measures to prevent unauthorized access.

Administrative safeguards include policies that limit PHI access to certain people, safety awareness training, and other people-based approaches to security.

Covered entities must also evaluate IT capabilities and the likelihood of a PHI security risk. HIPAA rules don't specify the types of technology needed, but covered organizations must take action to keep hackers and malware from gaining access to patient data.

In addition to HIPAA, other regulations affecting PHI include the European Union's General Data Protection Regulation (GDPR). This regulation applies to a broader set of health data, including genetics, and requires healthcare organizations that treat EU patients to adhere to GDPR regulations about patient consent to process PHI.

It's essential to regularly reinforce the specifics of what qualifies as PHI and what is not to ensure that your team understands the importance of keeping this information private and secure.

Employee training should educate the team on what is and is not PHI, and posters and email reminders can be used to reinforce the details to ensure compliance.

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To avoid common misconceptions about PHI, it's crucial to understand that security restrictions in place may not fully protect privacy under HIPAA mandates. For example, if a cloud vendor hosts encrypted PHI for an ambulatory clinic, privacy could still be an issue if the cloud vendor isn't part of a business associate agreement.

Here are some key compliance requirements to keep in mind:

  1. Technical safeguards: firewalls, encryption, access controls, and other technology
  2. Physical safeguards: locking up physical records, keycards, and other access controls
  3. Administrative safeguards: policies limiting PHI access, safety awareness training, and other people-based approaches
  4. Evaluate IT capabilities and likelihood of PHI security risk
  5. Regularly reinforce what is and is not PHI

By understanding these compliance requirements, you can ensure that your organization is taking the necessary steps to protect PHI and maintain compliance with HIPAA and other relevant regulations.

Enforcement Discretion Announcement

The OCR announced it will use its enforcement discretion for Community Based Testing Sites for COVID-19 testing on April 9, 2020. This was a significant move to address the pandemic.

The enforcement discretion was announced in response to the growing need for COVID-19 testing. The OCR recognized the importance of testing sites in controlling the spread of the virus.

Additional reading: Enforcement of Hipaa

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On April 9, 2020, the OCR announced the enforcement discretion, allowing testing sites to operate without full HIPAA compliance. This was a temporary measure to increase testing capacity.

The OCR's enforcement discretion was limited to Community Based Testing Sites for COVID-19 testing. This meant that other healthcare providers and organizations were still required to follow HIPAA regulations.

The OCR's announcement was a practical solution to a pressing problem. It allowed testing sites to focus on testing and public health, rather than navigating complex HIPAA regulations.

The enforcement discretion was a one-time announcement, and its terms were not extended to other healthcare providers.

Aaron Osinski

Writer

Aaron Osinski is a versatile writer with a passion for crafting engaging content across various topics. With a keen eye for detail and a knack for storytelling, he has established himself as a reliable voice in the online publishing world. Aaron's areas of expertise include financial journalism, with a focus on personal finance and consumer advocacy.

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