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Health Insurance Portability and Accountability Act (HIPAA)

The Health Insurance Portability and Accountability Act (HIPAA) privacy rule sets forth policies to protect all individually identifiable health information that is held or transmitted. These are the 18 HIPAA Identifiers that are considered personally identifiable information. This information can be used to identify, contact, or locate a single person or can be used with other sources to identify a single individual. When personally identifiable information is used in conjunction with one’s physical or mental health or condition, health care, or one’s payment for that health care, it becomes Protected Health Information (PHI).

HIPAA 18 De-identifying Elements

  1. Names
  2. 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
  3. 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
  4. Telephone numbers
  5. (L) Vehicle identifiers and serial numbers, including license plate numbers
  6. Fax numbers
  7. (M) Device identifiers and serial numbers
  8. Email addresses
  9. (N) Web Universal Resource Locators (URLs)
  10. Social security numbers
  11. (O) Internet Protocol (IP) addresses
  12. Medical record numbers
  13. (P) Biometric identifiers, including finger and voice prints
  14. Health plan beneficiary numbers
  15. (Q) Full-face photographs and any comparable images
  16. Account numbers
  17. (R) Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section
  18. Certificate/license numbers

If a communication contains any of these identifiers, or parts of the identifier, such as initials, the data is to be considered “identified”. To be considered “de-identified”, ALL of the 18 HIPAA Identifiers must be removed from the data set. This includes all dates, such as surgery dates, all voice recordings, and all photographic images.