Developers and HIPAA

When does a Patient Record(PR) become realized?

The topic came up in a planning session around the point in time when a PR becomes a PR. Let's say we are writing an app for first responders. If the user collects name, date of birth, and vital signs. Does the PR become legally protected as soon as the First name is collected, or is there some threshold of data size(fields, values, etc.) that indicates that the PR has been created in legal terms for HIPPA protection? Thanks!

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Question No. 99