Is there any limitation on a covered entity's de-identification of PHI or use of de-identified information? For example, may a covered entity de-identify information purely for the purposes of selling data as a service? Additionally, from a Privacy Rule perspective (i.e., not considering state law or contractual considerations), are there any restrictions on a business associate using or disclosing the de-identified... more »
We are not a covered entity or business associate. We are developing a direct-to-consumer app that tracks medication adherence. We want to de-identify the information the app collects to sell to third parties. Do we follow the same HIPAA de-identification processes that a covered entity or business associate would follow?
We have developed a platform to facilitate the scheduling of transport/rides for patients to provider appointments. The process works as follows. The provider logs into a secure site, to schedule a ride to an appointment for a patient. The platform, at the appropriate time, sends formation to a rider service provider (someone such as Lyft, Uber, etc..) to schedule the transport. The information provide the transport... more »
Assuming all other identifiers are removed from the data, which dates are considered PHI? The de-identification standard for safe harbor indicates the following must be removed: "(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... more »
I'm working on a free web application for use by healthcare providers that tracks the usage of antibiotics. I intend to make the application available to anyone as a tool without entering into any formal agreements. The tool would track such information as: facility census, medication name, dosage, date given, etc. patient age, gender, height, weight, etc. The tool would NOT use identifying information such as name,... more »
We are scheduling patients through an online scheduling app. We've been told patients are de-identified if we only use the first three letters of their first and last name for the scheduling portal. Could you confirm whether or not this is HIPAA compliant?