Developers and HIPAA

De-identification of individuals' information

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 »

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Developers and HIPAA

Sale of Data Collected by a Consumer Targeted App

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?

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Developers and HIPAA

When is PHI de-identified?

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 »

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Developers and HIPAA

Web app records meds, but not identifiable to patient.

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 »

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Developers and HIPAA

Which Dates are considered PHI?

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 »

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Developers and HIPAA

Which Dates are considered PHI?

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 »

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