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HIPAA De-Identifying
*The information on this page about HIPAA de-identifiers is for informational purposes only. It is not intended to be complete, definitive, or to be relied on without first consulting legal counsel, as APPIC does not provide legal advice.
Update: 11-14-06 (For 2007 applications): Please place at the top of the sample report the following statement: "All identifying data in this report has been changed to protect client anonymity."
To de-identify information so that it is not
subject to HIPAA, a number of identifying variables must all be taken out. The following identifiers of the individual or of relatives,
employers, or household members of the individual, are removed:
(A) Names;
(B) 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 a 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.
(C) All elements of dates (except year) for dates directly
related to an individual, including birth date, admission date,
discharge date, date of death; 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;
(D) Telephone numbers;
(E) Fax numbers;
(F) Electronic mail addresses;
(G) Social security numbers;
(H) Medical record numbers;
(I) Health plan beneficiary numbers;
(J) Account numbers;
(K) Certificate/license numbers;
(L) Vehicle identifiers and serial numbers, including license
plate
numbers;
(M) Device identifiers and serial numbers;
(N) Web Universal Resource Locators (URLs);
(O) Internet Protocol (IP) address numbers;
(P) Biometric identifiers, including finger and voice prints;
(Q) Full face photographic images and any comparable images; and
(R) Any other unique identifying number, characteristic, or code,
except as permitted by paragraph (c) of this section; and
(ii) The covered entity does not have actual knowledge that the
information could be used alone or in combination with other
information to identify an individual who is a subject of the
information.
14 November 2006
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