De-identification of Protected Health Information (PHI)
Sharing clinical experiences with your educators is imperative to your nursing education. Sharing your experiences between peers, as case studies, enhances all students learning and makes better prepared nurses. What about HIPAA??
HIPPA (Health Insurance Portability & Accountability Act of 1996). when paper charts were being replaced by electronic health records, in became very easy for medical records to fall into the wrong hands with a simple click. HHS.gov explains, “For example, unless otherwise forbidden by State or local law, without the Privacy Rule patient information held by a health plan could, without the patient’s permission, be passed on to a lender who could then deny the patient’s application for a home mortgage or a credit card, or to an employer who could use it in personnel decisions.” People didn’t want their personal medical information accidentally falling into the wrong hands and becoming public knowledge, especially public figures. This is very understandable and we feel it’s very important to respect everyone’s privacy.
When you share your experiences you share just that, YOUR experiences, your assessments, your critical thinking, your thoughts, what you learned and how you cared. Share the experience and learned knowledge while leaving any and all specific patient identifiers behind.
Below is a check list to be sure your reflective journal entry or case scenario is covered under HIPAA compliance.
Remove the 18 HIPAA Privacy Rule specific identifiers listed in the Privacy Rule and determine there is no other information that may identify the individual. The identifiers are:
- names – “Mr. Q” is fine but feel free to pick a random letter.
- geographic subdivisions smaller than a state
- all elements of dates (except year) related to an individual (including dates of admission, discharge, birth, death and, for individuals over 89 years old, the year of birth must not be used)
- telephone numbers
- FAX numbers
- electronic mail addresses
- Social Security numbers
- medical record numbers
- health plan beneficiary numbers
- account numbers
- certificate/license numbers
- vehicle identifiers and serial numbers including license plates
- device identifiers and serial numbers
- web URLs
- internet protocol addresses
- biometric identifiers (including finger and voice prints)
- full face photos and comparable images
- any unique identifying number, characteristic or code
An example of other information/unique characteristic that may identify the patient would be, “…Mr. P is a professional hockey player admitted for R femur fracture…” Together “professional hockey Player” matched with “femur fracture” could be identifying information as tens of thousands of people could have witnessed the injury on video.
All submissions to Student Nurse Journey will be screened by a Registered Nurse before any materials are published.