De-Identification Guidelines
Under HIPAA regulations, health information is not individually identifiable if it does not identify an individual and if the covered entity (i.e. provider) has no reasonable basis to believe it can be used to identify an individual. De-identified data is not subject to HIPAA regulations. Below outlines the Safe Harbor method, which is one of the two (2) methods to de-identify protected health information under the HIPAA Privacy Rule at 45 C.F.R. § 164.14(b)(2):
(i) The following identifiers of the individual or of relatives, employers, or household members of the individual, are removed:
(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.
Derivatives of any of the listed identifiers cannot be disclosed. For example, a data set that contained patient initials, or the last four digits of a Social Security number, would not meet the requirement of the Safe Harbor method for de-identification.
Review the Department of Health and Human Services Guidance for more details on proper de-Identification of protected health information to ensure the data you are submitting to this site meets the requirements under the Privacy Rule safe harbor method. De-ID Guidance
Section 164.514(a) of the HIPAA Privacy Rule provides the standard for de-identification of protected health information. Sections 164.514(b) and(c) of the Privacy Rule contain the implementation specifications that a covered entity must follow to meet the de-identification standard.