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De-identifying protected health information

| December 6, 2021

De-identifying protected health information

Just a reminder to members about the rules for sharing protected health information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA). The rules apply to information you may send to the Advocacy Council on reimbursement or other issues.

The Advocacy Council appreciates members informing us of issues surrounding denials of payment for allergy services. We rely on you to keep us informed of changing payer coverage and payment policies. However, communications to the Advocacy Council or College on these or similar issues must not include PHI, as that would be a HIPAA violation and puts the Advocacy Council/College and your practice at risk.

Therefore, it is important that information shared with the Advocacy Council or other entities (unless subject to a HIPAA exception) be de-identified in accordance with HIPAA standards. Specifically, HIPAA rules require that all of the following information be removed:

A. Names
B. All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code
C. All elements of dates (except year) for dates directly related to an individual, including birth date, date of service, admission date, discharge date, date of death; and all ages over 89
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
R. Any other unique identifying number, characteristic, or code

We hope this information will be helpful to you in your practice and in your communications with the Advocacy Council. The Advocacy Council is glad to review and discuss de-identified claims and other information with you.

The Advocacy Council – Advocating for Allergists and Their Patients.

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