It’s hard to understate the benefits of using protected health information (PHI) in your patient engagement efforts. By effectively leveraging PHI, you can create highly-targeted and personalized email marketing campaigns, which have greater potential to connect with your patients and customers – and drive your desired outcomes.
However, before diving in, it’s essential to be aware of HIPAA’s complex compliance requirements and how they govern healthcare organizations’ marketing communications. Chief among these considerations is the concept of PHI identifiers and the role they play in classifying and protecting sensitive patient data. With this in mind, let’s explore HIPAA’s 18 PHI identifiers
What is a PHI Identifier?
Before we detail the 18 different PHI identifiers, it’s crucial to first distinguish between what counts as PHI and what, in reality, is personally identifiable information (PII).
PHI (as well as its digital equivalent or electronic protected health information (ePHI)), is defined as “individually identifiable protected health information” and specifically refers to three classes of data:
- An individual’s past, present, or future physical or mental health or condition.
- The past, present, or future provisioning of health care to an individual.
- The past, present, or future payment-related information for the provisioning of health care to an individual.
In short, for an individual’s PII to be classed as protected health information it must be related to a health condition, their healthcare provision, or the payment of that provision. So, a patient’s email address in isolation, for example, isn’t necessarily PHI. However when combined with any information about their healthcare – such as in a patient engagement email campaign – it would constitute PHI.
Put another way, as HIPAA is designed to enforce standards and best practices in the healthcare industry, it’s concerned with protecting health-related information. While the protection of general PII is of the utmost importance, that’s a significantly larger remit – and, consequently, one that’s shared by a variety of data privacy regulations covering different industries and regions (PCI-DSS, GDPR, etc.).
What are the 18 PHI Identifiers?
With the above background in mind, we now have a clearer understanding of what is classed as PHI and, as a result, what data needs to be de-identified. The HIPAA Privacy Rule provides two methods for the de-identification of PHI: the Expert Determination and Safe Harbour methods.
Expert Determination requires a statistical or scientific expert to assess the PHI and conclude that the risk of it being able to identify a particular patient is very low. Safe Harbour, meanwhile, involves systematically removing or securing specific data types to mitigate the risk of patient identification. It’s from the Safe Harbour method that we get the following 18 PHI identifiers:
- Patient Names
- Geographical Elements: street address, city, and all other subdivisions lower than the state.
- Dates Related to Patient’s ID or Health History: eD.O.B, D.O.D, admission and discharge dates, etc.
- Telephone Numbers
- Fax Numbers
- Email Addresses
- Social Security Numbers
- Medical Record Numbers
- Health Insurance Beneficiary Numbers
- Account Numbers
- Certificate or License Numbers: as these can confirm an individual’s professional qualifications or credentials, and when combined with PHI, are exploitable by malicious actors.
- Vehicle Identifiers: i.e., license plate and serial numbers
- Device Identifiers and Serial Numbers: those belonging to smartphones, tablets, or medical devices, because they communicate with healthcare companies during provision and can be linked back to the patient
- Digital Identifiers: namely website addresses used by healthcare companies that patients may visit (for healthcare education, event registration, etc.)
- Internet Protocol (IP) Addresses: the digital location from where a patient’s device accesses the internet; this can be used to acquire subsequent PHI
- Biometric Identifiers: e.g., fingerprints, voice samples, etc.
- Full Face Photographs: in additional to other comparable images
- Other Unique Numbers, Codes, or Characteristics: not covered by the prior 17 categories
As illustrated by the above list, HIPAA’s list of PHI identifiers is comprehensive, covering all aspects of an individual’s identity and digital footprint. In light of this, when handling patient data it’s crucial to use platforms and digital solutions that have been designed with the secure transmission and storage of PHI in mind.
Harness the Benefits of Using PHI for Better Patient Engagement
As the most experienced provider of HIPAA-compliant communications, LuxSci specializes in secure email, text, marketing and forms for healthcare providers, payers and suppliers. LuxSci’s Secure Healthcare Communications suite offers flexible encryption, customizable security policies, and automated features to ensure HIPAA compliance and the protection of PHI data.
Interested in discovering how LuxSci’s solutions can help you securely engage with your patients and customers?
Contact us today!
