I
agree that this issue also pertains to test data, which is a big issue for me
at the moment. We are also considering scrambling the data, and I would
like to be copied on any additional suggestions.
We too are looking
at this issue. We are a health plan and currently use live data for training
purposes. The live data is stored in a test region of our system and
is periodically updated. One solution we are looking at is to
scramble the demographic data such as name, ssn, dependent names,
address, etc. before it is loaded to the test region. Although, this
does not meet the true definition of de-identification, we feel that it may
be a reasonable way to safeguard the PHI. Keep in mind, access
to our test region is tightly controlled by user. Only those
users who have a need to know have access to the test data. Individuals
being trained, using the modified live data, are the same staff that will
have access to this information for the purpose of performing the functions
of their jobs. In addition, the test data is not shared with any
outside entities. I sure would be interested in hearing how others are
addressing this question.
Phyllis Line
HEREIU Welfare Fund
HIPAA Privacy
Officer
(630)236-5114
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