PRIVACY: TRAINING DOCUMENTATION

[Bard, Greg]

I have a question related to Training documentation and the identifiers listed in the Privacy Regulation.   In the system we utilize to process millions of claims, there are specific derived processing fields that are driven by the Employer that an individual is associated with. If an organization has made reasonable attempts to de-identify data by changing names, addresses, SSN’s, is it OK to leave the employer information intact to illustrate the processing values that are very important to the system.  If we document the fact that the organization has determined that there is no reasonable means to identify an individual, are we considered in compliance?   The Regulation states in 164.514 (2) (i) that all identifiers of the individual, or of relatives, employers, or household members of the individual, are removed (followed by the 18 or so identifiers)…   Any thoughts or suggestions are welcome!   Greg Bard NASCO HIPAA Privacy and Security Project Manager (W) 678.441.6059 (F)  678.441.6359 [EMAIL PROTECTED]     ______________________________________________________________________________________ CONFIDENTIALITY NOTICE The information in this message (and the documents attached to it, if any) is confidential and may be legally privileged. It is intended solely for the addressee. Access to this message by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken, or omitted to be taken in reliance on it is prohibited and may be unlawful. If you have received this message in error, please delete all electronic copies of this message (and the documents attached to it, if any), destroy any hard copies you may have created and notify me immediately. Thank you.           ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address. The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited.