RE: PRIVACY: TRAINING DOCUMENTATION

Thu, 26 Sep 2002 17:44:24 -0700

What the regulation states in clear, unambiguous text should be followed to the letter.
 

Tim McGuinness, Ph.D.
Consulting Specialist in Regulatory Privacy, Security, and Application Compliance (HIPAA/ASCA/FDA/CMS-HCFA/ICH/ADA 508c),
 
President,
HIPAA Help Now
 
Executive Co-Chairman for Privacy,
HIPAA Conformance Certification Organization (HCCO)
www.hcco.us

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-----Original Message-----
From: Bard, Greg [mailto:[EMAIL PROTECTED]]
Sent: Thursday, September 26, 2002 10:45 AM
To: [EMAIL PROTECTED]
Subject: PRIVACY: TRAINING DOCUMENTATION



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]

 

 

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