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Guidance Issued on De-Identification of HIPAA Protected Health Information

November 30, 2012—The Department of Health and Human Services (HHS) Office of Civil Rights (OCR) Nov. 28 issued long-awaited “Guidance Regarding Methods for De-Identification of Protected Health Information in Accordance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule.”  The guidance was developed following stakeholder workshops held in 2010.

The guidance addresses issues such as:

  • What is an acceptable level of identification of risk for an expert determination;

  • What are the approaches by which an expert mitigates the risk of identification of an individual in health information; and

  • For covered entities seeking to satisfy the safe harbor method of de-identification, when can ZIP codes be included in de-indentified information?

However, to allow for flexibility, the guidance contains few definitive answers.


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806