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Brent Blanchard
Brent Blanchard, Attorney
Category: Legal
Satisfied Customers: 1975
Experience:  Twelve years of experience in estate planning and probate, consumer bankruptcy, and business law.
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Is it a violation of Hippa if a patients last name is listed

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Is it a violation of Hippa if a patient's last name is XXXXX XXXXX a letter without any first name, no date of birth, no SS, so address?
The missing element from your question,Customer is whether any other Protected Health Information was disclosed in the letter.

A last name by itself can be argued to NOT be enough Personally Identifiable Information to violate HIPAA, but IF it can be "boot-strapped" with other information in the communication to identify the person mentioned, then there would be a violation.

I suspect that saying that person "X" was receiving similar "telephone counseling" services would be enough PHI to violate HIPAA.

A safer route would have been to redact the last names from the cc documents sent outside the "need to know" health industry people who had legitimate access to the PIO ahd PHI.


Thank you.

BAB.

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