The PHI Magic 18 for HIPAA HITECH

One question that keeps coming up in our webinars is what exactly defines PHI. There are 18 elements that individually, in concert or if they can be related to other information define protected personal information.

Here is a quick list. The details are here from our good friend the “Privacy Professor”, Rebecca Herold.

(1) Names

(2) All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census:

(a) The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and

(b) The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.

(3) All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older;

(4) Telephone numbers;

(5) Fax numbers;

(6) Electronic mail addresses;

(7) Social security numbers;

(8) Medical record numbers;

(9) Health plan beneficiary numbers;

(10) Account numbers;

(11) Certificate/license numbers;

(12) Vehicle identifiers and serial numbers, including license plate numbers;

(13) Device identifiers and serial numbers;

(14) Web Universal Resource Locators (URLs);

(15) Internet Protocol (IP) address numbers;

(16) Biometric identifiers, including finger and voice prints;

(17) Full face photographic images and any comparable images; and

(18) Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section; and

(ii) The covered entity does not have actual knowledge that the information could be used alone or in combination with other information to identify an individual who is a subject of the information

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One Comment on “The PHI Magic 18 for HIPAA HITECH”


  1. […] The PHI Magic 18 for HIPAA HITECH « Industry Radar Insights […]


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