Publication
Health Law Checkup – November 2012
HHS Office for Civil Rights Releases Guidance on De-Identification of Health Information
by Eric L. Kintner
On November 26, 2012, the U.S. Department of Health and Human Services, Office for Civil Rights (OCR) released guidance about methods and approaches for de-identification of protected health information (PHI) in accordance with the HIPAA Privacy Rule. This guidance was required to be provided by HHS under the HITECH Act and helps covered entities and their business associates understand the process and options available for properly de-identifying PHI. As a result, now may be a good time for covered entities to consider reviewing their PHI policies to confirm they are consistent with this OCR guidance. Also, to the extent a covered entity has engaged a business associate to assist with de-identification of PHI, covered entities may want to review their business associate agreements to confirm that their business associates are required to follow this OCR guidance as well.
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Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 16 locations throughout the United States and in Mexico, including Los Angeles, Orange County and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
