What Is Protected Health Information?

Protected health information (PHI) under HIPAA includes any individually identifiable health information.

Identifiable refers not only to data that is explicitly linked to a particular individual (that's identified information), but also to health information with data items which reasonably could be expected to allow individual identification.

HIPAA regulations define health information as "any information, whether oral or recorded in any form or medium" that

• "[i]s created or received by a health care provider, health plan, public health authority, employer, life insurer, school or university, or health care clearinghouse"; and
• "[r]elates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual."

The following identifiers of the research subject or of relatives, employers or household members of the research subject are considered to be PHI per HIPAA:

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:
3. The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and
4. The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
5. 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;
6. Telephone numbers;
7. Fax numbers;
8. Electronic mail addresses;
9. Social security numbers;
10. Medical record numbers;
11. Health plan beneficiary numbers;
12. Account numbers;
13. Certificate/license numbers;
14. Vehicle identifiers and serial numbers, including license plate numbers;
15. Device identifiers and serial numbers; 
16. Web Universal Resource Locators (URLs); 
17. Internet Protocol (IP) address numbers; 
18. Biometric identifiers, including finger and voice prints; 
19. Full face photographic images and any comparable images; and 
20. Any other unique identifying number, characteristic, or code (note this does not mean unique code assigned by the investigator to code the data)

For a project to qualify as completely “de-identified,” none of the above identifiers can be captured. Learn more about guidance regarding methods for de-identification at www.hhs.org.