Individually Identifiable Health Information

Definition: Includes any subset of health information, including demographic information that identifies the individual (or there is a reasonable basis to believe that the information can be used to identify the individual).

How might this type of information be useful?  Individually identifiable health information might be useful if you wish to identify patients who meet specific inclusion/exclusion criteria, and approach patients about participating in your study. It is important to remember that the approach method must be approved in advance by the Human Subjects Review Committee.

Access requirements:  In addition to obtaining a waiver of authorization, you will need to complete an Accounting of Disclosures form. Note that two forms (single entry and batch entry) are available at this link. Information at the link will explain which of the two forms you should use for your study. The index page for the Accounting of Disclosures forms includes step-by-step directions about how to complete the forms. Note that patients can request an accounting of all disclosures of their PHI for up to six years after the disclosure was made. This means that any patients who inquire will know who has accessed their PHI, and you may possibly by questioned by them about your use of their PHI.