Managed Care

de-identified info to plan sponsors

  • 1.  de-identified info to plan sponsors

    Posted 01-31-2014 03:31 PM
    I posted this with no response in the HIPAA group so I thought I'd see if I get any thoughts from this group:


    I'm hoping to get some idea of industry standard regarding reports to plan sponsors. I'm doing a typical compliance review of our plan sponsor/employer group reporting. The rules defining individually identifiable health information are nicely specific in except for the 'there is a reasonable basis on the part of the disclosing entity for believing that the information may be used to identify the individual' caveat. How do other health plans decide how many subscribers there must be in a group for the information to be unidentifiable. For example, with a plan that has 50 subscribers, it is more likely the information could be identified than with a group of 250 subscribers.

    Thank you for your input!

    Brenda Dau
    Senior Privacy Coordinator
    Providence Health Plan
    2020 HCCA Managed Care