What items are considered PHI under HIPAA?
Protected Health Information (PHI) under HIPAA is any individually identifiable health information related to a person's physical or mental health, healthcare services, or payment for care that is created, received, maintained, or transmitted by a Covered Entity or its business associate.
Core Requirements for PHI
For data to be considered PHI, two conditions must be met simultaneously:
- Health context: It relates to past, present, or future physical/mental health conditions, healthcare delivery, or payment for healthcare.
- Individual identity: It is linked to one of the 18 specific personal identifiers (or can reasonably identify the person).
The 18 HIPAA Identifiers
When health information is combined with any of the following identifiers, it becomes PHI:
- Names
- Geographic data smaller than a state (e.g., street address, city, county, zip code)
- Dates specific to an individual (birth date, admission date, discharge date, death date, or ages over 89)
- Telephone and fax numbers
- Email addresses and IP addresses
- Social Security numbers
- Medical record numbers and health plan beneficiary numbers
- Account numbers and certificate/license numbers
- Vehicle identifiers and serial numbers (license plates)
- Device identifiers and serial numbers
- Web URLs
- Biometric identifiers (fingerprints, voiceprints)
- Full-face photographs and comparable images
- Any other unique identifying number, characteristic, or code
Form and Scope
- Medium agnostic: PHI applies to information in any form or media, whether electronic (ePHI), paper records, or spoken verbally.
- Exclusions: Employment records held by a covered entity in its role as an employer and certain educational/student health records governed by FERPA are excluded.
- De-identified data: Data is no longer PHI if all 18 identifiers are completely removed.
What are 10 examples of items that are considered PHI?
Protected Health Information (PHI) is any health, payment, or treatment data linked to an individual that can be used to identify them under HIPAA Rules.
10 Examples of PHI Items
Under the 18 HIPAA Identifiers, here are 10 common examples of items considered PHI when combined with health or payment details:
- Names: A patient’s full name or first/last name.
- Geographic data: Any location data more specific than a state, such as a street address, city, county, or ZIP code.
- Specific dates: Exact dates related to an individual (such as birth dates, admission dates, discharge dates, or appointment times).
- Telephone numbers: Home, work, or mobile numbers tied to a patient file.
- Email addresses: Personal or work email addresses used for medical correspondence.
- Social Security Numbers (SSN): A person’s government-issued Social Security number.
- Medical Record Numbers (MRN): Unique identification numbers assigned to a patient by a healthcare facility.
- Health plan beneficiary numbers: Insurance policy or member ID numbers.
- IP addresses: Internet Protocol addresses logged by patient portals or telehealth apps.
- Biometric identifiers: Unique physical measurements like fingerprints or voice prints.
What are the 18 identifiers of PHI?
The 18 identifiers of Protected Health Information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA Overview) are specific data points that can be used to identify a patient, their relatives, employers, or household members.
To fully de-identify health data under HIPAA's Safe Harbor method, all 18 of these elements must be removed:
The 18 HIPAA Identifiers
- Names: Full names or parts of names.
- Geographic data: All geographic subdivisions smaller than a state, including street address, city, county, and precinct (with narrow exceptions for the initial three digits of a ZIP code).
- Dates: All specific date elements (such as birth date, admission date, discharge date, or date of death) directly linked to an individual, excluding the year.
- Ages over 89: 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.
- Telephone numbers: Direct phone contact numbers.
- Fax numbers: Facsimile numbers.
- Email addresses: Electronic mail contact details.
- Social Security numbers (SSN): Individual SSNs.
- Medical record numbers: Patient file or chart identification numbers.
- Health plan beneficiary numbers: Insurance policy or member ID numbers.
- Account numbers: Financial or billing account numbers.
- Certificate or license numbers: Professional or driving license/certificate numbers.
- Vehicle identifiers: Vehicle serial numbers or license plate numbers.
- Device identifiers: Medical device serial numbers or tracking codes.
- Web URLs: Uniform Resource Locators pointing to specific web pages.
- IP addresses: Internet Protocol addresses used for digital networking.
- Biometric identifiers: Measurable physical characteristics, including finger, retinal, or voice prints.
- Full-face photographs: Facial photos and any comparable images.
- Unique identifying codes: Any other unique identifying number, characteristic, or code meant to single out the person.
You can review further details on these rules through guidelines from Loyola University Chicago or UC Berkeley.
Which of the following items could be considered PHI?
Because you didn't include the specific multiple-choice options or items to choose from, I can't point directly to the correct option. However, I can give you the exact criteria to easily figure out the right answer.
Under HIPAA, Protected Health Information (PHI) is defined as any health, treatment, or payment data that can be linked to a specific individual. To be considered PHI, an item must contain both health/medical data and at least one personal identifier.
To evaluate your items, check them against the 18 specific HIPAA identifiers (such as names, geographic data smaller than a state, specific dates, contact numbers, SSNs, and biometric data); the full list of these identifiers can be found in the reference documents.
Quick Checklist for Your Options:
- 👥 Is it PHI? Any medical diagnosis, treatment record, lab test result, or billing statement that is tied to one of the personal identifiers above.
- ❌ Is it NOT PHI?
- Health data completely stripped of all 18 identifiers (de-identified data).
- Common identifiers sitting alone without any medical context.
- Employment records held by a covered entity acting as an employer.
- Student health records covered under FERPA.
If you reply with the specific options from your question, I would be happy to identify the exact correct answer for you!
What should not contain PHI?
Because you didn't include the specific list of multiple-choice options in your question, the exact answer choice cannot be explicitly matched. However, based on standard medical compliance and HIPAA testing questions, the correct answer is typically an Informational pamphlet (or alternatively, personal items belonging to patients / benefits information without identifying details).
Here is an explanation of why certain items do or do not contain Protected Health Information (PHI):
❌ Items that do NOT contain PHI
- Informational pamphlet: These documents provide general health, wellness, or educational information intended for a broad audience. They contain no individual patient names, medical histories, or tracking data, meaning they do not violate HIPAA privacy rules.
- Personal items: Belongings like clothing, grooming items, or jewelry do not hold medical data or health tracking information.
- De-identified health information: Health or benefits data that has had all 18 HIPAA identifiers (such as names, specific dates, and biometric identifiers) completely removed is no longer considered PHI.
⭕ Items that DO contain PHI
The following items are regulated under HIPAA because they contain explicitly identifiable data tied to a person's healthcare, diagnosis, or financial payment records:
- Medical claim forms (contains patient identifiers, diagnosis codes, and billing information)
- Explanation of Benefits (EOB) (contains insurance numbers, patient names, and breakdown of services rendered)
- Electronic prescriptions / EHRs (contains patient names, specific dosages, and provider details)
- Patient ID bracelets and IV labels (contains medical record numbers and names)
If your question has a different set of choices, please reply with the options and I will gladly identify the correct one for you!
What are the 18 PHI identifiers?
What is not considered PHI under HIPAA?
Data is not considered Protected Health Information (PHI) under HIPAA if it is properly de-identified, kept by an employer in an employment record, or held by an organization that is not a covered entity.
Categories Not Considered PHI
- De-Identified Information: Health data that has all 18 HIPAA identifiers (such as names, specific geographic data, and full dates) removed, or data certified as de-identified by a qualified statistician.
- Employment Records: Health-related details kept by a Department of Health and Human Services covered entity strictly in its role as an employer—such as sick leave requests, fitness-for-duty reports, or drug test results—rather than as a healthcare provider.
- Education Records: Student health and treatment records protected under the Family Educational Rights and Privacy Act (FERPA).
- Data Held by Non-Covered Entities: Health metrics collected by consumer wellness apps, fitness trackers, life insurers, or schools that do not act on behalf of a covered healthcare provider or health plan.
- Publicly Available Information: Information found in public sources, such as news reports, court records, or obituaries.
- Decedent Information After 50 Years: Health records of individuals who have been deceased for more than 50 years.
What does PHI not cover?
Protected Health Information (PHI) under HIPAA does not cover health data that is stripped of personal identifiers, handled by non-covered entities, or maintained in specific employment and educational records.
What HIPAA Does Not Cover
- De-identified Data: Information that has had all 18 standard personal identifiers (such as names, specific dates, and geographic data smaller than a state) removed or certified by a statistician.
- Consumer Wearables and Apps: Health tracking data—such as heart rate logs, steps, or sleep metrics stored on personal smartwatches or fitness apps—unless that data is shared with a healthcare provider or covered entity.
- Employment Records: Health-related information maintained by a Covered Entity specifically in its capacity as an employer, including sick leave requests, fitness-for-duty exams, and workers' compensation files.
- Education Records: Student health records and immunizations managed by schools or universities that are instead governed by the Family Educational Rights and Privacy Act (FERPA).
- Information on Deceased Individuals: Health records pertaining to individuals who have been dead for more than 50 years.
- Non-Health Data Purposes: Data repurposed by third-party companies outside of treatment, payment, and healthcare operations (such as data used by life insurers for underwriting or general consumer marketing analytics).
What is not considered to be one of the 18 PHI identifiers?
Because you didn't provide specific multiple-choice options to choose from, here is how this question is typically answered in testing contexts:
Educational records, state of residence, and clinical data (like diagnosis codes or blood pressure readings) are not considered among the 18 HIPAA PHI identifiers.
❌ Common Incorrect Options (Items that ARE Identifiers)
Choices such as names, sub-state geographic locations, specific dates, contact details, official ID numbers, asset and digital identifiers, biometric data, and full-face photos are part of the official 18 identifiers.
Common Correct Options (Items that are NOT Identifiers)
Typical correct answers on tests (distractors) include educational records, state of residence, clinical data (like diagnosis or blood pressure), and general demographic information.
If you would like to reply with your specific multiple-choice options, I can point out the exact correct answer for you!
What are the 10 most common HIPAA violations?
The 10 most common HIPAA violations involve mishandling protected health information (PHI) through employee error, weak security, or administrative oversight.
Top 10 Most Common Violations
- Employee Snooping: Accessing patient files, family records, or coworker charts without a direct, professional need to know.
- Lost or Stolen Devices: Leaving unencrypted laptops, smartphones, tablets, or USB drives where they can be stolen or accessed by outsiders.
- Failure to Conduct Risk Analyses: Neglecting regular, organization-wide checkups to find and fix security gaps.
- Improper Disposal of Records: Tossing paper charts in regular trash or failing to securely wipe old hard drives.
- Weak Passwords and Access Controls: Using simple passwords or giving too many staff members broad, unmonitored access to electronic records (ePHI).
- Unauthorized Texting or Emailing: Sending patient details over regular, unsecured text messages or standard email instead of encrypted platforms.
- Missing Business Associate Agreements (BAAs): Failing to sign legal BAA contracts with outside vendors and cloud providers who handle patient data.
- Delayed Breach Notifications: Missing the legal deadline to notify patients, the government, and the media within 60 days of discovering a data breach.
- Inadequate Employee Training: Not providing regular, documented privacy and security awareness education for staff.
- Denying or Delaying Patient Access: Taking longer than allowed (or refusing outright) to give patients copies of their own medical records.
What is the new HIPAA rule in 2026?
The main new HIPAA requirement for 2026 is updating privacy notices under the HHS Model Notices of Privacy Practices to include stricter protections for substance use disorder (SUD) patient records.
Key 2026 Privacy Rule Updates
- February 16, 2026 Deadline: Healthcare providers and health plans had to update their Notice of Privacy Practices (NPP).
- Substance Use Records: Notices must now explain how substance use disorder records are protected under 42 CFR Part 2.
- Legal Protections: Patient records generally cannot be used in civil or criminal legal cases without explicit consent or a court order.
- Patient Rights: Patients gained clearer rights to restrict sharing, opt out of fundraising, and file complaints.
Proposed Security Rule Changes (Under Review)
Regulators are also pushing a major update to the HIPAA Security Rule that changes how organizations handle data safety:
- No More "Addressable" Rules: Optional security steps are becoming mandatory.
- Mandatory MFA: Multi-factor authentication is required across all systems.
- Required Encryption: Patient data must be encrypted both in transit and at rest.