PHI: Definition, Examples, & List of Identifiers

View All Blogs Nov 21, 2024 — 12 min read

Safeguarding PHI isn’t just compliance—it’s trust, security, and smarter care.

Introduction

Protected Health Information (PHI) is the backbone of privacy in healthcare. Governed by the Health Insurance Portability and Accountability Act (HIPAA), PHI encompasses any identifiable health data managed by healthcare providers, insurers, and their vendors. Ensuring PHI is secure isn’t just a legal requirement—it’s critical for maintaining trust and avoiding costly breaches.

This guide provides a clear definition of PHI, examples across industries, a full list of HIPAA’s 18 identifiers, and practical steps to secure it. Whether you’re a healthcare provider, insurer, or tech vendor, you’ll gain actionable insights to protect patient data effectively.


What is PHI?

Definition: Protected Health Information (PHI) includes any health information that can identify an individual and is used, maintained, stored, or transmitted by a HIPAA-covered entity or business associate. This information relates to an individual's past, present, or future physical or mental health or condition and the provision of healthcare.

HIPAA's 18 PHI Identifiers

 

 

HIPAA explicitly identifies the following as PHI when they are linked to health information:

  1. Names
  2. Geographic Data: All geographic subdivisions smaller than a state, including street address, city, county, and ZIP code.
  3. Dates: All elements of dates (except year) related to an individual, such as birth date, admission date, discharge date.
  4. Telephone Numbers
  5. Fax Numbers
  6. Email Addresses
  7. Social Security Numbers
  8. Medical Record Numbers
  9. Health Plan Beneficiary Numbers
  10. Account Numbers
  11. Certificate/License Numbers
  12. Vehicle Identifiers: Including license plate numbers.
  13. Device Identifiers and Serial Numbers
  14. Web URLs
  15. Internet Protocol (IP) Addresses
  16. Biometric Identifiers: Such as fingerprints or voiceprints.
  17. Full-Face Photographic Images
  18. Any Other Unique Identifying Number or Code

Quick Tip: If health information includes any of these identifiers, it's considered PHI and must be protected according to HIPAA regulations.


Examples of PHI

Healthcare Settings:

  • Clinical Records: A patient’s treatment plan containing their name, diagnosis, and prescribed medications.
  • Lab Results: A COVID-19 test result tied to a patient’s unique ID.
  • Imaging Records: An MRI with embedded metadata containing a patient's medical record number.

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Insurance and Billing:

  • EOB Forms: An explanation of benefits showing patient procedures, names, and health plan IDs.
  • Claim Information: Billing codes linked to patient accounts and identifiers.

Technology-Driven PHI:

  • Telemedicine: A video consultation record stored with identifiable patient data.
  • Wearables: Heart rate or sleep tracking data from a smartwatch, linked to a physician for care coordination.

PHI vs. Non-PHI

  • PHI: A person’s email address used in a physician's follow-up about their treatment.
  • Non-PHI: Aggregated health statistics with all identifiers removed (de-identified data).

Key Tip: PHI can exist outside traditional healthcare settings. If it identifies an individual and relates to health, it’s PHI.

Case Study: Check out How Tadabase saved a midwest medical group $180K by creating a custom HIPAA compliant communication workflow.


Why is PHI Important?

PHI protects patient privacy while enabling healthcare services. Unauthorized access to PHI can result in:

  1. Compliance: Avoid costly HIPAA fines ranging from $100 to $50,000 per violation.
  2. Trust: Patients entrust healthcare providers with sensitive data.
  3. Operational Continuity: Breaches cause audits, fines, and downtime.

Top Threats to PHI

  1. Human Errors:
    • Sending emails with PHI to the wrong recipient.
    • Failing to properly dispose of physical PHI documents.
  2. Cybersecurity Risks:
    • Ransomware attacks targeting hospital databases.
    • Unsecured medical devices storing PHI.
  3. Vendor Negligence:
    • Third-party services without signed Business Associate Agreements (BAAs).
    • Poor encryption practices by vendors.

Case Study:
A healthcare provider incurred $3 million in penalties after an unencrypted laptop containing PHI was stolen, underscoring the importance of robust encryption and device security protocols. Read the full story.


Top Strategies for Securing PHI Effectively

Protecting Protected Health Information (PHI) requires a comprehensive, proactive approach that addresses both technical and human vulnerabilities. Below are the top strategies to safeguard PHI and ensure compliance with HIPAA regulations. Learn how to get HIPAA compliance right.


1. Conduct Regular Risk Assessments

  • Identify vulnerabilities in how PHI is stored, accessed, and transmitted.
  • Document potential risks and develop mitigation strategies to align with HIPAA standards.
  • Update risk assessments annually or whenever major changes occur.

Pro Tip: Involve both IT and compliance teams to ensure a holistic assessment of your PHI systems.


2. Implement Robust Access Controls

  • Use role-based access controls (RBAC) to limit who can access PHI based on job responsibilities.
  • Regularly review access permissions and remove unnecessary access.

Example: Allow clinical staff to view patient records but restrict billing teams to payment-related information only.


3. Encrypt PHI at All Times

  • Encrypt PHI during storage and transmission to protect it from unauthorized access.
  • Adopt Advanced Encryption Standards (AES) to comply with HIPAA’s technical safeguard requirements.

Quick Tip: Ensure all emails and file-sharing systems handling PHI are encrypted end-to-end.


4. Train Employees on PHI Security

  • Conduct regular training sessions on handling PHI securely, identifying phishing attempts, and HIPAA compliance.
  • Use simulated phishing attacks to educate employees on real-world threats.

Pro Tip: Provide role-specific training to ensure all employees understand how PHI security applies to their responsibilities.


5. Monitor and Audit Systems Regularly

  • Use automated tools to monitor system logs and detect suspicious activities.
  • Perform regular audits of system access to ensure compliance with internal policies.

Actionable Step: Enable alerts for unusual activities, such as logins from unexpected locations or bulk data downloads.


6. Secure Vendor Relationships

  • Require Business Associate Agreements (BAAs) for all vendors handling PHI on your behalf.
  • Regularly evaluate vendor compliance with HIPAA standards, especially for cloud-based tools.

Example: Ensure cloud storage providers implement robust encryption and detailed access logs.


7. Develop and Test an Incident Response Plan

  • Create a detailed process for handling PHI breaches, including:
    • Immediate notification protocols.
    • Mitigation steps.
    • Reporting breaches within HIPAA’s required 60-day window.
  • Test the plan annually with simulated breach scenarios.

Pro Tip: Assign a dedicated incident response team to act quickly in case of a breach.


8. Use Secure Platforms to Manage PHI

  • Leverage tools like Tadabase to build apps with essential security features, including:
    • Role-based access controls.
    • Automated workflows to minimize manual errors.
    • Audit trails for monitoring PHI activity.

Note: Apps created with secure platforms can be configured to meet HIPAA compliance standards.


9. Enable Two-Factor Authentication (2FA)

  • Require 2FA for all systems that handle PHI to add an extra layer of security.
  • Use authentication apps or biometrics for enhanced protection.

Quick Tip: Combine 2FA with strong password policies, such as regular updates and complexity requirements.


10. Regularly Update and Patch Systems

  • Ensure all software and systems handling PHI are up-to-date with the latest security patches.
  • Disable outdated protocols and remove unsupported software from your environment.

Pro Tip: Automate patch management to minimize vulnerabilities from outdated systems.


Checklist for PHI Security

Task Frequency Notes
Risk Analysis Annually Document vulnerabilities and solutions.
Encryption Testing Quarterly Verify all PHI data is encrypted.
Staff Training Quarterly Update staff on HIPAA compliance.
Vendor Reviews (BAAs) Annually Confirm vendors meet HIPAA standards.
Breach Response Testing Annually Test your breach notification plans.

By implementing these strategies, organizations can not only protect sensitive health information but also foster trust, ensure regulatory compliance, and minimize operational risks. Adopting these best practices demonstrates a proactive approach to data security and positions your organization as a leader in patient privacy.


Frequently Asked Questions

1. What is PHI in HIPAA?
PHI, or Protected Health Information, refers to any health-related information that can identify an individual and is created, used, or disclosed during healthcare services such as diagnosis or treatment. Under HIPAA, PHI must be safeguarded to protect patient privacy.

Example of PHI:
A medical record with a patient’s name, date of birth, and treatment details.


2. What are the 18 HIPAA Identifiers for PHI?
Names, email addresses, medical record numbers, IP addresses, and biometric data are just a few examples. (See full list above.)

Quick Tip: If the data can identify someone and relates to their health, it’s likely PHI.


3. What is not considered PHI?
Information is not considered PHI if it is de-identified, meaning all 18 HIPAA identifiers are removed, and there is no reasonable way to identify the individual.

Example of Non-PHI:
Aggregated health data, such as "80% of patients showed improvement after treatment," without any linked identifiers.


4. What are examples of PHI?
Here are examples of PHI across healthcare settings:

  • A patient’s name and diagnosis in a medical record.
  • Insurance claim forms with health plan IDs and billing information.
  • Emails with appointment reminders that include patient identifiers.

Non-Example: Step count data from a fitness tracker, unless it’s connected to a healthcare provider.


5. What is the difference between PHI and PII?

  • PII (Personally Identifiable Information) refers to any data that identifies an individual, such as name, address, or phone number.
  • PHI is a subset of PII that specifically pertains to health-related information governed by HIPAA.

6. How do I protect PHI?
To secure PHI, follow these best practices:

  • Encrypt all PHI during transmission and storage.
  • Limit access to PHI using role-based controls.
  • Train employees regularly on HIPAA compliance and phishing prevention.
  • Use secure platforms like Tadabase for managing sensitive data with built-in compliance features. Read our guide to architecting for HIPAA on Tadabase.

7. What happens if PHI is breached?
A PHI breach can result in:

  • Financial penalties: Fines range from $100 to $50,000 per violation.
  • Reputation damage: Loss of patient trust.
  • Operational disruptions: Investigations, audits, and increased scrutiny.

8. What are the penalties for mishandling PHI?
HIPAA violations have severe financial and reputational consequences. Penalties are categorized into four tiers based on the level of negligence:

Tier Description Fine per Violation Annual Cap
Tier 1 Lack of knowledge, no willful neglect $100 – $50,000 $25,000
Tier 2 Reasonable cause, not willfully negligent $1,000 – $50,000 $100,000
Tier 3 Willful neglect, corrected within 30 days $10,000 – $50,000 $250,000
Tier 4 Willful neglect, not corrected $50,000 per violation $1,500,000

Real-World Example:
A hospital paid $2.5M after a staff member lost an unencrypted laptop containing PHI for 1,000+ patients.


9. What tools can help manage PHI securely?
Adopting secure software and tools is essential to protect PHI. Look for platforms that offer:

  • Encryption: Secures data in transit and at rest.
  • Audit Logs: Tracks access and changes to PHI.
  • Role-Based Access: Limits PHI access to authorized individuals.
  • Data Redundancy: Prevents data loss through backups.

Recommended Tools:

  • Tadabase: A platform that enables you to build HIPAA-compliant applications, offering advanced encryption, audit trails, and user access controls.
  • Secure Email Services: For encrypted communication (e.g., ProtonMail, Virtru).
  • Firewalls and VPNs: Adds layers of protection to PHI systems.

10. What steps should businesses take to comply with HIPAA?
Compliance with HIPAA requires proactive measures to safeguard PHI. Here’s a step-by-step guide:

  1. Perform Risk Assessments:

    • Identify risks to PHI and develop strategies to mitigate them.
    • Document findings and revisit annually.
  2. Implement Safeguards:

    • Administrative: Train employees on PHI security.
    • Physical: Secure devices storing PHI in locked areas.
    • Technical: Encrypt PHI and monitor system access.
  3. Sign Business Associate Agreements (BAAs):

    • Ensure all third-party vendors handling PHI sign BAAs.
  4. Develop an Incident Response Plan:

    • Create a plan to address and report breaches within 60 days as required by HIPAA.

Bonus Tip: Keep up with updates to HIPAA regulations by subscribing to resources like HHS.gov.


11. What is the difference between PHI and EHR?

  • PHI: Encompasses all health-related information that identifies an individual.
  • EHR (Electronic Health Record): A digital version of a patient’s medical chart, often containing PHI.

Key Difference: While all EHRs contain PHI, not all PHI is found in EHRs (e.g., billing data).


12. How do de-identified data and PHI differ?

  • PHI: Includes any health-related information tied to an individual’s identity.
  • De-Identified Data: PHI stripped of all 18 identifiers. Once data is de-identified, it is no longer subject to HIPAA.

Example:

  • PHI: “Jane Doe was diagnosed with diabetes on 01/01/2024.”
  • De-Identified: “A 35-year-old woman was diagnosed with diabetes.”

13. What are the most common causes of PHI breaches?
The top causes of PHI breaches include:

  1. Human Error: Sending emails to the wrong recipient or losing devices containing PHI.
  2. Unsecured Systems: Databases lacking encryption or proper firewalls.
  3. Third-Party Breaches: Vendor negligence, such as failing to encrypt patient records.
  4. Phishing Attacks: Malicious emails targeting healthcare employees.

Preventative Measures:

  • Regular staff training.
  • Advanced threat detection software.
  • Ensuring all vendors meet HIPAA compliance standards.

Conclusion

Protecting Protected Health Information (PHI) is not just a legal obligation—it's a fundamental responsibility for any organization handling sensitive health data. By fully understanding what constitutes PHI and recognizing the common threats it faces, you can implement effective strategies to safeguard this critical information.

From deploying advanced encryption methods and enforcing strict access controls to conducting regular employee training and risk assessments, comprehensive safeguards are essential. These measures not only ensure HIPAA compliance but also build trust with patients, partners, and the broader healthcare community.

By using Tadabase, you can confidently create tailored solutions that meet your organization's unique needs while maintaining strict adherence to HIPAA regulations.

Take proactive steps today to secure PHI. With tools and strategies that address HIPAA compliance and data security, your organization can build trust, ensure regulatory adherence, and focus on delivering exceptional healthcare services.

Published by

Sariva Sherman

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