Protected Health Information (PHI)

In the ever-evolving healthcare technology landscape, telehealth apps have emerged as transformative tools, connecting patients and healthcare providers like never before. For product managers in this dynamic field, being well-versed in Protected Health Information (PHI) and its relationship with the Health Insurance Portability and Accountability Act (HIPAA) is crucial.

What Is Protected Health Information?

PHI refers to any individually identifiable health information held or transmitted by covered entities (e.g. your company) or their business associates (e.g. your vendors).

"Covered entities" are providers, including hospitals, individual care providers, insurance companies, and telehealth companies. "Business associates" are entities that perform or provide certain functions, services, or activities for or to a covered entity. Essentially, business associates provide services to support the operations of a covered entity.

PHI is protected under HIPAA's Privacy Rule. The privacy rule establishes standards and guidelines for the permissible uses and disclosures of PHI. By defining exactly what PHI includes, HIPAA aims to protect the confidentiality and privacy of patients.

What Information is Confidential Under PHI and HIPAA?

Under PHI, all individually identifiable health information created, received, maintained, or transmitted by covered entities or their business associates must remain confidential. This includes a wide range of information related to an individual's physical or mental health, medical history, or healthcare services.

HIPAA provides a list of 18 specific identifiers for PHI. Including:

  • Patient names
  • Dates related to medical history, e.g. birth dates, admission dates, discharge dates, and appointment dates
  • Addresses and other contact information
  • Social security numbers
  • Biometric data, e.g. fingerprints and retinal scans used for ID purposes
  • Medical records, e.g. medical history, treatment plans, diagnoses, prescription information, and general notes
  • Payment information
  • Genetic information and family history

What Isn't Confidential Under PHI and HIPAA?

There are some pieces of information that PHI doesn't protect. Typically, this type of medical information either doesn't have personally identifiable information attached to it or isn't accessible to a covered entity or business associate. This type of information includes:

  • De-identified information, e.g. when the medical data is not attached to any identifiable information 
  • Information from wearable devices, e.g. fitness trackers, etc.
  • Research data 

Why Do Telehealth Product Managers Need to Know What PHI Is?

Product managers play a critical role in developing telehealth applications, often involving handling and transmitting sensitive patient information. By prioritizing PHI, product managers can maintain the highest data protection and patient care standards. Equipped with the right info, PMs can make informed decisions throughout their app's development, implementation, and maintenance.

Remain in Compliance With HIPAA

Identifying PHI is a fundamental step in achieving compliance with HIPAA. Compliance with privacy and security regulations is essential in the healthcare industry. Failure to comply with HIPAA can lead to severe consequences, including financial penalties and legal actions.

Product managers may overlook sensitive information and fail to implement adequate privacy and security measures without a clear understanding of what constitutes PHI.

Conversely, with thorough knowledge of PHI guidelines, product managers can effectively identify the types of data that fall under HIPAA regulations and handle the data with utmost care. For example, HIPAA has specific requirements for the retention and disposal of PHI. Based on HIPAA guidelines, product managers must understand which data elements qualify as PHI and how long to retain them.

Avoid Risk of Data Breaches and Compromises

A data breach within a telehealth app can have severe consequences, ranging from compromised patient privacy to financial loss and damage to the app's reputation. Understanding PHI helps telehealth product managers avoid these situations — or address them if they do happen.

Product managers can proactively implement appropriate safeguards and security measures to keep patient information confidential and mitigate the risk of breaches. This can include user authentication protocols, encryption mechanisms, secure data storage, regular vulnerability assessments, and robust access controls.

By employing these measures, product managers reduce the chances of unauthorized access or disclosure of PHI, maintaining the privacy and security of patient information.

Enhance User Experience and Build Trust

Understanding PHI helps product managers protect user information and instills confidence in users, leading to a safer and more trustworthy app experience.

Prioritizing the safeguarding of PHI shows your users you value their privacy and security. They appreciate when you implement features and functions that demonstrate transparent data handling practices, secure data storage, and clear consent mechanisms.

Building trust is crucial for the success of telehealth apps. When users have confidence that their PHI is being handled securely and with respect for their privacy, they are more likely to trust and engage with the app. This trust can foster a positive user experience and encourage ongoing app usage.

Frequently Asked Questions

What formats of PHI are covered?

PHI covers various formats, including electronic, paper, and oral forms. This encompasses information stored in electronic health records (EHRs), emails, faxes, scanned documents, handwritten notes, conversations between healthcare providers, and any other form that contains individually identifiable health information.

One thing to note: the format itself does not determine the applicability of PHI. Instead, the content and context of the information determine its classification as PHI.

What are some specific examples of PHI?

PHI includes various types of individually identifiable health information, such as:

  • An invoice from a doctor’s office
  • Test results within your medical record
  • Phone records
  • Physician notes

Does PHI only apply to healthcare information?

Yes, PHI only applies to healthcare situations where covered entities receive private information. However, there are other data privacy laws and regulations for protecting personal information. For example, GDPR establishes requirements for developers and product managers to implement safeguards to protect the personal information of online consumers.

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