What Is PHI, And Why Does Your Healthcare Organisation Need To Secure It?
There are two things that every person wants to keep private – their browser history and health history. Most of us feel insecure and somewhat embarrassed to reveal our health history to anyone, and we do all we can to keep it safe and secure.
For the same reason, healthcare organisations must protect their patients’ healthcare information. And the first step you need to take to protect this information is to understand the PHI Protected Health Information concept.
Below we discuss PHI in detail and why it is essential for ensuring the security of your patient’s healthcare information. So let’s start by first explaining what PHI is and how it applies to your healthcare organisation.
What is PHI?
If you are working in healthcare or insurance, the chances are that you have come across the term PHI. And you have wondered what is PHI and whether it is relevant to your organisation.
PHI is short for Protected Health Information but is also referred to as Personal or Patient Health Information by some. To be more elaborate, PHI includes various health-related information about a person, such as
- Demographic information
- Medical history
- Lab and test results
- Mental and physical health conditions
- Health insurance information
- And more
To put things more simply, PHI Protected Health Information is any health-related information that could reveal the patient’s identity. Every organisation dealing with PHI must ensure its protection unless you want to risk strict legal actions, including a hefty fine.
But who decided which information is worth protection as PHI and which isn’t?
And when and where does this PHI apply?
To answer this question, you must first learn about the HIPAA act and how it protects PHI Protected Health Information. But worry not; we will discuss all of that below.
ePHI
The PHI health data also include Protected Health Information in electronic or digital format. ePHI refers to electronic PHI data and receives the same protection and privileges as regular PHI. For all practical reasons, ePHI and PHI are considered the same. Most people use the term PHI interchangeably with ePHI.
What is HIPAA, And How Does It Apply To Your Organisation?
PHI is integral to HIPAA, or the Health Insurance Portability and Accountability Act of 1996. HIPAA governs or regulates the use of PHI data from a legal perspective, and it applies to the use, access and disclosure of PHI in the US.
Hence, the legal consequences of sharing PHI only apply to your patients in the US. However, PHI Protected Health Information applies to every healthcare organisation worldwide from a security perspective.
Unlike most privacy laws, HIPAA specifically deals with PHI Patient Health Information and elaborates on how you can ensure the security of PHI. HIPAA compliance means you have set all necessary measures to protect patient information.
What does that mean for your organisation? Well, it means you can ensure your PHI’s security and prepare yourself for national and international healthcare/privacy laws.
Why Do Healthcare Organisations Need to Comply With Privacy Laws?
As you know, PHI Patient Health Information is crucial for every individual. No one wants their PHI data to fall into the wrong hands. Every country, including Australia, has a set of privacy rules. In Australia, we have the Privacy act of 1988. In Europe, it is GDPR and HIPAA in the US.
One thing is common in all of these rules. They are all designed to safeguard the PHI Patient Health Information. Every organisation must comply with healthcare privacy laws, including healthcare and insurance providers. Following are some compelling reasons why you should ensure HIPAA compliance for your healthcare organisation.
International Healthcare Services And Consultations
The world is a much smaller place than it used to be. Today, accessing healthcare consultations and services is so quick and convenient. Healthcare apps and online services have only brought international healthcare services to the forefront. And the PHI Protected Health Information is shared across several spectrums.
Hence, healthcare organisations must ensure that they are compliant with the relevant laws. HIPAA and GDPR are two major privacy laws that your healthcare organisation must watch out for. You must protect the PHI Patient Health Information as these privacy laws may have severe consequences for non-compliance and data leaks.
Enhance The Security For Your PHI Protected Health Information
Privacy rules like HIPAA come with detailed guidelines to protect your PHI Protected Health Information and ensure HIPAA compliance. It includes a detailed description of how to store PHI and the safeguards to protect it from malicious attacks or unauthorised access.
Hence, ensuring HIPAA compliance means that you can put preventive measures to protect your PHI Patient Health Information. As a result, you can ensure the security of your patient’s healthcare data even if you do not have international patients.
Easier Transition For New Compliances
For most privacy laws, there are many standard security requirements you need to meet. For example, let’s say that you ensure HIPAA compliance for your healthcare or insurance organisation. The security measures you implement for HIPAA may also require another privacy rule like GDPR.
In, other words HIPAA compliance makes it easier for your healthcare organisation to offer its services to new audiences. For instance, a hospital can quickly launch a healthcare consultation app that lets patients from different countries access its services.
How? Because the transition from one compliance to another is more accessible than starting from scratch. In other words, it becomes easier for you to use, access, and disclose PHI Protected Health Information according to the relevant standards.
What Is Protected Health Information Under HIPAA?
Under HIPAA, Protected Health Information includes any health information used, accessed, or disclosed by a covered entity that can reveal the patient’s identity. We will explain what exactly is a covered entity as we move forwards.
For now, all you need to know about PHI Protected Health Information is that you must safeguard every bit of identifiable information. But, what precisely is this information that you need to defend?
HIPAA provides a list of 18 identifiable information that becomes PHI when you couple it with health information. Some identifiers don’t have to pair with healthcare information to identify a person. Whereas others can identify a person when paired with health information. The identifier under Protected Health Information includes the following.
- Names
- Addresses
- Phone numbers
- Email addresses
- Social security numbers
- Medical record numbers
- Health plan beneficiary numbers
- Account numbers
- License/certificate numbers
- Fax numbers
- Vehicle identifiers, such as license plate numbers
- Serial numbers and device identifiers
- Website URLs
- IP addresses
- Biometric identifiers, such as finger and voice prints
- Full-face photographs and photos of identifying characteristics
- Dates, except years
- Any other unique identifying numbers or codes
Essential Terms In PHI Protected Health Information You Need To Know
If you are learning what is PHI, you might not have heard about terms like covered entity or business associate. And if you are familiar with these terms, then you probably wonder what they mean.
It is crucial to understand these terms to ensure HIPAA-compliant communication for your business. Below we discuss just two significant terms in HIPAA-compliant communications, and they are
- Covered Entity
- Business Associate
What Are Covered Entities?
According to HIPAA, any organisation or individual that handles PHI health data is a covered entity. That makes your healthcare or health insurance organisation a covered entity too. The HIPAA regulations are primarily aims covered entities as they are often the source for PHI.
Covered entities must follow HIPAA privacy and security rule. Numerous organisations use, access, or disclose PHI health data regularly, but not all are not considered covered entities. According to HIPAA, covered entities come in three categories, and they are
- Healthcare Providers
- Health Plans
- Healthcare Clearinghouses
Healthcare Providers
Healthcare providers like hospitals and clinics often source most PHI health data. But you are wrong if you think hospitals, clinics, and doctors are the only entities that come under healthcare providers. HIPAA classifies the following entities as healthcare providers.
- Hospitals
- Doctors
- Clinics
- Psychologists
- Dentists
- Chiropractors
- Nursing Homes
- Pharmacies
So, suppose you see your business organisation in the list above. In that case, you need to take special care of PHI Protected Health Information.
Health Plans
Health plans include government programs for medical expenses, such as Medicare in Australia. But more importantly, it provides healthcare insurance providers because they often deal with sensitive Protected Health Information.
Health Maintenance Organisations or HMOs also come under the health plan as a covered entity. The HMO is much similar to a typical health insurance provider. HMOs and health insurance providers deal with the same type of PHI health data. However, there is one clear distinction between an HMO and a regular healthcare insurance provider.
The HMO limit its services or coverage to healthcare services from doctors who are in a contractual agreement with it. And finally, health plans also include company/organisation health plans. It means if an employer or institution provides health insurance, they also become a covered entity.
Healthcare Clearinghouses
Healthcare clearinghouses are organisations that process nonstandard health information. The standardisation process usually uses standard electronic format or data content. Healthcare clearinghouses obtain the PHI Protected Health Information from an entity.
It then standardises the data obtained and submits the output to a different entity or organisation. As you can see, the PHI data merely passes through the healthcare clearinghouses, and still, they require HIPAA compliance.
It should give you an idea of how serious it is to deal with PHI health data for your organisation.
What Are Business Associates?
Sometimes covered entities may have to share PHI Protected Health Information with other organisations for their internal processes. For example, consider all the important documents and patient statements hospitals send to their patients.
The chances are that hospitals share the PHI health data with a Managed Print Service like PostGrid for printing and sending medical documents. Here, service providers like PostGrid may use the same PHI as the hospital, but that does not make it a covered entity.
PostGrid and other similar services to whom covered entities, including healthcare providers and health plans, outsource their operations are called business associates. In other words, business associates are subcontractors or vendors of a covered entity with access to PHI health data.
What Happens To PHI Protected Health Information Given To Business Associates?
The purpose of a business associate is to let you perform a business function or operation that uses PHI health data. For example, HIPAA-compliant service providers like PostGrid ensures security features to protect the PHI.
At the Collision Conference 2022, we met with marketing experts from some leading healthcare organisations and insurance companies based in Australia and the US. They wanted to know if and how they could use a direct mail marketing tool like PostGrid for their other internal operations.
Our CEO explained how PostGrid’s direct mail and address verification services could streamline their business processes. Everyone was awed by the applicational use of our direct mail and address verification tools. Some of the applicational use of PostGrid that impressed the crowd included its ability to
- Confirm patient identity for HIPAA requirements
- Process distribution of prescription medicines
- Avoid medical identity theft
- Onboard and register patients remotely
- Streamline healthcare communication from top to bottom
You must use HIPAA-compliant service providers like PostGrid to share PHI health data with them. Using business associates often takes a load off healthcare providers and health plans.
For example, PostGrid makes sending billing statements, collection letters etc., becomes significantly easy for hospitals and health insurance providers. Covered entities can use similar HIPAA-compliant business associates to streamline operations like
- Data storage or document storage services
- Data transmission services
- Communication services
- Portals/interfaces for sharing patient details via ePHI
Business Associate Agreement
A Business Associate Agreement or BAA is an agreement signed between a covered entity and its business associate. Signing the BAA is crucial to maintaining HIPAA compliance for your organisation. It states how and when the business associate can access your PHI health data.
Besides this, the Business Associate Agreement also specifies the nature of the outsourced service’s use of PHI Protected Health Information. The agreement must explicitly state that the business associate will either return or destroy the PHI you hand over to it after task completion.
It is also worth noting that while the business associate has custody of PHI health data, it must maintain HIPAA compliance. Hence, you must choose a HIPAA-compliant business associate like PostGrid for your business operations.
Security Of PHI Protected Health Information
The HIPAA security rule is crucial because it lays out the security measure for protecting PHI health data. Companies across all spectrums and industries use the HIPAA security rule guidelines to optimise their security. It regulates the storing and transferring of PHI and defines who can access the PHI.
HIPAA security rule applies to PHI and ePHI data. The biggest takeaway of the HIPAA security rule is the three security safeguards it defines for covered entities.
Even though HIPAA compliance deals with PHI Patient Health Information, these safeguards can help every industry vertical and business organisation.
The three safeguards as per the HIPAA security rule are
- Administrative Safeguarding
- Physical Safeguarding
- Technical Safeguarding
Administrative Safeguarding For PHI Protected Health Information
Administrative safeguards make up nearly half of the HIPAA security rule protecting your PHI health data. The administrative policies and actions establish security measures around
- Selection Management
- Security Maintenance
- Implementation
- Conduct Management
It is best to investigate your existing administrative safeguards thoroughly to ensure HIPAA compliance. Doing so helps you evaluate your security systems and assess the risk factors.
You should also note that these security features or measures are unique for every organisation. Hence, there is no quick way around it other than to carry out a clean security analysis. The administrative safeguards you should have in place to ensure the security of your Protected Health Information includes
- Security Management Process
- Risk Analysis
- Risk Management
- Sanction Policy
- Review Information System Activity
- Assigned Security Responsibility
- Workforce Security
- Information Access Management
- Periodic Training And Security Awareness
- Security Incident Procedures
- Contingency Plan
- Evaluation
- Business Associate Contracts And Other Arrangements
Physical Safeguarding For PHI Protected Health Information
The physical safeguards protect the PHI health data from any physical damage it may face. Like the administrative safeguards, you need to conduct an in-depth analysis of the physical security measures. It includes analysing your security posture, documentation, and potential risks.
Any policies, procedures, and physical obstacles you use to protect the PHI Protected Health Information of a covered entity are physical safeguards. Some of the major components involved in ensuring the physical security of the PHI include the following.
- Facility Access Controls: It involves limiting the physical access to your PHI data to authorised personnel only. Additionally, it addresses the procedure for identifying individual workforce members/Business Associates.
- Workstation Use: The workstation use standard requires you to establish security protocols and procedures for accessing workstations. It is considered a weak point in storing and processing PHI health data. Hence, you need to pay special attention to this part of the security.
- Workstation Security: It dictates how covered entities must protect workstations from unauthorised physical access. Using secured/locked rooms for ePHI and PHI data is an example of workstation security.
- Device and Media Controls: It involves the transfer of electronic and hardware media relevant to the PHI Protected Health Information. Device and Media Controls governs the policies and procedures for devices and media that help them in
- Tracking PHI
- Identifying PHI
- Disposing PHI
- Reusing PHI
Technical Safeguarding For PHI Protected Health Information
As you are well aware, the tech you use for day-to-day business operations keeps changing and evolving. Technical safeguarding involves creating policies and procedures concerning technology for protecting PHI health data.
Today, healthcare providers can quickly access and use PHI conveniently through cloud storage aided by other advanced technologies. At the same time, it raises concerns about risks associated with accessing and sharing PHI health data.
The HIPAA Security Rule does not dictate the technologies you need to use as safeguards. It means you have the flexibility to accommodate a new technology if necessary. Hence, it would be best to use procedures and policies surrounding technical safeguards that stick to specific core principles.
- Access Control: You may use an extensive range of access control methods and technical controls for securing PHI Protected Health Information. HIPAA does not specify access control methods as long as you implement the necessary policies and procedures.
- Audit Controls: You must submit recordings and information system activity per HIPAA compliance requirements. Audit controls help you identify potential security violations. However, HIPAA does not mandate you to review specific data or dictate the frequency of review.
- Integrity: It governs alteration to the PHI Protected Health Information. In other words, it requires you to implement procedures and policies to ensure the integrity of PHI.
- Person or Entity Authentication: You are responsible for ensuring the validity of individuals accessing the PHI. As the covered entity, you must authenticate the person’s proof of identity accessing the PHI data.
- Transmission Security: The transmission security standard requires you to review their existing methods for transferring and transmitting PHI health data. Once the review is over, you must ensure sufficient technical safeguards for your data delivery methods.
Conclusion
Healthcare organisations like hospitals and clinics with sensitive Protected Health Information and security are non-negotiable. Following HIPAA guidelines to ensure the security of PHI optimises your organisation’s data security.
Using advanced HIPAA-complaint tools like PostGrid further enhances the protection of PHI health data. Furthermore, PostGrid ensures active and effective communication for your healthcare organisation.
Healthcare organisations and insurance providers should make it a point to use service providers that deliver the highest quality services. Using HIPAA-compliant tools like PostGrid ensures quality service, even when dealing with crucial data like PHI.
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