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  1. FHIR Specification Feedback
  2. FHIR-35806

Use of “de-identified, but potentially re-identifiable” information and PHI

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    • Icon: Change Request Change Request
    • Resolution: Not Persuasive with Modification
    • Icon: Medium Medium
    • US Da Vinci CRD (FHIR)
    • current
    • Clinical Decision Support
    • Supported Hooks
    • 4.2.1
    • Hide

      The question is made moot by the resolution of FHIR-36052, which will remove all of the de-identified support

      Show
      The question is made moot by the resolution of FHIR-36052 , which will remove all of the de-identified support
    • Bob Dieterle / Rachael Foerster : 8-0-0
    • Correction
    • Non-compatible
    • Yes

    Description

      http://build.fhir.org/ig/HL7/davinci-crd/hooks.html#phi-and-hook-invocation says that CRD clients SHALL support CRD without PHI using a de-identified Patient and Coverage, however by including things like group/plan ID, patient date of birth, gender, and patient ID, it's very easy for the third party to look up information on the patient and/or reidentify them.

      Given that, the scenarios mentioned here:

      Nevertheless, there are situations where PHI will not be shared with a CRD Service because a patient has withheld consent to share information with the payer, the provider has concerns about sharing sensitive data with the payer...

      Don't seem to be addressed by the current spec.

       

      We've historically avoided supporting de-identification since it's filled with potential landmines, and don't think it belongs in the spec.

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            Unassigned Unassigned
            kjohnsen Kyle Johnsen
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              Updated:
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