HIPAA - De-identified information

[J2D2]

Can someone help me determine if I am reading the definition of "de-identified information" correctly? Reg. 164.514(b)(2)(i)© seems to provide that it is OK to not remove an individual's year of birth in creating de-identified information. In other words, it looks like a de-identified record could not include an exact birthdate, e.g. 1/1/1973, but could show the year of birth, e.g. 1973. Any thoughts?

[Guest b2kates]

generally, I agree, but watch out that the individual year is unique and thereby identifies an individual; i.e. the only person born in 1985 is .....

we watched this situation with respect to zip code sorting also.

[Steve72]

I agree with b2kates.

I don't have the regs in front of me, but I also believe there is an age limit (i.e., you couldn't provide a date of birth that indicated the individual was over 89...or something).

I could be mistaken, however.

[J2D2]

Both of you raise excellent points. Thank you.