PHI and HIPAA Identifiers: What Do They Mean for Marketing Analytics in Healthcare?

Did you know that over half of U.S. citizens use the Internet to look for health-related information? When we combine this with the personal details they share with medical institutions and services, we have a vast amount of highly sensitive data.

Healthcare marketers need this data to understand patient needs and boost engagement. However, this data is often considered Protected Health Information (PHI) and must be guarded against harmful practices at all times.

To enhance PHI security, the Department of Health and Human Services (HHS) introduced HIPAA identifiers, a list of specific types of information linking individuals to their healthcare data, backed by the Health Insurance Portability and Accountability Act (HIPAA).

This makes promotional activities complex, especially marketing analytics in healthcare. 

What’s PHI?

PHI includes any data about health status, healthcare services, or payment for healthcare that can be tied to a person. For example, a patient’s medical history in your records is PHI. However, PHI isn’t just medical records; it also covers conversations about patient care, billing details, and even health insurance information.

In short, PHI is any data that could identify someone by their healthcare details.

Given its sensitivity, using PHI for marketing analytics in healthcare needs to be tightly controlled. Otherwise, you could face pricey HIPAA fines and severe consequences for your practice.

What are HIPAA Identifiers?

HIPAA identifiers are specific pieces of information that, when combined with health data, create PHI. They’re protected under HIPAA rules to ensure patient privacy and control over their health information.

The main purpose of these identifiers is to ensure that any data that could identify someone is treated with the utmost care and confidentiality.

HIPAA Identifiers: The List

Here are the 18 HIPAA identifiers, each carrying the potential to identify an individual patient:

1. Name – Any part of a patient’s name.
2. Address (all geographic subdivisions smaller than a state) – Includes street address, city, county, and zip code.
3. All dates (except years) related to an individual. This includes birthdate, admission date, discharge date, date of death, and exact age if over 89.
4. Telephone numbers – Any phone number linked to an individual.
5. Fax number – Any fax number linked to an individual.
6. Email address – Personal or work email addresses.
7. Social Security Number – A unique number assigned to U.S. citizens and residents.
8. Medical record number – Unique identification number assigned to a patient’s medical records.
9. Health plan beneficiary number – Identification number associated with a health insurance policy.
10. Account number – Any number linked to a financial account.
11. Certificate or license number – Professional or personal certification or license numbers.
12. Vehicle identifiers and serial numbers – Including license plate numbers.
13. Device identifiers and serial numbers – Unique numbers assigned to medical devices.
14. Web URL – Internet addresses linked to an individual.
15. Internet Protocol (I.P.) Address – Unique numeric identifier assigned to a device.
16. Fingerprint or voiceprint – Biometric data used to verify identity.
17. Photographic image – Including, but not limited to, images of the face.
18. Any other characteristic – This includes any distinctive detail that can identify a person.

Even though it’s a long list, every healthcare marketer should know it. Otherwise, HIPAA fines are bound to happen.

PHI Vs. Marketing Analytics in Healthcare: The Road to HIPAA Violations or Powerful Alliance?

If you’re a healthcare marketer, you know that the success of your promotional activities depends on analytics and tracking. Without it, you stay in the dark, not knowing how your marketing performs or if your advertising dollar is well-spent.

With that in mind, you choose mighty tools like Google Analytics 4 (GA4) and Google Tag Manager (GTM) to make the most of the marketing analytics in healthcare. You supply them with patient data to get more precise insights. But, instead of the insights, you end up in HIPAA violations. 

GA4: The Most Needed Non-Compliant Tool

According to the 2022 guidelines on tracking technologies from HSS, which were updated this March, services like GA4 aren’t HIPAA-compliant. So, if any PHI is captured by GA4, you could face hefty HIPAA fines and legal issues.

For instance, identifiers like user IDs, location data, and partial IP information processed by GA4 for geolocation may qualify as PHI. Even though GA4 captures IP addresses during transit, HIPAA still considers this data identifiable if tied to health-related activities.

While this may lead some marketers to consider giving up this vital tool, no matter how valuable its insights are, there are solutions.

What about GTM?

Just like GA4, GTM has its own set of challenges. As per Google’s rules, you can’t share any PHI or HIPAA identifiers through GTM.

However, client-side tagging can collect and send PHI, leading to potential HIPAA violations. On the other hand, server-side GTM gives you more control over data sharing, but it still needs careful setup to stay compliant. That means there’s a way to use this tool in a HIPAA-compliant way.

Ready for Safe Marketing Analytics In Healthcare? Then, Make GA4 and GTM HIPAA-compliant.

If you’re looking for a solution to make your marketing analytics HIPAA-compliant, choose HIPALYTICS.

We make GA4 and GTM safe by anonymizing PHI and storing it on private, US-based servers. This way, patient data stays secure, sparing you compliance issues, liability, and fines. To ensure this, we sign a BAA and manage ongoing updates for GA4, GTM, and HIPAA regulations.

With HIPALYTICS, you use these powerful tools like always, but with peace of mind and free from HIPAA risks.