PHI/PII & Preventing Security Violations

Modified on Tue, Nov 21, 2023 at 2:51 PM

Updated 11/21/2023


All ESRD Networks are required to follow CMS policy for handling security violations.

  • CMS policy is different from policies at other organizations
  • Corporate email policies do not apply outside of your organization.
  • All facility emails and support Tickets that contain PHI/PII must be immediately reported to CMS


PII: Personally Identifiable Information

  • First Name
  • Last Name
  • Initials
  • Date of Birth (DOB)
  • Social Security Number (SSN)
  • Medicare Beneficiary ID (MBI)
  • Patient Address

 

PHI: Protected Health Information

  • Any PII listed above in combination with any detailed specifics below:
  • Lab results
  • Behavioral concerns
  • Treatment type/duration
  • Past, present, or future: 
    • physical or mental health conditions
    • healthcare provided
    • healthcare payment information

NOT PHI/PIIEQRS UPI

If you email or submit via ticket any PHI/PII to the Network you will be reported to CMS and you will need to complete the US Department of Health and Human Services Cybersecurity Awareness Training and provide a copy of the Certificate upon completion: https://www.hhs.gov/sites/default/files/hhs-etc/cybersecurity-awareness-training/index.html 


When contacting the ESRD Network: always include the UPI, never any PHI/PII !!



If you have any questions, please review resources here: 

  • HIPAA Training Materials: Link

    Health Information Privacy: Link

    Understanding Patient Safety Confidentiality: Link

    HIPAA Basics for Providers: Privacy, Security, and Breach Notification Rules: Guide 
    National Provider Identifier Standard (NPI): Link

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