Remove direct identifiers before a health record is summarized

Key facts

Human involvement
YellowClose supervision
How AI is used
List each direct identifier the lawyer marks, the page it appears on, and a proposed removal. Do not send the record to a tool and do not say the result is de-identified.
What the lawyer must review
45 CFR § 164.502 provides that a covered entity or a business associate may not use or disclose protected health information except as permitted or required by that subpart or by subpart C of part 160. A permitted disclosure includes disclosure to the individual and, as § 164.506 allows, for treatment, payment, or health care operations. The de-identification standard was not opened. Do not treat a removal of names as meeting it. You decide whether a disclosure is permitted before any record is put into a tool. Formal Opinion 512 requires informed consent before information relating to the representation goes into a self-learning tool. The HHS covered-entity page is the starting point for whether the holder is a covered entity or a business associate.
Written for / version
United States versionUS

Who does what

Who does what
RoleWhat they do
AssistancePotential support includes identifying points for review. Confirm the tool’s capability and permitted scope.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
  2. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  3. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

Related tasks

Related jurisdictions