05-02-2014, 12:11 AM
http://www.compbenefits.com/hipaa_policy.html
"We have received a number of questions inquiring as to whether or not the Privacy Rules promulgated under the Health Insurance Portability and Accountability Act ("HIPAA") will prohibit the collection or use of an individual's Social Security number as an identifier for the group health plan.
Although the HIPAA Privacy Rules provide for the protection of individually identifiable information, which may include Social Security numbers, we do not believe that it is the intent of HIPAA to limit the collection or use of an individual's Social Security number for the following reasons. First, and most importantly, the HIPAA regulations do not specifically prohibit the use or disclosure of an individual's Social Security number. Secondly, since the individual's Social Security number falls under the same category as other individually identifiable information, such as the individual's name and address, it is equally protected under the HIPAA privacy and security requirements. Lastly, because of the fact that the Social Security number falls under the same category as other individually identifiable information, to prohibit the use or disclosure of the individual's Social Security number would also preclude the use of the individual's other identifiers, such as name and address, which is clearly not the intent of HIPAA.
We hope that this information has been helpful in your understanding of why we believe that the use of Social Security numbers is still allowed under the HIPAA regulations
If you should have any questions, please do not hesitate to contact our Privacy Officer at privacyofficer@compbenefits.com. "
"We have received a number of questions inquiring as to whether or not the Privacy Rules promulgated under the Health Insurance Portability and Accountability Act ("HIPAA") will prohibit the collection or use of an individual's Social Security number as an identifier for the group health plan.
Although the HIPAA Privacy Rules provide for the protection of individually identifiable information, which may include Social Security numbers, we do not believe that it is the intent of HIPAA to limit the collection or use of an individual's Social Security number for the following reasons. First, and most importantly, the HIPAA regulations do not specifically prohibit the use or disclosure of an individual's Social Security number. Secondly, since the individual's Social Security number falls under the same category as other individually identifiable information, such as the individual's name and address, it is equally protected under the HIPAA privacy and security requirements. Lastly, because of the fact that the Social Security number falls under the same category as other individually identifiable information, to prohibit the use or disclosure of the individual's Social Security number would also preclude the use of the individual's other identifiers, such as name and address, which is clearly not the intent of HIPAA.
We hope that this information has been helpful in your understanding of why we believe that the use of Social Security numbers is still allowed under the HIPAA regulations
If you should have any questions, please do not hesitate to contact our Privacy Officer at privacyofficer@compbenefits.com. "