HIPAA Compliance and Protected
Health Information (PHI)
§ HIPAA may impact availability of certain data, but does
not govern research using data per se
§ Applies to protected health information (identifiable
information) generated only from covered entities
§ De-identified health information is not covered by the
Privacy rule
§ PHI may be used and disclosed for research if individual
gave written permission
§ PHI may be used and disclosed under a waiver, as a
limited data set with a data use agreement, preparatory
to research, and for research on deceased individuals
§ Privacy not covered by the Privacy rule may be covered
by other rules, e.g. the “Common Rule”
§ Further information is available in the Columbia
University HIPAA training module