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The PHI line

The one rule that shapes every prompt in this course, the four moves that de-identify a survey note, and the client Project that holds a facility without holding a person.

Nine facilities, one rule

Dr. Salma carries nine clients: three surgery centres, two dental groups, three skilled nursing facilities and a wound clinic. Each gives her a different set of standards and the same category of data to refuse. Before any of this work is safe, the line has to be drawn once and held everywhere.

The rule is short. Nothing that identifies a patient or an employee goes into a chat. No name, no room or bed number, no medical record number, no date of service, no admission or birth date, no photograph of a chart or a wound. And no de-identified version of a patient story that still carries a date, because a knee case on a stated day at a single four room centre is one person.

That last part is where consultants slip. De-identification is not name removal. In a forty bed facility, a date plus a unit plus a diagnosis is an identifier, and deleting the name does not change that.

What crosses and what does not

Employee health sits on the same side as patient data. A fit test result, an exposure, a vaccination status: those live in the employee file and reach your report as a count.

Four moves before the first paste

Do these on the drive back, not at eleven at night with a report due.

1. Every name becomes a role. The circulating nurse. The infection preventionist. The administrator.
2. Every calendar date becomes a relative marker. Week one of the review period. Day three after the index case.
3. Every individual becomes a count with a denominator. Three of eight opportunities. Two of five loads.
4. Every facility becomes a type and a client code. ASC-4. SNF-2. The key stays in your files.

The client Project

One Project per client, named by code. It holds a facility and nothing about a person.

Files. The facility profile: type, licence categories, room count, services, sterilization equipment, water and ventilation systems, the survey body. The current policy set. The last findings register. The guidance PDFs this facility type is held to.

Instructions. The standing brief below.

Not in the Project. Line lists, employee health records, anything carrying a patient date, and the key that maps codes to facilities.

The instruction set

You assist me, Dr. Salma. I run an infection prevention and healthcare compliance consultancy. This Project covers one client, an ambulatory surgery centre with four operating rooms, referred to as ASC-4.

Refuse protected health information. If anything I paste carries a name, a room number, a record number, a date of service or a narrative about one person, stop, tell me which line, and wait. Do not de-identify it for me and continue.

Never state a standard, regulation or citation as established. When a requirement is relevant, name the source and the section you believe applies, then repeat it in a list headed Verify before citing, with the exact proposition I am checking. I open the source myself before anything is cited.

Work in the language of survey: observation, finding, standard, risk, corrective action, responsible party, due date. Facility deficiencies are confidential to the client and are never softened. Format: tables of three columns or fewer, plain sentences, no exclamation marks, no em dashes.

Try this

Below are my raw walkthrough notes. Rewrite them as de-identified observations: roles instead of names, counts with denominators instead of individuals, week numbers of the review period instead of dates. Then list separately, without quoting them back, every line you dropped and what made it identifying.

[paste the raw walkthrough notes]

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