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HEALTHCARE AGENTS · PATIENT DE-IDENTIFICATION

De-identify PHI and SUD data with an agent built for HIPAA expert determination

De-identify PHI and SUD data with an agent built for HIPAA expert determination

De-identify PHI and SUD data with an agent built for HIPAA expert determination

Expert determination needs a qualified statistician and a sound method, not a certified attester. The Patient De-identification Agent inventories every identifier, removes and measures, and drafts the determination for a qualified statistician to sign. One team, one contract, one accountable party.

In short: the Patient De-identification Agent prepares PHI and 42 CFR Part 2 data for research, analytics and data partnerships under HIPAA expert determination. It inventories identifiers, transforms and measures re-identification risk, and drafts the determination for a qualified statistician to sign.

Expert determination needs a qualified statistician and a sound method, not a certified attester. The Patient De-identification Agent inventories every identifier, removes and measures, and drafts the determination for a qualified statistician to sign. One team, one contract, one accountable party.

In short: the Patient De-identification Agent prepares PHI and 42 CFR Part 2 data for research, analytics and data partnerships under HIPAA expert determination. It inventories identifiers, transforms and measures re-identification risk, and drafts the determination for a qualified statistician to sign.

THE METHOD

How the determination is reached

How the determination is reached

How the determination is reached

Under 45 CFR 164.514(b)(1), the agent does the work and a qualified statistician signs.

Under 45 CFR 164.514(b)(1), the agent does the work and a qualified statistician signs.

01

Classify, then segment

The agent classifies every field and span of free text, and segments Part 2 records before anything is transformed.

02

Measure the risk against numbers, not a checklist

The agent measures k-anonymity, l-diversity and t-closeness across the full linked record, each against a threshold the release must clear.

03

Change only what the numbers say to change

The agent suppresses or generalises only where a measurement misses, and shifts dates per patient so intervals survive.

04

The agent produces the evidence, then a person signs it

The agent drafts the determination. A qualified statistician signs it, and a checksum binds it to the exact data set.

WHAT IT PRODUCES

What the engagement produces

What the engagement produces

What the engagement produces

Prebuilt for de-identification, configured to your systems and release rules. Five deliverables, one contract.

Prebuilt for de-identification, configured to your systems and release rules. Five deliverables, one contract.

The de-identification process

The de-identification process

Built and run by the agent in your environment or ours, designed against the risk model.

The full expert determination report

The full expert determination report

Method, analysis and determination, drafted by the agent, signed by a qualified statistician, bound to the data set by checksum.

A summary report you can share

A summary report you can share

A shorter document for authorized recipients, so the full method log stays with you.

Twenty four months of validity

Twenty four months of validity

The determination holds for 24 months, with re-attestation when the data or population changes materially.

Monthly monitoring

Monthly monitoring

The agent keeps measuring between attestations, because a growing data set changes its risk profile.

THE SYSTEMS IT READS

The systems the Patient De-identification Agent is configured to

The systems the Patient De-identification Agent is configured to

The systems the Patient De-identification Agent is configured to

Reached where they sit. Identifiers live in all of them.

Reached where they sit. Identifiers live in all of them.

Epic

Epic

Encounters, notes and MRNs

Oracle Health

Oracle Health

Inpatient records and orders

MEDITECH

MEDITECH

Community hospital charts

athenahealth

athenahealth

Ambulatory charts and billing

Netsmart

Netsmart

SUD and behavioral health programs

Kipu and similar

Kipu and similar

Treatment program records

Clinical notes

Clinical notes

Identifiers inline, in free text

Pathology and imaging

Pathology and imaging

DICOM headers carry names

Lab results

Lab results

HL7 feeds and ordering data

Claims 837 and 835

Claims 837 and 835

Members, subscribers and dates

Consent records

Consent records

Part 2 consent and revocation

Datavant

Datavant

Tokens for linkage after release

FAQ

Patient de-identification and expert determination: common questions

Patient de-identification and expert determination: common questions

Patient de-identification and expert determination: common questions

What is HIPAA expert determination?

What is HIPAA expert determination?

One of the two de-identification methods HIPAA allows, under 45 CFR 164.514(b)(1). A qualified statistician measures re-identification risk and determines in writing that it is very small.

Do you need to be certified to provide an expert determination?

Do you need to be certified to provide an expert determination?

No. There is no certification or register of approved attesters. The rule asks for appropriate statistical expertise and documented methods and results.

Can 42 CFR Part 2 SUD data be de-identified?

Can 42 CFR Part 2 SUD data be de-identified?

Yes, on its own track from the start. Part 2 records are segmented before any transformation and governed separately, because they carry obligations HIPAA alone does not.

Do we need a data team to run this?

No. We connect your systems, configure the agent to your rules and run the layer underneath it. Your team reviews and approves the agent’s work; nobody has to build or maintain data pipelines.

Do we have to move our data into a new warehouse first?

No. The agent works across the systems you already run, through a governed context layer that keeps every figure traced to the record it came from. If you already have a warehouse, it becomes one more source.

Why not build this ourselves?

You can, and for some teams it is the right call. The build is rarely the hard part. Resolving the same patient and identifier across systems, keeping definitions consistent and getting the team to use it every week is where internal projects stall. We take that on so your engineers do not become platform operators.

What are your security and compliance standards?

OutcomeCatalyst is HIPAA-aligned and SOC 2 Type 2 aligned, with the formal audit underway and expected to complete before year-end.

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and put AI to work.

Let’s build your company a brain
and put AI to work.

Let’s build your company a brain
and put AI to work.

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