Health Information Compliance Alert

READER QUESTIONS:

IS A SOCIAL SECURITY NUMBER APPROPRIATE AT SIGN IN?

Question: We ask patients to write down their date of birth or the last four digits of their Social Security numbers when signing in so we can properly match up their charts. Is this allowable under HIPAA?


Indiana subscriber


Answer: The Office of Civil Rights allows the use of sign-in sheets for patient check-in, but only if the information disclosed on them is appropriately limited. Your current procedure may not be a violation in the strictest sense, but there are more secure choices than birth dates or Social Security numbers (even partial) you can use to identify patients' information correctly.

Alternative: Since the combination of a person's name and birthdate or Social Security number may provide an entry into other personal information, consider requesting less specific information such as the month of their birthday or the name of their street. That way, even if someone inappropriately accesses the sheet, the information is unlikely to harm the patient.

While any information seen on your sign-in sheet or overheard in your waiting room is categorized as an incidental disclosure, being cautious about the information you ask patients to disclose can protect your practice as well as your patients.