To what extent does and e-mail need to be deindentified currently.  We are
placing reasonable technical safeguards in place with encyption.  We feel
that some level of deindentification is still necessary.  Is it "reasonable"
to include first name last initial such as John S?  We are finding it
"unreasonable" for us to use only initials because we have individuals with
the same initials and it is difficult for our staff to efficiently identify
who the individual is referring to.

To explain our situation further, as a home health agency we have therapist
provide summary updates on patient progress.  They are e-mailed to us for
purposes of producing a clean readable document that is forwarded in U.S.
mail to the physician.  Currently they place patient first name and last
initial on the document.  No other PHI is present(as summary of progress by
itself does not seem to be PHI by the definitions I have seen..please
correct me if I am wrong)  Knowing our situation, what do others think is
reasonable?  Is there specific language in the law someone can direct me to?

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