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When is health information considered PHI?

Health-related information is considered PHI if (any of the following are true):

  1. the researcher obtains the records directly from a health plan, health care clearing house, or health care provider;
  2. the records were created by any of the entities (aka Covered Entities) in "1" and the researcher obtains the records from an intermediate source; OR
  3. the researcher obtains it directly from the study subject in the course of providing treatment to the subject.

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