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HIPAA Q&A: De-identifying pill bottles

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Q. Some of the medications we receive for our assisted living residents are in blister packs. After the pack is emptied, the labels are easily torn off and shredded. However, some medications are received in a multidose pill bottle. Is using a felt-tip marker an acceptable means to de-identify these labels before placing the bottles in the trash?

A. Yes. Obliterating patient identification (including name and medical record number) with a permanent marker is a good way to protect patient privacy before disposing of these containers.

Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, a nationally recognized expert on patient privacy, information security, and regulatory compliance, answered this question. She is associate executive director of Health Information Management (HIM) at Scott & White Healthcare in Temple, TX. Some of her publications were used as a basis for the Health Insurance Portability and Accountability Act of 1996 privacy regulations.  

Categories : HIPAA Q&A


  1. I would like to make a comment to the above question. I have found that using a felt-tip marker do allows an individual to see through and read the PHI that is being blacked out. I have found the best approach is to use a black ball point pen which will make the PHI unidentifiable.

  2. Ronda Hogan says:

    I very much agree. You certainly can read right through a marker blackened area. It also helps to write other random letters overtop of the PHI, then scribble.

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