oh gosh: will they think i violated HIPAA?

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Delilah

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so i submitted my primary already. it contained two anectodes about patients i had a significant interaction w/ as a clinical research coordinator. (i've been a HIPAA certified clinical research coord. for over 2 years). i gave the patients pseudonyms that were real names (Curtis as opposed to Mr. X) so the essay read fluidly. however, i just realized that the adcomm might think that i violated hipaa by disclosing the real name and i'm terrified by this thought. i cant revert my statement. what should i do??

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That's why people suggest NOT changing names unless you specifically say that the names you use are not real.

That said, I wouldn't worry about it. The ability to determine a specific patient without specific dates is nearly impossible.

Besides, even if it is a problem, what's done is done. AMCAS can never be changed after submission, unlike some secondaries.
 
should i write a letter to individual schools clarifying that they are made up names
 
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Using real names is fine in med school essays. Just try to avoid using full names. Med school essays are confidential and people who read them understand their confidentiality.

should i write a letter to individual schools clarifying that they are made up names

no don't worry about it
 
so i submitted my primary already. it contained two anectodes about patients i had a significant interaction w/ as a clinical research coordinator. (i've been a HIPAA certified clinical research coord. for over 2 years). i gave the patients pseudonyms that were real names (Curtis as opposed to Mr. X) so the essay read fluidly. however, i just realized that the adcomm might think that i violated hipaa by disclosing the real name and i'm terrified by this thought. i cant revert my statement. what should i do??

Hmm. I would guess they'd give you the benefit of the doubt, maybe ask you for clarification in an interview.

If you really want to, you can e-mail the schools and let them know that the name in your PS is a pseudonym.
 
Using real names is fine in med school essays. Just try to avoid using full names. Med school essays are confidential and people who read them understand their confidentiality.



no don't worry about it

This is not true. HIPAA is a federal law. It specifically says what can and cannot be disclosed. If an adcom member were to believe an applicant violated this law, it would not help the applicant's chances b/c it would demonstrate a lack of comprehension of the confidentiality required in medicine.
 
My opinion: Don't worry about it. They will give you the benefit of the doubt and it may just be considered annoying if you contact them.
 
This is not true. HIPAA is a federal law. It specifically says what can and cannot be disclosed. If an adcom member were to believe an applicant violated this law, it would not help the applicant's chances b/c it would demonstrate a lack of comprehension of the confidentiality required in medicine.

I disagree. HIPAA prohibits disclosure of Protected Health Information (PHI). In med school essays, I doubt someone would be revealing info that is considered PHI. First names are OK because they are not enough to identify an individual. Check below. You should only be worried if you provided enough information to identify who the patient is.
  1. Names;
  2. All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census:
    1. The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and
    2. The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
  3. All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older;
  4. Telephone numbers;
  5. Fax numbers;
  6. Electronic mail addresses;
  7. Social security numbers;
  8. Medical record numbers;
  9. Health plan beneficiary numbers;
  10. Account numbers;
  11. Certificate/license numbers;
  12. Vehicle identifiers and serial numbers, including license plate numbers;
  13. Device identifiers and serial numbers;
  14. Web Universal Resource Locators (URLs);
  15. Internet Protocol (IP) address numbers;
  16. Biometric identifiers, including finger and voice prints;
  17. Full face photographic images and any comparable images; and
  18. Any other unique identifying number, characteristic, or code
 
I disagree. HIPAA prohibits disclosure of Protected Health Information (PHI). In med school essays, I doubt someone would be revealing info that is considered PHI. First names are OK because they are not enough to identify an individual. Check below. You should only be worried if you provided enough information to identify who the patient is.
  1. Names;
  2. All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census:
    1. The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and
    2. The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
  3. All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older;
  4. Telephone numbers;
  5. Fax numbers;
  6. Electronic mail addresses;
  7. Social security numbers;
  8. Medical record numbers;
  9. Health plan beneficiary numbers;
  10. Account numbers;
  11. Certificate/license numbers;
  12. Vehicle identifiers and serial numbers, including license plate numbers;
  13. Device identifiers and serial numbers;
  14. Web Universal Resource Locators (URLs);
  15. Internet Protocol (IP) address numbers;
  16. Biometric identifiers, including finger and voice prints;
  17. Full face photographic images and any comparable images; and
  18. Any other unique identifying number, characteristic, or code

I understand your point, but the first prohibited point is Names and it is not specific to first/last.

Also, I assume the OP gave some context to the story. A place, perhaps a diagnosis. So going to clinic A with name B perhaps even in a specific timeframe... it would be sketchy, but this is what they are protecting against. Overkill, yes. But HIPAA is a pain in the ass and designed to be bulletproof. You don't want to get too lax with it and it is always better to err on the side of caution. (I've sat through too many HIPAA presentations to mess around)
 
I disagree. HIPAA prohibits disclosure of Protected Health Information (PHI). In med school essays, I doubt someone would be revealing info that is considered PHI. First names are OK because they are not enough to identify an individual. Check below. You should only be worried if you provided enough information to identify who the patient is.
  1. Names;
  2. All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census:
    1. The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and
    2. The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
  3. All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older;
  4. Telephone numbers;
  5. Fax numbers;
  6. Electronic mail addresses;
  7. Social security numbers;
  8. Medical record numbers;
  9. Health plan beneficiary numbers;
  10. Account numbers;
  11. Certificate/license numbers;
  12. Vehicle identifiers and serial numbers, including license plate numbers;
  13. Device identifiers and serial numbers;
  14. Web Universal Resource Locators (URLs);
  15. Internet Protocol (IP) address numbers;
  16. Biometric identifiers, including finger and voice prints;
  17. Full face photographic images and any comparable images; and
  18. Any other unique identifying number, characteristic, or code

So I mentioned a PSEUDONYM, the illness that he had, and the country he emigrated from (this was relevant b/c I spoke about the plight of uninsured immigrants), as well as the hospital where i met him -- thereby revealing the city. It is a pseudonym though. the pt was African, so i ascribed a pseudonym African name to retain some authenticity. so i'm worried that this might come across as his real name when it was in fact completely fabricated. based on that pseudonym and illness and country of nationality, it is impossible to identify the patient. I'm more concerned that an adcomm would think that I didn't bother to use a pseudonym b/c the name (a generic African) sounds like a coneivable name of the patient. Does this make sense? I only used a first name.
 
So I mentioned a PSEUDONYM, the illness that he had, and the country he emigrated from (this was relevant b/c I spoke about the plight of uninsured immigrants), as well as the hospital where i met him -- thereby revealing the city. It is a pseudonym though. the pt was African, so i ascribed a pseudonym African name to retain some authenticity. so i'm worried that this might come across as his real name when it was in fact completely fabricated. based on that pseudonym and illness and country of nationality, it is impossible to identify the patient. I'm more concerned that an adcomm would think that I didn't bother to use a pseudonym b/c the name (a generic African) sounds like a coneivable name of the patient. Does this make sense? I only used a first name.
Yeah, here's how I like to think of it. If a person who knows the patient could identify him based on your information in a reasonable amount of time, then you violated HIPAA. You did a pretty good job of describing the patient, from the sound of it, but without knowing the department or the date you saw the patient, I think you're fine.

I agree with dep's earlier comments. You want to err on the side of caution with these things in the future.
 
Yeah, here's how I like to think of it. If a person who knows the patient could identify him based on your information in a reasonable amount of time, then you violated HIPAA. You did a pretty good job of describing the patient, from the sound of it, but without knowing the department or the date you saw the patient, I think you're fine.

I agree with dep's earlier comments. You want to err on the side of caution with these things in the future.

That was well put.
 
I think the issue here isn't that the OP thought they might have violated HIPAA, just that an adcom might think they used a real name when they didn't, and thus the adcom might assume they violated HIPAA.

Personally, I'd let it go. If they ask at the interview, clarify that you didn't use any real names. If you're REALLY worried about it, I guess you could call each school and ask to speak to someone in the admissions office and explain that you didn't use real patient names, but were worried it might appear that way and were wondering if you could send a letter to that effect to be placed in your file.
 
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I think the issue here isn't that the OP thought they might have violated HIPAA, just that an adcom might think they used a real name when they didn't, and thus the adcom might assume they violated HIPAA.

Personally, I'd let it go. If they ask at the interview, clarify that you didn't use any real names. If you're REALLY worried about it, I guess you could call each school and ask to speak to someone in the admissions office and explain that you didn't use real patient names, but were worried it might appear that way and were wondering if you could send a letter to that effect to be placed in your file.

Phoenix (my favorite mythology by the way second to Daedalus) -- exactly. I'm worried more about perceived carelessness. I just don't want them to tank my essay, or raise a red flag before giving me the benefit of the doubt. Thanks for the suggestion.
 
Phoenix (my favorite mythology by the way second to Daedalus) -- exactly. I'm worried more about perceived carelessness. I just don't want them to tank my essay, or raise a red flag before giving me the benefit of the doubt. Thanks for the suggestion.
I'd shoot them an email to ask what you should do. Some schools will simply print the email to put in your file (do we seriously have paper files or is it all electronic nowadays). If schools tell you not to worry, then you can leave it at that.

Either way though, ease your mind and contact the schools if you're still worried on Monday.
 
Hey there Delilah
What's it like in New York City?
 
Phoenix (my favorite mythology by the way second to Daedalus) -- exactly. I'm worried more about perceived carelessness. I just don't want them to tank my essay, or raise a red flag before giving me the benefit of the doubt. Thanks for the suggestion.

Thanks! I'm a huge mythology fan too. (Technically, I'm "rising from the ashes" of my prior career.)

And while I think you'll be fine, I can completely understand stressing about this. Best thing for your peace of mind is to call the schools and run it by them. G'luck!
 
Every year on SDN, someone gets worried about violating HIPAA in their essay. IMO you don't need to worry about it. HIPAA law is complicated and people on this forum, as well as Adcom essay readers, are not lawyers specializing in HIPAA. You can contact the school if you'd like, but I doubt they really care or know if it really is a violation of HIPAA. Good luck!
 
here was the first example:

"...I was fortunate to meet people like [GENERIC AFRICAN NAME]. Although today a florist, [GENERIC AFRICAN NAME] emigrated from Malawi to study pharmacology. In his second year of school, he discovered that he was HIV positive, and was forced to drop out due to his deteriorating vision. Much like the millions of uninsured who constantly negotiate with fatality, [GENERIC AFRICAN NAME] delayed treatment for his HIV, until CMV retinitis nearly eclipsed his vision. It took six years of failed treatment options and clinical trials for the team of physicians to fine tune a stabilizing regimen for him. I admired the dedication and skill with which they guided him back to a productive life, and was honored to have witnessed his recovery."

second:

[PSEUDONYM] abused heroin
 
here was the paragraph:

...I was fortunate to meet people like [GENERIC AFRICAN NAME]. Although today a florist, [GENERIC AFRICAN NAME] emigrated from Malawi to study pharmacology. In his second year of school, he discovered that he was HIV positive, and was forced to drop out due to his deteriorating vision. Much like the millions of uninsured who constantly negotiate with fatality, [GENERIC AFRICAN NAME] delayed treatment for his HIV, until CMV retinitis nearly eclipsed his vision. It took six years of failed treatment options and clinical trials for the team of physicians to fine tune a stabilizing regimen for him. I admired the dedication and skill with which they guided him back to a productive life, and was honored to have witnessed his recovery.
Mmm... I'd let the schools know.
 
Even if they did think you gave real names, I don't think they would hold it against you. I doubt they expect you to know about a law that is not even clearly understood by medical professionals. Also, if you do understand the law, why would you just disregard it? Some people seem to find gray areas. Now if you were working in the medical field in any sense prior to application, they might raise an eyebrow. I would just wait and see. Next time just use a few more characters to state the names are not actual. Or just use the typical age/sex format. For example: "A 50 year old male patient ....."

I think they will give you the benefit of the doubt.

Good Luck
 
I understand your point, but the first prohibited point is Names and it is not specific to first/last.

If I said "Mr. X," or "Bob," it's not like these people are easily identifiable unless I am MUCH more specific. If it is a common name, the person might not even be identifiable without other details. I doubt anything will happen just because you mentioned a name (or pseudonym, whatever) and talked about a medical issue. It might be a different story if you also specified the hospital and a rough time frame (ie, if you say 'last year' or something to that effect), because a person might be able to get the patient's details with a little digging.
 
i think it should be fine. getting an extra document stuck in your file will draw unnecessary attention to your "mistake". chances are whoever's reading will be enjoying the story too much to notice it.
 
so i submitted my primary already. it contained two anectodes about patients i had a significant interaction w/ as a clinical research coordinator. (i've been a HIPAA certified clinical research coord. for over 2 years). i gave the patients pseudonyms that were real names (Curtis as opposed to Mr. X) so the essay read fluidly. however, i just realized that the adcomm might think that i violated hipaa by disclosing the real name and i'm terrified by this thought. i cant revert my statement. what should i do??

I really, REALLLY wouldn't stress about this. I had to be certified through HIPPA for my research too and all I can say is it was a 15 minute online program that ended in a quiz you could take as many times as necessary to pass. It was created to protect people who had something discovered/used in a study from being bothered, or slapped in some published medical study without their permission ... or to make sure names didn't fall into hands of people who could deny health insurance, etc etc. What you did was an honest mistake, and didn't hurt or (really) realease any medical information to someone who would use it. Disclaimer ... I don't know how adcoms think, this is my common sense speaking, but IN MY OPINION; I don't even think anyone reading your essay would ever realize what you did, or think down on you because of it.
 
Some schools will simply print the email to put in your file (do we seriously have paper files or is it all electronic nowadays).

Some schools have completely electronic records. Colorado, before this year, went and scanned in every paper document they received for an applicant's file. This year, they just require everything, except the check, electronically.
 
OP, relax! I had similar concerns about my personal statement, I mentioned three very generic made up first names in passing because the names helped the flow and emotion of the essay. I got really scared after submitting that I should not have used any names, even if they were generic and made up. I talked to my very experienced pre-med advisor and she told me I was totally overreacting. She said in her years and years of experience, she has NEVER seen this come up as an issue...adcoms have a million things to worry about, and they are not going to be sitting there second guessing whether or not your violated HIPAA confidentiality...so don't worry, and relax! What's done is done, and I don't think you did anything wrong, or will leave anyone wondering...
 
You should be fine.

If you mention 'Kwabena' from Malawi who has HIV, I don't think anyone is going to know who you're talking about, except potentially if you applied to the school where 'Kwabena' studied pharmacology.
 
You should be fine.

If you mention 'Kwabena' from Malawi who has HIV, I don't think anyone is going to know who you're talking about, except potentially if you applied to the school where 'Kwabena' studied pharmacology.

You're funny Enigma. And no, I didn't apply to that school.

And chickenlittle, that's exactly why I opted to use real names as opposed to initials. For flow and readability...

Thanks everyone.
 
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