Expert Determination
Performing a statistical analysis on your information is critical to ensuring very small risk of unauthorized identification or disclosure. We regularly advise clients on healthcare data ingestion, processing, procedures, storage and exchange of healthcare data regarding disclosure risk.
We offer bespoke expert determination reports to meet your organizational, vendor, and customer requirements to meet relevant data compliance regulations such as the Health Insurance Portability and Accountability Act (HIPAA).
Our typical assessment involves
Our reports are much more than a pass/fail document. Our customers are immersed in our processes and communication is key.
What our HIPAA expert determinations cover
We offer bespoke expert determination reports to meet your organizational, vendor, and customer requirements to meet relevant data compliance regulations such as the Health Insurance Portability and Accountability Act (HIPAA).
Our typical assessment involves
- Collating your information and gathering assumptions
- Performing relevant statistical disclosure risk analyses on your data
- Presenting initial findings and recommendations
- Delivering a finalized determination report
Our reports are much more than a pass/fail document. Our customers are immersed in our processes and communication is key.
What our HIPAA expert determinations cover
- Determination based on a representative data sample
- Determination of combined sets of deidentified data
- Determination of a data feed
- Determination of a growing/expanding dataset
HIPAA Expert Determination
45 CFR § 164.514 (b):
“A covered entity may determine that health information is not individually identifiable health information only if:
(1) A person with appropriate knowledge of and experience with generally accepted statistical and scientific principles and methods for rendering information not individually identifiable:
(i) Applying such principles and methods, determines that the risk is very small that the information could be used, alone or in combination with other reasonably available information, by an anticipated recipient to identify an individual who is a subject of the information; and
(ii) Documents the methods and results of the analysis that justify such determination“
45 CFR § 164.514 (b):
“A covered entity may determine that health information is not individually identifiable health information only if:
(1) A person with appropriate knowledge of and experience with generally accepted statistical and scientific principles and methods for rendering information not individually identifiable:
(i) Applying such principles and methods, determines that the risk is very small that the information could be used, alone or in combination with other reasonably available information, by an anticipated recipient to identify an individual who is a subject of the information; and
(ii) Documents the methods and results of the analysis that justify such determination“
Other Disclosure Risk Analysis Options
Where the traditional HIPAA expert determination may not quite fit your needs, we have alternate solutions for other regulatory areas, different types of data, and conceptual new solutions you may be bringing to market
Expert opinions
Disclosure risk assessments of overall processes and technologies
Unstructured Dataset analysis
Characterization of risk documents
Expert opinions
- Investing heavily in developing ideas without considering privacy initially can have costly repercussions or remedies later down the line. During the conceptual stages of your product development we look at the ideas in principle. We outline areas of potential disclosure risk and best practices to mitigate against this risk. At a later stage, expert opinions can be used as the base for our expert determination reports. These opinions are often used by our clients to support approvals; internally, with data vendors, and customers and advance the concepts to the development stage.
Disclosure risk assessments of overall processes and technologies
- Sometimes an expert determination alone doesn’t build a full picture or reidentification risk in a process. Our disclosure risk assessment is a documentation of your overall process to highlight risk areas combined with any relevant expert determination work needed. This robust report can be used to support documentation of compliance efforts both internally and externally.
Unstructured Dataset analysis
- Traditionally disclosure risk analysis of deidentified data has been performed on structured datasets. As technology such as AI advances, the ability to deidentify unstructured data becomes easier. Incorporating unstructured health data into current data sources could positively influence future innovation in healthcare data analysis. Mirador works with companies to assess the effectiveness of redaction tools and deidentification engines, as well as, assessing the outputs they produce.
Characterization of risk documents
- An organisation may not always need an expert determination or be trying to deidentify data. However, it can be beneficial from a security and compliance perspective to understand the areas of disclosure risk within a process.
Timeline and Pricing
Timelines
Our typical projects take less than 4 weeks from receiving a data sample to providing a determination report for one off projects and less than 2 weeks as part of our ongoing disclosure risk support offering.
Pricing
We offer a fixed cost for a standard structured data expert determination, with both hourly and fixed pricing available for additional changes or updates. We offer the ability for client’s to easily transition from or “one-off” determinations into or ongoing support as needed.
We have flexibility on our fixed price offering when completing multiple determinations with Mirador.
Our typical projects take less than 4 weeks from receiving a data sample to providing a determination report for one off projects and less than 2 weeks as part of our ongoing disclosure risk support offering.
Pricing
We offer a fixed cost for a standard structured data expert determination, with both hourly and fixed pricing available for additional changes or updates. We offer the ability for client’s to easily transition from or “one-off” determinations into or ongoing support as needed.
We have flexibility on our fixed price offering when completing multiple determinations with Mirador.
