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November 8, 2019

Identifying Social Determinants of Health, Coding, and HIPAA Compliance

Written by: Compliance blogger


A patient’s health outcome might be affected by a wide variety of factors, some of which can stem from their environment and surroundings. These types of influences, called social determinants of health, are gaining more visibility as healthcare providers and organizations look for methods to identify them and attempt to manage the bigger health picture that many patients face.

As a provider, it is important to understand not only how to address social determinants of health, but also what privacy and security regulations might govern the use of this information.

What Are Social Determinants of Health?

To put it briefly, social determinants of health are the ways that the conditions in which people live affect their health. They might include such factors as transportation, housing, education, or social isolation. For example, if an individual does not have access to a reliable source of transportation, they cannot always get to the doctor when they are ill. This, in turn, can make it more difficult to manage health conditions, especially chronic ones.

One reason these influences are so important for healthcare professionals to consider is because addressing them is a key part of achieving health equity. Minority groups, in particular, tend to be disproportionately affected by social determinants of health. There are a number of ways that healthcare providers are beginning to incorporate social determinants of health into patient care.

Of course, the first step in addressing these factors is to collect information about them from the patient.

How Can Providers Identify Social Determinants of Health?

In some situations, a clinician may decide to make a note of a patient’s socioeconomic and psychosocial needs. If this happens, there is a group of codes within ICD-10 that can help record this information – Z codes. Some examples of these Z codes include:

  • Z56: Problems related to employment and unemployment
  • Z58: Problems related to physical environment
  • Z59: Problems related to housing and economic circumstances
  • Z60: Problems related to social environment

The Centers for Medicare and Medicaid Services (CMS) is also conducting tests to determine whether finding and dealing with the health-related social needs of Medicare and Medicaid beneficiaries can improve their health outcomes or affect their healthcare costs. One of the ways they are examining this potential difference is by asking providers to use the Accountable Health Communities (AHC) Health-Related Social Needs Screening Tool. This tool focuses on five core areas:

  • Housing instability
  • Food insecurity
  • Transportation problems
  • Utility help needs
  • Interpersonal safety

This screening tool also includes eight supplemental domains covering topics such as financial strain, family and community support, education, and mental health.

It is important to note that the AHC Health-Related Social Needs Screening Tool is not yet standard practice nationwide. It is primarily being used as a way to increase awareness of social determinants of health. However, it is a standard tool for the communities that are participating in the AHC Model.

This model is a collaboration of thirty participating organizations designed to address the health-related social needs of Medicare and Medicaid beneficiaries by:

  • Screening beneficiaries in the community to identify certain unmet health-related social needs,
  • Referring beneficiaries in the community to increase awareness of community services,
  • Assisting high-risk beneficiaries in the community with accessing community services, and
  • Working to ensure that community services are available and responsive to the needs of beneficiaries in the community.

Finally, the Agency for Healthcare Research and Quality (AHRQ) also provides a number of resources and tools that providers and researchers can use to gain a better understanding of how social determinants of health might be affecting individuals’ health outcomes.

Is Social Determinants Of Health Data Protected Under HIPAA?

Once your organization has collected data about social determinants of health that are potentially influencing a patient, what steps should you take to keep this information secure and protected? Before answering this question, you should first identify whether any of this information might be protected under HIPAA.

The HIPAA Privacy Rule sets forth requirements for protecting individually identifiable health information. This information includes any data that relates to an individual’s past, present, or future physical or mental health. It also covers any data for which there is a reasonable belief that it could be used to identify the patient. Based on this definition, data that a provider might collect about social determinants of health, such as information about housing, employment, interpersonal safety, et cetera could potentially fall into this category of individually identifiable information. If this is the case, then Privacy Rule regulations like minimum necessary use and disclosure would apply to this data.

If information about social determinants of health that your organization has collected is considered protected health information under HIPAA, it may also fall under the HIPAA Security Rule if it is stored electronically. One example of a situation where the Security Rule would apply is when the protected information is incorporated into a patient’s file in an electronic health record (EHR). Should your organization collect data about social determinants of health, take care that any use or disclosure of protected health information is compliant with the Privacy and Security Rules.

You can make sure that your organization’s staff members are well equipped to keep all types of protected health information safe with HIPAA compliance training. Compliance Officers should also consider more in-depth HIPAA privacy and security training to help ensure that your organization’s privacy and security practices are compliant with state and federal regulations.


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