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HHS OCR guidance on de-identification (2012): time-limited determinations (HHS OCR, Guidance Regarding Methods for De-identification of PHI, 26 November 2012, section 2.4)

Expert determinations often carry an expiry, because what counts as reasonably available outside data changes.

Dated 17 Oct 2026Source checked 17 Oct 2026Basis: primary text

In the source's own words
“The Privacy Rule does not explicitly require that an expiration date be attached to the determination that a data set, or the method that generated such a data set, is deidentified information. However, experts have recognized that technology, social conditions, and the availability of information changes over time. Consequently, certain de-identification practitioners use the approach of time-limited certifications.”
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