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SESK: Stuff Everyone Should Know · sesk.info/hipaa-deid-age-90

In Safe Harbor de-identified data, how must a 93-year-old patient's age appear?

Grouped as 90 or older.

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  1. As exactly 93
  2. Grouped as 90 or older ✔
  3. Removed, but birth year kept

Why: Ages over 89 are identifiers because so few people are that old. They may be lumped into one category, age 90 or older, and even the birth year must go.

Huh, didn't know that: The rule treats ages 89 and under as safe to keep in de-identified data.

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What's the best thing about being 99? Hardly any peer pressure.
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References

Answer: Grouped as 90 or older. Ages over 89 are identifiers because so few people are that old. They may be lumped into one category, age 90 or older, and even the birth year must go.

  1. 45 CFR 164.514 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.514
    all ages over 89 and all elements of dates (including year) indicative of such age
    Checked 2026-10-10.
  2. 45 CFR 164.514 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.514
    may be aggregated into a single category of age 90 or older
    Checked 2026-10-10.

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