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SESK: Stuff Everyone Should Know · sesk.info/hipaa-risk-factor-nature-of-phi

What is the first factor in a HIPAA breach risk assessment?

The nature and extent of the PHI, including the types of identifiers.

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  1. The nature and extent of the PHI involved ✔
  2. Whether the person apologized
  3. The cost of fixing the problem

Why: The first factor looks at what kind of PHI was involved, including the types of identifiers and how likely it is someone could be re-identified. More identifying or sensitive data means more risk.

Huh, didn't know that: The other three factors are who got the PHI, whether it was actually viewed, and how far the risk was reduced.

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Why was the first factor so nosy? It wanted to know exactly what got out.
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References

Answer: The nature and extent of the PHI involved. The first factor looks at what kind of PHI was involved, including the types of identifiers and how likely it is someone could be re-identified. More identifying or sensitive data means more risk.

  1. 45 CFR 164.402 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-D/section-164.402
    The nature and extent of the protected health information involved, including the types of identifiers and the likelihood of re-identification
    Checked 2026-10-10.

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