A covered entity removes all 18 Safe Harbor identifiers but retains free-text clinical notes. Is the resulting data de-identified under HIPAA?
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A
Yes, because all 18 required identifiers have been removed
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B
No, because free-text notes may contain incidental identifiers and the entity must verify no such information remains
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C
Yes, because free-text clinical notes are not PHI under HIPAA
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D
No, because de-identification always requires Expert Determination for datasets with clinical notes