it's not about the individual record, it's about correlating records. if you can sequence everything in time it gets a lot easier to deanonymize data
In most cases this forms a compliance matter rather than an open attack vector, but it nevertheless remains that one has to answer any question along the lines "did you minimise the privacy surface?" in the negative, or at least, with a caveat.
Whether creation date is PHI…I could see the argument being yes, since it correlates to medical information (when someone sought treatment, which could be when symptoms present.)
The only thing that seems to be protected is ‘reason for appointment’, and not all systems do that.
Everyone signs paperwork to authorize this when they first engage with the medical providers!