For research, we state in our Privacy Notice that we may use or disclose
protected health information without pt consent or authorization if our
research privacy board (IRB) approves a waiver of authorization for
disclosure. 
So, do we then need to account for those disclosures in the accounting of
disclosures?  
Our team has 2 opinions:
1) YES, because it is a disclosure made without authorization, and not for
TPO.
2) No, because the IRB approved the waiver of needing an authorization.

Thanks for your help!!

Janelle J. Wesloh
Hazelden Foundation



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