Yes you do have to account for those research disclosures.
Molly Shek, MS, RHIA
-----Original Message-----
From: Wesloh, Janelle [mailto:[EMAIL PROTECTED]
Sent: Wednesday, March 26, 2003 11:05 AM
To: WEDI SNIP Privacy Workgroup List
Subject: Accounting of Disclosures, research with approval of IRB
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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