Hi Janelle, In regards to your questions about the accounting of disclosures, waivers of authorization and research, the answer is YES. No accounting of disclosures for the following: - Limited data set disclosure for research - Deidentified information for research - Research conducted pursuant to an Authorization An accounting of disclosures is required for: - Research conducted pursuant to a Waiver - Research involving PHI of decedents - Use of PHI preparatory to research Colleen Rooney, MHSA, CMCE Senior Consultant, HIPAA Practice CTG HealthCare Solutions
-----Original Message----- From: Wesloh, Janelle [mailto:[EMAIL PROTECTED] Sent: Wed 3/26/2003 12:05 PM To: WEDI SNIP Privacy Workgroup List Cc: 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 --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org ya!#H>Xǫ0'!ʋ.n+j zyyجr,{ab azzޱ,az)݊ijbr*ZhgyǬ*ަz{m{ ([EMAIL PROTECTED])zhܨzb{h24Ȳ˞6iyarHzǥlz.起_(gr&zا ݊.Ȩ"~'/zwhv-ݱǬNj[(jاyhmy֬i+g讗ڕجj zg+zk*'jW(kƭڵ)b.\ &v0yة+s&j!j)Zb(:.˛mkab(ay+mԞ˛mfi.n+yب +iZGj)mW v*k^<9b0yب ʋym칻 &nrܺޞצj)ZuȬm欶u.n+azX^jǮay+mԞ˛mfi.n+yب
