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National Institutes of Health HIPAA Privacy Rule - Information for Researchers
This website is currently in the process of being updated. For guidance on the HIPAA Privacy Rule in research, please see: https://www.hhs.gov/hipaa/for-professionals/special-topics/research/index.html
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Slide Presentation on the Privacy Rule and Research


Slide 38:
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Accounting for Disclosures

  • "Disclosure means the release, transfer, provision of access to, or divulging in any other manner of information outside the entity holding the information."
  • A covered entity is generally required to account for PHI research disclosures made after the compliance date without Authorization.
  • Including for research disclosures of PHI for:
    • Reviews preparatory to research.
    • Research using decedents’ PHI.
    • Research under a waiver of Authorization (including waivers that meet the transition provision requirements).
    • Disclosures for public health activities.
    • Most disclosures mandated by law.

Department of Health and Human Services National Institutes of Health USAGov The HIPAA Privacy Rule