Accounting of Disclosures Requirements
UNC HCS staff who disclose PHI for research purposes MUST maintain an accounting of disclosures under the following circumstances:
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using an IRB Waiver of Authorization with fewer than 50 patients involved by entering each accounting of disclosures into the DisclosureTrac database,
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reviews preparatory to research only, or
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reviews of decedents' information
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reviews of 50 or more patients, MIM accounts for the disclosures.
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