Accounting of Disclosures Requirements

UNC HCS staff who disclose PHI for research purposes MUST maintain an accounting of disclosures under the following circumstances:

  • using an IRB Waiver of Authorization with fewer than 50 patients involved by entering each accounting of disclosures into the DisclosureTrac database,

  • reviews preparatory to research only, or

  • reviews of decedents' information

  • reviews of 50 or more patients, MIM accounts for the disclosures.