Use and Disclosure of PHI in Research

PHI may be used for research if it is:

  • Completely "de-identified"

    • requires the removal of the 18 identifiers listed in the HCS Release of PHI for Research Purposes policy.

  • A "limited data set" which requires

    • specific direct identifiers to be removed and

    • compliance with specified terms of a data use agreement.

  • Reviewed solely in preparation for research which requires that

    • no PHI will be removed from records

    • no PHI will be recorded

    • no patients will be contacted using PHI obtained from records.

  • Research on decedents which

    • requires the researcher to present a written statement that access is solely for research of decedents and that decedents' PHI is necessary for study and

    • if requested, will provide documentation of the death of the individual.