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Are HIPAA Research Authorizations or an IRB/Privacy Board Waiver required for databases I maintain containing PHI that are for future research?

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Are HIPAA Research Authorizations or an IRB/Privacy Board Waiver required for databases I maintain containing PHI that are for future research?

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Databases where PHI is placed, processed and stored that are resources for future research are Research for HIPAA purposes and require HIPAA Research Authorization or Waiver. Since the definition of Research is the same under HIPAA and the Common Rule these databases also require IRB approval.

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