I plan to use de-identified information in my research. Do I still need to submit an eIRB application?
The answer depends upon whether the data already exist in de-identified form. If your research involves only the analysis of pre-existing data that have been fully de-identified to the HIPAA standard, you do not need to submit an application in eIRB, because such research involves neither PHI nor an identifiable human subject. If, however, you wish to extract de-identified data from medical records or other identifiable sources, for use in your research or to create a de-identified database for future research, you must submit an Exempt Research Application and an Application for Waiver of HIPAA Privacy Authorization in eIRB.
