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Research Streamlining Initiative

The DHA Privacy and Civil Liberties Office (PCLO) introduced the Research Streamlining Initiative to streamline the process of requesting data managed by the DHA Chief Information Officer (DHA data) for research. Under the Research Streamlining Initiative, DOD Institutional Review Boards (IRBs) will make data determinations and conduct HIPAA Privacy Rule reviews of research that involve the use of DHA data. In many cases, the reviews can be done simultaneously with the Common Rule review, but even exempt studies will require a data determination and HIPAA Privacy Rule review if the researcher intends to access, use, or receive DHA data.

DHA IRB HIPAA Compliance Review Findings on Data Requests (IRB Findings Document)

Researchers requesting DHA data must identify the type and source of data requested for the research in Section A of the IRB Findings Document. The reviewer will document the data determination and, if the data request is for PHI, the type of HIPAA documentation required for the research in Section B. The reviewer should provide the completed document to the researcher for submission to the PCLO along with a data sharing agreement application, as necessary.

Research Repository Template

Researchers who request DHA data for their research must complete the Research Repository Template. The RRT asks researchers whether they intend to put data into a repository, and if yes, what data and under what governance terms. A repository is defined as:

  1. the physical or virtual collection and storage of data or derivative data for future use and disclosure, or
  2. any collection of data or derivative data without an explicit plan to destroy the data or derivative data when the purpose for which the data or derivative data was collected ends.

Examples of repositories include:

  • Copies of a data set
  • A key code based on identifiable information
  • Transcribed or digitized verbal data
  • Data collections of any size created by individuals in a program or application, or in a document, such as an Excel spreadsheet

Resources/References

  • HIPAA Privacy Rule, 45 CFR Parts 160 and 164.
  • DOD Manual 6025.18, Implementation of the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule in DOD Health Care Programs, March 13, 2019

Frequently Asked Questions

Last Updated: March 25, 2024
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