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.
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