Fred Hutch HIPAA authorizations were updated effective June 7, 2015. This page provides instructions for using the new HIPAA Authorization forms.
To learn more about this topic, view the Fred Hutch Privacy and Confidentiality Policy.
Actions needed include the following:
If the HIPAA authorization form currently used for a research project uses the Fred Hutch Protocol Specific Authorization, submit a Research Modification Form to update the Protocol Specific HIPAA Authorization to the new version.
To determine whether your research study will require HIPAA authorization from study participants, first determine the type of protected health information, or PHI, which will be accessed or used.
The sections below cover the following:
By definition, a limited data set may include categories of PHI such as ZIP codes, geocodes, date of birth, data of admission/discharge/service and other unique codes.
Research studies that will only access a limited data set are not required to obtain a HIPAA authorization from study participants. However, the covered entity from the location where the limited data set will be accessed may require a HIPAA-compliant Data Use Agreement.
When using or accessing more than a limited data set, separate HIPAA Authorization forms are required depending on the type of activity or the location where the activity will take place.
Who is conducting the activity or the location of the activity | Complete and submit this form |
---|---|
1. Fred Hutch Investigators, non-transplant-related research: most locations | Fred Hutch Protocol Specific Authorization Form |
2. Fred Hutch Investigators conducting transplant-related research at FHCC or UW | Fred Hutch Transplant Program General HIPAA Authorization Form This form is used for transplant program studies only. It can be found on Clinical FYI / CORE |
3. UW Consortium investigator | UW HIPAA forms |
4. All activities taking place at Seattle Children's | Seattle Children's HIPAA Form |
Fred Hutch Investigators requesting a complete waiver of HIPAA authorization are to use the HIPAA Supplement and Waiver of Authorization Form.
Those accessing medical records solely for purposes of ascertaining potential subjects may request a partial waiver for recruitment purposes using the HIPAA Supplement and Waiver of Authorization Form.
Note: The Fred Hutch IRB does not "approve" HIPAA authorization forms. Responsibility for the legal acceptability of HIPAA authorization rests with the covered entity from which researchers will obtain the PHI. Local requirements will vary. To determine what is needed, check with the institution where the PHI resides.
Situations that require the use of HIPAA forms from outside Fred Hutch include the following:
If a covered entity requires the use of their own HIPAA forms, their forms will be used in place of the Fred Hutch HIPAA forms. In these situations, provide the following:
These forms will not receive Fred Hutch IRB approval dates.
Contact the Fred Hutch Office General Counsel before using this method. If advised to do so, provide the following:
The consent form will be reviewed and approved by the IRB.
NOTE: This method is not recommended, but it may be used in some situations.
Submit the following:
NOTE: These updated forms will not receive IRB approval dates.
Submit the following:
These modifications will be reviewed and approved by the IRB.
Submit the following:
These changes will be reviewed and approved by the IRB.