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| • | Patients have the right to request an
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| accounting of disclosures of their PHI for past
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| six years.
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|
| • | Applies to disclosure of PHI pursuant to a
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| waiver of authorization, disclosures required
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| by law, and for public health purposes.
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|
| • | Does not apply to disclosures pursuant to an
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| authorization or to limited data set.
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|
| • | The Privacy Office, not the IRB, will maintain
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| a centralized database to track disclosures.
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| This tracking requirement is the responsibility
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| of the PI in conjunction with the Privacy
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| Office.
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