 |  |  |  |  |  |  |  |  |  |
| ü | Institutional Review Board serves as the Privacy Board | |
| for Research. | |
|
| ü | IRBs are NOT serving as the Privacy Board for | |
| institutions outside the Covered Entity. | |
|
| ü | All institutions will need their own authorization language |
| and will be responsible for submission as an | |
| amendment. | |
|
| ü | Sponsors are generally NOT covered entities. The IRB | |
| will not be incorporating sponsor’s language in the | |
| authorization for patients. | |