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Code of Conduct

MR Subjects' Rights by MR Subjects Type

X. Simulated Consultations

19.4

Simulated consultations between a patient and a healthcare professional (known or unknown to each other) are a legitimate research approach however they should be conducted with great care because they may lead to misunderstanding with the patient. It is important that participating patients are fully aware of the nature of the research and that the consultation is a simulation and not a substitute for a normal consultation.


19.5

 

There is no restriction upon the use of protected health information if it has been de-identified.  There are two ways to de-identify data.  The first method is to remove all  identifiers such as::

 

 

(A)  Names

(B)  All geographic data , including street address, city, county,  part or all of the postal code

(C)  Elements of dates (except year) directly related to an individual, including birth date, admission date, discharge date, date of death; and identifying ages e.g. those over 89;

(D)  Telephone numbers;

(E)  Fax numbers;

(F)  Electronic mail addresses;

(G)  Social security numbers;

(H)  Medical record numbers;

(I)   Health plan numbers;

(J)   Account numbers;

(K)  Certificate/license numbers;

(L)   Vehicle identifiers and serial numbers, including license plate numbers;

(M)  Device identifiers and serial numbers;

(N)  Web Universal Resource Locators (URLs);

(O)  Internet Protocol (IP) address numbers;

(P)  Biometric identifiers, including finger and voice prints;

(Q)  Full face photographic images and any comparable images; and

(R)  Any other unique identifying number, characteristic, or code

 

 

The second option is to have a qualified statistician determine that the risk is very small that the information could be used to identify the individual.

https://www.hhs.gov/hipaa/for-professionals/privacy/laws-regulations/

 


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