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Under the preparatory to research provision, no PHI may leave the covered entity. Under the preparatory to research provision, covered entities may use and disclose PHI to researchers to aid in study recruitment. They may allow a researcher to identify, but not contact, potential study participants.
The IRB must review combined consent/authorization documents to ensure that the language meets the requirements of HIPAA. While the IRB does not approve stand-alone HIPAA documents, it does check them for accuracy and that they contain the required elements.
Under the Privacy Rule, covered entities are permitted to use and disclose protected health information for research with individual authorization, or without individual authorization under limited circumstances set forth in the Privacy Rule. Research Use/Disclosure Without Authorization.
Research Health Information (RHI) is defined as data used in research that would be personally identifiable but not considered PHI and is therefore not subject to the HIPAA Privacy and security Rules.
The Privacy Rule permits a covered entity reasonably to rely on a Privacy Boards or an IRBs documentation granting a waiver or alteration of the Authorization requirement so long as the documentation is proper.
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The Privacy Rule applies to covered entities,9 which are individuals or organizations that electronically transmit health information in the course of normal health care practices. Covered entities include health care providers, health plans, and health care clearinghouses.

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