University of Rochester Medical Center

Research Use of Electronic Patient Information:
URMC Policy Statement

1. Scope of the
Policy

This policy covers the use of electronic patient information for research purposes. The term research applies to "systematic exploration designed to develop or contribute to generalized knowledge" [University of Rochester Research Subjects Review Board (RSRB). Investigator's Handbook, 1/29/98]. It does not cover uses of patient information for health care administration or internal quality assurance studies within a single department or unit: existing access, security and confidentiality policies of the entities of Strong Memorial Hospital (SMH) and the University of Rochester cover those uses.
2. Resource Covered This policy covers patient information stored in digital form on equipment, tapes, discs or diskettes that belong to any division of Strong Memorial Hospital or of the University of Rochester Medical Center. This includes central clinical information systems, billing systems, laboratory systems and other systems that store information about patients. This policy covers private departmental or practice-based patient databases if access will be made to those databases for research purposes.
3. Statement of the
Policy
  1. Any research project that employs patient information taken from the electronic medical records of the Medical Center must be reviewed by the RSRB. The investigator may apply to the RSRB for a study exemption or an expedited review, as outlined in the RSRB handbook. Either case requires the investigator to submit a study proposal that includes a rationale for the study, describes the data requested, and outlines measures that will be taken with respect to the confidentiality and security of the research data. The protocol should also indicate whether patient consent will be obtained. If the researcher does not intend to obtain patient consent, sufficient justification should be provided to the RSRB so the RSRB can determine whether it will waive consent in accordance with applicable regulations.

  2. Investigators who require research data sets that contain identifying information must provide for stricter access controls and confidentiality protections than those who employ data sets stripped of identifiers that support discovery of the individual patient. Investigators must provide a compelling rationale for requesting identifying rather than anonymous data. Studies that employ identifying data will receive a more rigorous review by the RSRB. No publication can contain patient-identifying information without patient consent. Investigators whose studies will employ anonymous data sets must still apply to the RSRB for review as exempt studies.

  3. Upon approval by the RSRB, the investigator must arrange with the SMH Office of Clinical Practice Evaluation (OCPE) to extract the requested data. OCPE will perform a "need-to-know" assessment, design an appropriate extraction algorithm, and deliver requested data to the investigator in an agreed-upon format on a mutually acceptable timetable. The algorithm for making records anonymous will remove the name, social security number, parent's name, street address, provider name and other identifying information as appropriate.

  4. The investigator will sign a receipt for the data received from OCPE, acknowledging responsibility for proper management and protection of the data. OCPE will retain records about patient information that has been released for research purposes, in accordance with state and federal guidelines.

  5. The security and integrity of extracted data are the responsibility of the investigator. Patient data taken from the electronic clinical records of Strong Memorial Hospital belong to the institution. When data are no longer needed by the investigator, or when an investigator leaves, appropriate arrangements must be made regarding the disposal of the research data set.

  6. Records containing HIV-related information or information about alcohol/drug abuse treatment cannot be extracted for research purposes without additional authorizations. The investigator's research proposal to the RSRB should include assurances that appropriate authorizations have been arranged.
4. Legal Restrictions There are state and national laws relating to confidentiality and security of patient information, particularly information relating to AIDS and alcohol or drug use; these are addressed in existing medical records and security policies at SMH. Federal regulations covering research which involves human subjects are addressed through RSRB procedures. Institutional policies concerning ownership of research data also apply.
5. Implementation This policy applies to all entities of the University of Rochester Medical Center. The policy is communicated to researchers throughout the University of Rochester Medical Center and Strong Health system via the Medical Center's web site, with a comment capability attached. Additional supporting information is provided on Rationale and Context for the URMC policy. Scenarios and test questions have been developed to assist investigators in applying the policy.
6. Update Cycle The policy and dissemination method will be reviewed after a 6-month period and revised as necessary. Substantive revisions of the policy must be approved by the Medical Center Executive Committee (MCEC). The policy will be reviewed and updated at any time without MCEC approval (1) on the advice of legal counsel or (2) as needed due to changes in federal, state or institutional policy.
7. Implementation
Responsibility
The responsibility for data extraction and maintenance of audit records rests with the SMH Office of Clinical Practice Evaluation. OCPE will arrange for the technical assistance from SMH's Information Systems Division or other authorized departmental staff as appropriate.
8. Approval Approved by Medical Center Executive Committee on April 7, 1998; last update 7/17/98.

Appendix 1 Appendix 1: Relevant UR Policy relating to Human Subjects Research
Scenarios & Test Questions Scenarios and Test Questions
Appendix 2 Appendix 2: Rationale and Context for the URMC Policy

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Jul98; jd