MLCHE Policies & Annual Reports
Our research occasionally includes access to and use of protected health information (PHI). This data is protected under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). We have a strong commitment to protecting the privacy of all individuals covered by our research. All faculty and staff participating in research requiring the use of PHI must undergo HHS-developed training. Specifically, they must complete the following modules found on the HHS HIPAA training site.
- Protected Health Information, Uses and Disclosures, and Minimum Necessary
- Administrative Requirements
Data Storage Policy
All raw data sets containing PHI are stored in password-protected files unless currently under analysis. In no circumstance will PHI from the raw data set be included in the analysis file unless absolutely necessary for work to proceed.
Analysis files must be stored on University-owned computers requiring user-authentication before access and stored in folders only accessible to a single user (i.e., not shared on the machine). When research concludes, all analysis files will be combined into a single archive and password protected. Raw data will be destroyed after a reasonable period, depending on the need for access following questions by peer-reviewers of our research.
Data Use Policy
Data sets containing PHI are used only following University of Memphis Institutional Review Board approval or granting of a waiver. The acquisition and use of each HIPAA-protected data set is restricted to a single study unless additional IRB approvals/waivers are explicitly applied for and granted.
In compliance with HIPAA’s “minimum necessary” requirement, researchers will only use that PHI which is necessary for successful completion of the project. This determination will be made by the Director of the Methodist-Le Bonheur Center for Healthcare Economics at the researcher level, since not all researchers for a given study will need access to PHI to complete their duties. In order to gain access to PHI data, researchers (including graduate assistants) must first complete the University of Memphis’s “Education in Responsible Conduct of Research” training, or an appropriate substitute as determined by the Director.
A log will be kept of all research staff who access PHI, the type of PHI accessed, the IRB-approved study it relates to, and the purpose for access. These records can be reviewed at any time by data suppliers and appropriate regulators.
We do not report rates based on unreliable numbers. An estimate may be unreliable because (1) it has a denominator of 30 or less or (2) because it has a large relative standard error. We consider a standard error to be large if it exceeds 30% of the point estimate. In the first case, we will report the raw numbers for the numerator and denominator and users are cautioned to interpret these values with caution. In the second case, we will only publish pooled estimates.