Research on Health Information of Deceased Individuals
To access protected health information from individuals that are deceased, the investigator needs to indicate that:
- The information that is requested will be used solely for research purposes,
- The health information is necessary for the purpose of the research, and, if requested by the covered entity,
- The individuals whose health information is requested are, in fact, deceased.
A completed Decedent Form should be sent to the Research Privacy Advocate who will review the information submitted. Once the form is accepted, the investigator will receive a statement that can be given to the “covered entities” that are holding the needed protected health information.
An additional important point: Investigators who receive health information under Decedent Research and disclose any of that information to other investigators, institutions, or agencies, the investigator is responsible for keeping an accounting of disclosures. Under HIPAA, subjects can request a record of how often their health information was released to others in the previous six (6) year period. For health information obtained under Decedent Research, it is the investigator’s responsibility to provide this record of disclosures.
Minimum Necessary applies: When using or disclosing protected health information(PHI) or when requesting protected health information from another covered entitiy, a covered entity must make reasonable efforts to limit PHI to the minimum necessary to accomplish the intended purpose of the use, disclosure, or request.
To acquire health information from BMC for research purposes, present your approved request form to: Ellen Jamieson, Grants Administration, Gambro 2, 617-414-5646. She will direct you to the source of information you need.