The HIPAA regulations have language specific to research involving only deceased individuals. Studies involving information from only deceased individuals must have a HIPAA certification on file regarding the use of the deceased individuals’ protected health information. A new CLARA form, called the “HIPAA Certification for Research Involving Only Deceased Individuals,” allows this certification to be submitted electronically. The form asks completers to verify that they seek the decedents’ PHI solely for research; that they will provide UAMS with documentations of the decedents’ deaths, if requested; and the PHI is necessary for the research.
This form can be accessed via “create a new submission” link in CLARA. Once signed and submitted, the IRB office will acknowledge it, much like the IRB office acknowledges receipt of “Review Preparatory to Research” HIPAA-related forms.
Please note that this form applies to research involving only decedents. If your target population may involve both living and deceased individuals, e.g. it’s a chart review, please complete a regular new submission in CLARA.