Central Research Privacy Board (CRPB)
On December 2, 2021 the Office of Research and Development (ORD) provided a status report to the nine VA sites relying on the Central Research Privacy Board (CRPB). The referenced email conveyed that a status report would be sent concerning ORD plans for the VA CRPB continuation or closure. The ORD cited CPRB continuation would be contingent on increased utilization of the CRPB. There have been no new submissions to the CRPB since December 2nd. As such, ORD will close the VA CRPB on May 31, 2022 in compliance with the Memorandum of Understanding (MOU), Section E, Termination Provisions. No new applications will be accepted by the CRPB effective February 23, 2022. Formal closure letters will be sent by ORD to each of the nine sites in May 2022.
The CRPB approved two waivers of written HIPAA authorization for two different studies at two different VA facilities (South Texas Veterans Health Care System (STVHCS) and North Florida South/Georgia Veterans Health System). The CRPB approved waivers of written HIPAA authorization for those two studies remain in effect and valid. The VA Principal Investigators must maintain the CRPB approval of the waivers of HIPAA authorization for their documentation. Future changes or modifications to these CRPB approved waivers of HIPAA authorization must be reviewed by an IRB or a Privacy Board who may request documentation of the CRPB waiver approval. The HIPAA Privacy Rule permits a covered entity to rely on documentation of waiver approval from any qualified Institutional Review Board (IRB) or Privacy Board in compliance with 164.512(i)(1)(i). The CRPB Administrator will work with the CRPB Liaisons at these two sites to identify the transition plan for their CRPB approved waivers of written HIPAA authorization to determine where the waivers will be assigned for future modifications or changes.
At the facility level, the Local Site Liaison (LSL) or designee for each facility must do the following no later than May 31, 2022:
- Remove the document “CRPB Submission Application” from the local library in VAIRRS.
- Update local Standard Operating Procedures (SOPs) to:
- Remove processes involving the use of the CRPB to include that the CPRB approved waivers of HIPAA authorization remain valid and the process for any future changes to the VA CRPB approved waivers.
- Identify the IRB or Privacy Board to be utilized for any future applications for waivers of written HIPAA authorization.
- Notify stakeholders of the planned CRPB closure and timeline.
Thank you for your support of the VA CRPB program.
VA CRPB Administrator/ORD Privacy Officer
VA CRPB Mailbox: firstname.lastname@example.org