Central Research Privacy Board (CRPB) Administration

Overview | Memorandum of Understanding | Submission Processes & Documents | Administration

Meeting Dates

The VA CRPB 2021 meetings are as follows:

Ad hoc meetings will be called as necessary.

Review Pathways & Timelines

The waiver requests can be approved by either expedited review or convened board review.  Applications that do not meet the criteria for expedited review will be reviewed by the convened CRPB.

It is anticipated that most applications for waivers of authorization will be reviewed by expedited procedures.   Expedited review should take place within 10 business days with a target of five (5) business days depending upon availability of VA CRPB reviewer.  Applications requiring review by the convened CRPB will be placed on the calendar for the next monthly meeting once the pre-review has been completed. 

Projects may request an accelerated timeline by contacting the CPRB Administrator for specific project details.  These are reviewed on a case-by-case basis and are the exception.

Members

The Privacy Rule requires that a Privacy Board consist of at least two members and that:

• The members must have varying backgrounds and appropriate professional competencies as necessary to review the effect of a research protocol on the individual’s privacy rights and related interests.
• At least one member of a Privacy Board must be an independent member who is (1) not affiliated with the covered entity that will use or disclose the Protected Health Information (PHI) in connection with the research project, (2) not affiliated with the entity conducting or sponsoring the research, and (3) not related to any person who is affiliated with the covered entity or the entities conducting or sponsoring the research. Reference:  512(i)(1)(i)B

• No Privacy Board member may participate in the review of any project if that person has a conflict of interest.
• A covered entity may rely on documentation of waiver or alteration approval from any qualified Privacy Board. NOTE:  VA DOES NOT PERMIT ALTERATIONS OF WAIVERS OF HIPAA AUTHORIZATION.

The VA CRPB membership is composed of three members including one non-affiliated member.  The CRPB membership may increase over time.  The VA CRPB Administrator will make every non-discriminatory effort to ensure that the membership of the VA CRPB has adequate gender, racial, cultural, and geographic representation and sensitivity to community attitudes to promote respect for the advice and counsel of the VA CRPB; as well as expertise in research involving vulnerable participants likely to participate in research, e.g., research with persons with impaired decision-making capability.  However, no appointment to the VA CRPB is made based solely on these criteria.

VA CRPB Membership Roster

CRPB Member Review Process

The CRPB Member conducts their review in the VAIRRS system.  If clarifications or corrections are needed, the CRPB member notifies the CRPB Support Staff who communicate directly with the investigator via VAIRRS to obtain the required corrections and/or clarifications. If the package is complete and the application for waiver of HIPAA authorization can be approved, the reviewer will document approval and the CRPB Support Staff will provide the outcome to the investigator via VAIRRS. If the package cannot be approved, the project is placed on the next meeting agenda for convened board review.  All outcomes are provided via VAIRRS.

Additional information is available in the CRPB Standard Operating Procedures (SOP)

Contact Information: 

Michelle Christiano
VA CRPB Administrator/ORD Privacy Officer
Phone: 706-399-7980
Email: Michelle.Christiano@va.gov

VA CRPB Mailbox: vacrpb@va.gov