Elaine,

the Privacy Certificate has been in the standard forms of a DoJ grant
application kit for several years. We have submitted the form as part of a
grant application to the Drug-Free Communities Program. I did not think that
the requirements were anymore significant than what is asked of the
institution in regard to its assurance to protect human subjects.

Molly Daniel
Grants Specialist
Sarah Bush Lincoln Health Center
Mattoon, IL

-----Original Message-----
From: Elaine Young [mailto:xxxxxx@UMBC.EDU]
Sent: Friday, February 08, 2002 10:25 AM
To: xxxxxx@HRINET.ORG
Subject: [RESADM-L] Privacy in human subject research

Yesterday, I attended a COGR presentation on the proposed HIPAA regulations
and how they might affect human subject research in the future.  The rules
are still being written and are not to be effective until at least April
2003.

Today, I returned to my office to be presented with a rather onerous
"Privacy Certificate and Confidentiality Requirement" from the U.S.
Department of Justice that must accompany an application that one of our
researchers is proposing.  It states that "NIJ, as a matter of policy,
requires that Privacy Certificates be submitted as part of all
applications..."

The form requires the University to certify a number of items, including one
indicatiang that subcontractors have agreed in writing to comply with all
privacy procedures.

Has anyone had a similar experience?  Is NIJ jumping the gun?  I'm not sure
the institution can agree to ALL the certifications required.

Thanks

Elaine Young, Ph.D.
Assistant Vice Provost for Research
University of Maryland, Baltimore County
1000 Hilltop Circle, Admin 204
Baltimore, Maryland 21250

(410) 455-1336
(410) 455 1876
xxxxxx@umbc.edu

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