Limited Data Set
lUsed or disclosed for research, public health, or health care operations purposes only
lRequires the removal of fewer identifiers – “facial identifiers”
lMay include
–Dates related to admission, discharge, birth, death
–City, state, five digit zip code
lData use agreement signed by recipient
Explain difference in limited and de-identified (What can you get in the limited data set)

Data use agreement = “super confidentiality agreement” – specifies that information will be used only for stated purpose, implement appropriate safeguards, not to re-identify data or contact the individual (s)

Apply “minimum necessary standard”

Generally, the disclosing CE is not liable for breaches of the data agreement – but must take reasonable steps to cure the breach

HHS has no jurisdiction to enforce data use agreements unless the recipient is a CE