Data Request Policy
Purpose
To manage educational data requests in a manner that protects learner confidentiality and makes medical education data available for the improvement of our educational programs.
Overview
The UCSF School of Medicine’s Office of Medical Education (OME) provides a variety of services that include supporting a central repository of data available for use in program evaluation, educational research, and quality improvement. The Medical Education Data Governance Committee (herein known as “Committee’).
Principles
- The SOM is committed to ensuring the confidentiality of learner data and adhering to FERPA law.
- While resident and fellow learners are not protected by FERPA the School of Medicine respects the privacy of all learners according to FERPA guidelines.
- Medical education is committed to making educational data available to further innovation and improvement of our programs.
Definitions
For the purpose of educational data requests, data are classified into the following categories:
- Learner demographics: Includes descriptive data about learners (e.g., year in program, graduation date, age, UIM status, undergraduate institutions, etc.).
- Learner performance: Includes learner academic achievement prior to, during, and post training (e.g., admission data, internal and external examination scores, assessment of learner performance, learners’ summative portfolios, residency/fellowship director’s rating of intern performance).
- Program performance: Data on satisfaction with the School of Medicine curriculum, programs, and faculty/non-faculty teaching (e.g., program, course, and faculty evaluations, AAMC Graduation Questionnaire data, ACGME annual surveys) and data from surveys and research conducted by School of Medicine faculty and learners on SOM programs that are not a part of routine program evaluation.
Policy
- Data Requests
- All data requests must be made in writing to the Medical Education Data Governance Committee.
- All data requests must include the reason the data is needed, type of data needed, period of time data will be used, and how the data will be secured.
- Data Consultations
- The Committee may require the requesting party to consult with a Medical Education Data Consultant in order to verify the use of the data. Consultations include the following types of issues:
- Clarify intent of continuous improvement work
- Clarify intent of educational research
- Review data security and confidentiality requirements
- Confirm availability of data
- Clarify the type of data requested
- Consultations will be required for all requests considered “High Risk” by the committee. These may include data request for de-identified or easily identifiable data; and requests from individuals without prior experience handling sensitive data.
- The Committee may require the requesting party to consult with a Medical Education Data Consultant in order to verify the use of the data. Consultations include the following types of issues:
- Data Security
- Data must be stored in accordance with UCSF minimum security standards for electronic information at http://it.ucsf.edu/policies/ucsf-minimum-security-standards-electronic-information-resources(link is external).
- All requestors must demonstrate understanding of the Family Educational Rights and Privacy Act (FERPA).
- Access to Data
- The Committee will only provide access to data for which medical education is the primary owner. When 3rd party data is requested to be incorporated into a data set, the requestor is responsible for securing access to the specified data.
- The Committee retains the right to prioritize the fulfillment of data requests based on current priorities and the complexity of the request and to refuse any data requests.
- Current medical students and residents cannot be granted access to any peer learner demographic or performance data, regardless of its format.
- Access to program performance data and research conducted by the SOM on its curriculum and programs will require approval from the Director of Program Evaluation.
- Research Data Requests
- Approval by the UCSF Institutional Review Board (IRB) is required prior for the release of any data used for research. IRB approval for access to data does not override restrictions described in this policy.
- Any changes to the IRB protocol including changes to the research team membership must be shared promptly with the OME consultant assigned to the request.
- Any data sharing with investigators outside of UCSF must be approved by both the IRB and the OME consultant.
Procedures and Conditions
- Consultations
- Consultations with a Medical Education Data Consultant are recommended for all requests.
- Request Process
- All data requests must be made through the Medical Education Data Governance Committee using the online data request form at tiny.ucsf.edu/makeadatarequest
- Request Turnaround Time
- Assuming all conditions are met for the release of medical education data the Office of Medical Education will strive to deliver the data within 15 working days.
- If the dataset requires extensive work to de-identify, as with qualitative data about leaners, Committee will assess the feasibility to provide this de-identified data. Delays in fulfilling these requests may occur.
- Data Formats
- Data will be provided in de-identified formats with unique identifiers were appropriat.
- Data can be provided in multiple file formats include comma separated values (CSV), spreadsheet formats, SPSS, or text documents.
- Third Party Data
- If the requestor has data that must be incorporated into an education data set and then de-identified, there may be a delay for this service.
- The requestor is responsible for obtaining 3rd party data to be incorporated into medical education data sets.
- UCSF Institutional Review Board (IRB)
- Data requestors are responsible for obtaining necessary approvals from the UCSF Institutional Review Board (IRB) and providing proof of approval along with a copy of the IRB protocol as part of the Medical Education Data Request.
- Any changes to the IRB protocol including changes to the research team membership must be shared promptly with the OME consultant assigned to the request.
- Any data sharing with investigators outside of UCSF must be approved by both the IRB and the Committee.
- Delivery of Medical Education Data
- Data requestor and all parties who will have access to the medical education data must read and sign the Medical Education Data Use MOU.
Accountable Dean or Director: Associate Dean for Medical Education
Approval Date and Governing Body: January 9, 2018, CCEP