Any facility performing radiology procedures can participate in NRDR. A NRDR participation agreement between ACR and the facility must be signed before the facility can begin participation.
Because the data are being collected for the purpose of quality assurance and peer review, it is not required that you obtain IRB approval. The ACR has obtained a document from its IRB stating that the registry activities qualify as an exemption. Even though it is not required, individual institutions may choose to request an exemption from their IRB.
The participation agreement and BAA posted on the NRDR website must be executed without changes. We understand that you may wish to use your own BAA or modify the participation agreement. However, because of the number of facilities participating in NRDR, it is not practical for the ACR to provide legal review for different agreements to ensure compliance with HIPAA requirements. We are fully prepared to comply with the HIPAA requirements and believe the BAA on the NRDR website meets the requirements of the HIPAA privacy and security rules.
There is a one-time facility registration fee (not including NOPR). In addition, there is an annual fee based on the number of radiologists practicing at a facility and the number of registries in which a facility chooses to participate. Please see our registration process and fee schedule. (link to http://www.acr.org/clinical-resources/registries/registration-fees)
The ACR has access to all of the data entered into the registry, and will not disclose the Protected Health Information (PHI) in its possession to a third party except for the purpose of the ACR’s proper management and administration of the registry or to fulfill any legal responsibilities of the ACR, and only provided that the disclosures are required by law or that the ACR has received from the third party written assurances that the information will be (i) held confidentially and (ii) used or further disclosed only as required by law or for the purposes for which it was disclosed to the third party.
The ACR will use and disclose a limited data set for purposes of research or as otherwise permitted by the privacy standards or required by law. The ACR will not use a limited data set in such a way as to identify any individual and will not to contact any individual.
NRDR activities meet the definition of peer review. NRDR data collected and stored by the ACR are considered privileged and confidential peer review under Virginia Code Section 8.01-581.17 and not discoverable during legal proceedings unless so ordered by a court and then only upon a showing for good cause and for extraordinary circumstances. For information relative to your own state consult your state statutory authority.
Individual patient data submitted by a facility remain the exclusive property of the facility. However, such data once aggregated or data de-identified by ACR and any derivative works from de-identified data are the sole intellectual property of ACR.