Honest Broker Guidance

 

This page provides information about how to become a certified honest broker and how the investigator obtains permission to use a certified honest broker system.

  • An honest broker is a neutral third party, who is not part of the research team in any way. The honest broker cannot be one of the investigators, study coordinators, or statisticians on the study and cannot serve as a co-author on any publication.
     
  • Honest Broker Systems are set up for divisions, departments, clinics, labs etc. There are multiple honest broker systems throughout UPMC and Pitt.
     
  • An honest broker must have normal access (as part of their job responsibilities) to the data, records, specimens, etc that they will be obtaining and de-identifying. An honest broker is an individual, or system, acting on behalf of the researcher to collect and provide de-identified information/samples to the research team. In most cases, the honest broker systems are set up to obtain and provide clinical/medical records, data and specimens.

How to become a certified Honest Broker:

  • The Honest Broker application must be completed, signed, and submitted to the IRB for both the IRB and UPMC Privacy Officer to review and approve. Refer below to the application form and UPMC policy.
     
  • One individual must take responsibility for the honest broker system. More than one individual may be listed as honest brokers on the system. Once approved, the system can be modified to add and remove individuals/brokers.
     
  • All Honest Brokers are required to complete CITI Research Ethics and HIPAA training before accessing the data. Refer to the required training as noted below.
     
  • Any listed honest broker(on an honest broker system for UPMC records/data) who is not a UPMC Employee must document how they are a part of the UPMC workforce and have a UPMC employee as a supervisor.

How to request permission to use a certified Honest Broker:

  • The investigator wishing to use an honest broker system should contact the honest broker system and request honest broker services for their research study.  The investigator and honest broker should work together to determine if the honest broker system is able to provide the data/samples that the investigator would like.
  • The Honest broker needs to agree to provide services and sign the honest broker assurance form [Word]. The investigator then submits to the IRB and provides the signed honest broker assurance form in their PittPRO submission to the IRB.  An honest broker must be an approved, listed broker on a certified honest broker system before that system can be referenced and the broker named. The IRB submission must be approved before the honest broker can begin providing services to the investigator.

If you have any questions email askirb@pitt.edu.

Links to the documents for Honest Broker Certification Process:

UPMC Policy on PHI for Research

Use and Disclosure of Private Health Information (PHI) for Research Purposes Pursuant to the HIPAA Privacy Rules: UPMC Policy HSEC1611 (formerly HS-RS0001) [PDF]

Required Research Ethics and HIPAA Training

Three CITI (Collaborative Institutional Training Institute) courses must be completed before an individual can serve as an Honest Broker.  Follow the instructions displayed on the Pitt CITI portal at www.citi.pitt.edu. The IRB requires the following modules:

  1. Responsible Conduct of Research
     
  2. Human Subjects Research (Biomedical Course)
     
  3. Privacy & Information Security   

v. 4/21/2021