UC Comment Letters

This comment letter responds to the California Department of Justice’s proposed modifications to regulations governing access to identified individual-level data in the Controlled Substance Utilization Review and Evaluation System (CURES). UC recommends that researchers accessing CURES data through established research-review procedures not be required to use DOJ’s proposed consent form, arguing that the form is inconsistent with standard human-subject research practices, creates unnecessary participant burdens, and may increase privacy risks by requiring excessive identifying information.