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Open Access Publications from the University of California

UC Comments on California Department of Justice Notice of Modification to Text of Proposed Regulations regarding the Controlled Substance Utilization Review and Evaluation System (CURES) at Title 11, Division 1, Chapter 8.5 Issued on January 16, 2020

Abstract

This comment letter responds to the California Department of Justice’s proposed modifications to regulations governing researcher access to the Controlled Substance Utilization Review and Evaluation System (CURES). UC argues that requiring individual patient consent would effectively prevent population-level research using identified CURES data and recommends restoring provisions that permit access under existing privacy, security, and human-subject protections, including the option to restrict access to DOJ’s secure laboratory.