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Data governance policies and procedures to inform data-related activities were developed by the NACHC Clinical Affairs team in partnership with other NACHC teams and external partners. These policies and procedures can be applied to any activities where data is received, collected, or generated, referred to as 'informatics work' hereinafter.

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NACHC receives UDS data from HRSA that includes health-center level information on a variety of topics including services, staff, capacity, and financial data. The UDS data that NACHC receives includes some data that is available publicly and some sensitive data that only NACHC receives. holds. UDS data does not contain PHI but is sensitive and requires physical, technical, and administrative safeguards.

Sharing UDS data with NACHC occurs under a cooperative agreement with HRSA which is overseen by Margaret Davis (UDS Program Director). The parameters of UDS data sharing and use are defined in two HRSA agreements (Authorization letter, NACHC DUA). Included in the LOA these documents are explicit directions about how findings from the UDS data should be communicated in a way that protects the identity of health centers. 

UDS data does not contain PHI but is sensitive and requires physical, technical, and administrative safeguards. The UDS data is stored securely in the Amazon cloud and only individuals who have signed a UDS specific DUA are permitted to access and use the UDS data. Once a DUA has been executed with an individual and access granted to the UDS datasets, all uses of UDS data must be approved by the UDS Program Director. 

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Section 4: Other Governance Topics 

Requests

NACHC receives many requests for data that has already been shared with them for an existing project or a request for data related to a new project. Additionally, NACHC receives requests for information partnership meaning a desire from one organization to partner and share data with a health center through support from NACHC.  

Requests for data or information partnerships are evaluated by the GC which meets monthly. Requests can be submitted here. Requests ​must be well defined meaning that they include a detailed description of what data is desired, how the data will be used, the type of use (e.g., research, surveillance, quality improvement or other) and how the request aligns with the NACHC vision and benefits health centers. Incomplete requests cannot be evaluated by the and will be returned to the requester. Requesters will be notified ​of an approval or denial within one week of the data governance council meeting. ​

For requests of data that NACHC has received for other projects, NACHC is not a data owner but a steward of data from other contributing organizations​. Thus ​a request ​approval from ​NACHC's data governance council is the first in a series of required approvals. Approved request will be shared with the originating data contributor ​and if approved by the data contributor, a data use agreement to define the parameters of the data exchange must be executed before any data can be shared. 
NACHC is facilitator of information partnerships​ rather than a broker of data​. NACHC strongly prefers building an information partnership with the goal of collaboratively developing a data sharing project that is beneficial to all parties involved.  

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