IRB member here. This is absolutely human subjects research and requires IRB approval.pic.twitter.com/7Izw841Zi0
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But what makes something research or QI isn't whether you want to publish it or not. It's whether you decide there is scientific equipoise between the treatment options or not. If you believe there is, its always research, and if you don't, it's QI.
This guy clearly believes that equipoise does not exist. He believes the evidence supports HCQ administration in his patients. That (erroneous) belief means that he is practicing medicine, not doing n human experiment; and makes data collection QI, not clinical research
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