We agree with Dr. Goldman that patients should be allowed to opt out of records-based research. When research use is anticipated, consent should be obtained before data are collected. We do not, however, concur with her proposal that decisions regarding research use of existing data be delegated to a medical records review board. The supposed merits of such a board (community representation, independence, and authority to make binding decisions) are all legally required characteristics of institutional review boards. If existing institutional review boards fail to meet this standard, the appropriate solution seems to be reform of institutional review boards rather than creation of a separate review process for records-based research. Records-based research deserves the same level of ethical review as traditional clinical research—not more or less.