No. The HIPAA Privacy Rule, 45 C.F.R section 164.512 (i)(1)(i)(B) and Department of Defense Manual 6025.18 paragraph 4.4.i.(1)(a)2, set forth specific criteria to establish a HIPAA Privacy Board. The HIPAA Privacy Rule requires that a HIPAA Privacy Board have at least two members of varying backgrounds and expertise to review the effect of a research protocol on individual privacy rights and related interests. Further, at least one member must be unaffiliated with the covered entity and the entity conducting or sponsoring the research, and unrelated to any person who is affiliated with such entities. Additionally, no HIPAA Privacy Board member may review any project if that person has a conflict of interest.