The considerations that was relevant to the IRB's determination that this activity does not constitute research with human subjects is "The researcher will not be interacting/intervening with subjects and the data has no identifiers".
Generally, any human subjects inquire about that is directed by VDH, by outside examiners in a joint effort with VDH, or by outside agents utilizing VDH information, is liable to survey and endorsement by the VDH Institutional Review Board. However, not all examinations require IRB review.