Obtaining Access to Underlying Data for Medical Studies

Can/should lawyers be able to use subpoena power to access underlying data from medical research studies at issue in litigation?  The subject is reviewed under the Illinois Medical Studies Act  in an August 2, 2014 post by Nathan Schactman at his Tortini blog. As he notes, the case law leans towards requiring production, and one can say that current trends towards open access data suggest that data should be subject to production.