Have you ever heard the phrase "proper preparation prevents poor performance?" That refrain echoed in my mind as I enjoyed three AER21 sessions on implementing OHRP and FDA regulations. In each session, the presenters dismantled any fear I had surrounding interaction with regulatory entities by offering rubber-meets-the-road application of regulatory requirements and resources to be properly prepared. Read more
Guest blogger Anthony Peña discusses SACHRP's work to expand upon the role of justice in the Belmont Report. SACHRP’s task is to identify where holes exist in the ethical framework and regulations, and comment on what is needed to respond. Underscored by current events, this is overdue work that needs to result in rapid updates to IRB discourse and operations. Read more
Some of the most significant changes in the revised Common Rule involve the provisions around informed consent, including the new requirement that informed consent begin with a “concise and focused presentation of key information that is most likely to assist a prospective subject or legally authorized representative in understanding the reasons why one might or might not want to participate in the research” [46.116(a)(5)(i)]—the “key information requirement,” for short. I welcome the key information requirement and think it has the potential to greatly improve informed consent, but it is bringing with it several complexities. Read more
Twenty years ago in 1999 I attended my first annual PRIM&R conference. I did so in the aftermath of then OPRR (now OHRP)’s shutdown of human subjects research that year of three federally funded institutions. At the time, there was a feeling of “there go I but for the grace of god;” if it could happen at these institutions, it could happen anywhere. Here we are in 2019, and there are once again scandals grabbing the research compliance headlines—this time involving scientific misconduct and questions of research integrity. And I cannot help but step back 20 years to that pivotal moment for IRBs and human subjects protections programs across the United States and ask again, what does a strong and robust Research Integrity program look like? Read more
Despite the partial government shutdown, it’s business as usual at the Office for Human Research Protections (OHRP), and the revised Common Rule will go into effect, as planned, less than a week from today, on January 21, 2019. Last week, OHRP released a new draft guidance titled, “The Revised Common Rule Compliance Dates and Transition Provision (45 CFR 46.101(l))." Though it’s coming about six months later than would have been ideal, this is the most useful guidance related to the revised Rule released to date. Read more
