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 HRP Associates, Inc. Newsletter Training and Consulting in Human Research Protections IRB Management Solutions
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Welcome to the second issue of our electronic newsletter. We hope you find this newsletter informative and useful. Please send us feedback and suggestions for what you would like to see in this newsletter. Email us at hrpp.info@gmail.com.
Sincerely,
Jeffrey Cohen Cheryl Savini
HRP Associates, Inc.
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Accountability: Preserving the Public Trust
Human
research protection programs primarily focus on ethics and regulatory
compliance. However, those are not the only functions of HRPPs; they also serve
to preserve public trust in research. We must remember that there is no right
to conduct research. Research, especially research involving human subjects, is
a privilege granted to the research community by the public. That privilege is
granted based on the trust that the research will be conducted according to
appropriate ethical principles and regulations. Anything that erodes that trust
can result in that privilege being restricted or withdrawn. When the public has
serious concerns about research it puts pressure on Congress and federal
agencies to further regulate research, which is how we got to the current
regulatory situation in this country.
So,
how do HRPPs serve to maintain the public trust in human research? Through
accountability; that is, being able to demonstrate that organizations and
investigators are conducting research according to ethical and regulatory
standards. It is not good enough just to do the right thing; we must be able to
demonstrate to others that we are doing the right thing!
Accountability
begins with investigators and institutions maintaining appropriate
documentation. If you examine the federal regulations you will see that,
although most of the regulations address the implementation of ethical
principles (informed consent, risk/benefit, etc.), the rest is about
documentation (consent forms, minutes etc.). This is because the regulations,
when they were drafted, were designed to restore public trust in human research.
The
next level of accountability involves oversight by government agencies. The
federal human subject regulations were first imposed back in the 70s because
the public trust in research had eroded. When public trust eroded again in the
mid-90s, federal oversight increased. By issuing regulations and overseeing the
compliance with those regulations, the government assures the public that human
research is being conducted with appropriate safeguards for the rights and
welfare of subjects.
Finally,
accountability involves accreditation. Organizations must be able to
demonstrate that they have an HRPP that meets appropriate standards. An
independent accrediting body, currently AAHRPP, develops HRPP standards and
assesses organizations as to how well their HRPP meets those standards.
Accreditation involves more than just compliance with regulations and
appropriate documentation; it also involves the evaluation of the effectiveness
of the HRPP through a site visit and interviews. As more organizations become accredited, the
public can trust that research at those institutions at least meets AAHRPP
standards.
Many
people in our field see accountability as just so much bureaucratic nonsense
and fail to appreciate the important role it plays in ensuring that important
research can continue to be done. Maintaining the public's trust in research is
as important as the ethical conduct of research for, without that trust, the
conduct of research will be even more difficult.
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Question: Should IRB meeting minutes include the name of
board members who either approve/disapprove/or abstain from voting?
Answer: There is no regulatory requirement to record the names of those voting and it is generally not a good idea. Decisions by the IRB should be group decisions and individual votes should be confidential. Linking names with votes could stifle individuals voting as they see fit and defeat the purpose of group decision-making. There are some who say that abstentions should be recorded with the name of the person abstaining and the reason for the abstention. Unless the person wishes to go on record with regard to his or her abstention, then we feel that this should also not be identified.
The only time that names should be recorded in the minutes would be when a) individuals have left the meeting (to ensure that a quorum is maintain - the names would indicate whether the necessary representation has been maintained as well as the necessary number), and b) when a member recuses himself or herself for conflict of interest (so that any COI can be identified).
----------------------------------- If you submit questions to hrpa.questions@gmail.com, we will post answers here to the most interesting questions. Don't worry, we'll try and answer directly as many as we can
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OHRP ANPRM
ORHP has issued an Advanced Notice of Proposed Rule Making to enable OHRP to hold institutional review boards (IRB) and the institutions or organizations operating the IRBs directly accountable for meeting certain regulatory requirements of the DHHS regulations for the protection of human subjects. (http://edocket.access.gpo.gov/2009/E9-4628.htm) Comments on this proposal are due by June 3, 2009. If adopted, this proposal could change the relationship between research institutions and external IRBs. Is this a good thing or not? Jeff will be posting his thoughts on this on the HRPP Blog (http://hrpp.blogspot.com). NIH Receives Massive Funding
NIH has recived over $9 billion ($8.2 billion in extramural funding, $1 billion to the National
Center for Research Resources (NCRR) to support
extramural construction, repairs, and alterations
in support of all NIH funded research institutions
and $300 million for shared instrumentation and
other capital equipment to support all NIH activities) as part of the economic stimulus package. (http://grants.nih.gov/recovery/) This represents the first time the federal government has recognized that biomedical and behavioral research has a significant impact on the economy. Research organizations should move quickly to take advanatage of this influx of research funding.
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Congratulations!
HRPA wants to congratulate Lifespan on becoming fully accredited at the March AAHRPP Council meeting. HRPA assisted Lifespan through the accreditation process.
Lifespan also utilized AccreditStation in preparing the AAHRPP application at each stage.
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What We Do
We offer many consulting, education and IRB management solutions:
AAHRP Accreditation Consulting HRPP SOPs & Forms HRPP Program Review Education & Training IRB Management Services QA Audits
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Contact Us
Email: hrpa.info@gmail.com Telephone: 240-432-4525 Web: www.hrpa-inc.com,
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