Awards & Pre-Award Compliance (15%) Flashcards
3 tenets of the Belmont Report
- Respect for persons
- Beneficence
- Justice
Respects for Persons means:
(Belmont Report)
- individuals should be treated as autonomous agents
- persons with diminished autonomy are entitled to protection
Beneficence means:
(Belmont Report)
- do no harm
- maximize possible benefits and minimize possible harms
Justice means:
(Belmont Report)
Certain individuals (eg those in marginalized or vulnerable groups) may not face greater risks in participation while others benefit. IRB or ethics committee should review all research studies
Where is the common rule found?
US Department of Health and Human Services (HHS) policy for the protection of human subjects (45 CFR 45, Subpart A)
What does the Common Rule do?
Provides additional protection for vulnerable groups:
- Pregnant women, fetuses, and neonates/ newborns (subpart B)
- Prisoners (subpart C)
- Children (subpart D)
Definition of “human subject” per IRB
A living individual about whom an investigator (whether professional or student) conducting research: (1) obtains Information or biospecimans through intervention or interaction with the individual, and uses, studies, or analyzes the information or biospecimans; or (2) obtains, uses, studies, analyses, or generates identifiable private information or identifiable biospecimans.
How is “research” defined by the Common Rule and the Belmont Report?
Common Rule: research is a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge
Belmont Report: an activity designed to test a hypothesis and permit conclusions to be drawn
Through a formal study plan with a set of procedures to reach an objective
Is oral history considered research?
Not accordingly to federal regulations, but some institutions will review these activities to ensure protection of subjects are providing personal data
According to 45 CFR 46, IRB must include:
- 5 members from relevant academic disciplines or experiences
- at least one member not affiliated with the institution
- at least one member with scientific expertise (conducts and is knowledgeable about research and human subjects research)
- at least one member who is a “non-scientist” to provide a layperson perspective
What is Review for Exemption?
Studies with no more than minimal risk. Determined by experienced staff member, chair, or IRB member.
- educational research (eG curriculum evaluation where info is non-identifiable and participation is voluntary)
- interview/survey on non-sensitive subjects
Public officials or professional/program evaluation - existing (“extant”) data that is de-identified / anonymous
-taste testing, food quality, or marketing research
What is Expedited Review?
Typically involve some degree of risk but still to a minimal degree. An IRB member may review the study. For studies of slightly higher risk, multiple revisits may conduct the review.) Some categories:
- collection of direct identifiers (voice or image) linked to responses of a more personal or sensitive nature
- work with potentially vulnerable populations (children, homeless, undocumented)
- potential for distress to participants beyond what normal in everyday life
- possibility of undue influence ( eg supervisor recruiting office staff or professor recruiting students)
- direct contact interviews, surveys, focus groups to collect sensitive or personal information
What is convened review?
When research activities pose significantly higher risks to subjects than those that might occur in daily life. Select IRB members may serve as “primary reviewers” and present their assessment as a convened meeting where all members will review the study and engage in a discussion. Examples include:
- minors if the data are sensitive
- pregnant women, fetuses, newborns
- prisoners or parolees
- individuals with decisional impairment
- abuse, drug use, or sexuality
- certain biomedical and/or experimental procedures
- heightened physical discomfort, risk of injury, or invasion of privacy
- use of a regulated drug/device, dietary manipulation, or medical/clinical assessment of identifiable patients/ volunteers
What documents are required as part of a complete IRB study plan?
- an application with plan for recruitment, study plan, managing data, managing potential risks of harm, list of who is involved
- Recruitment materials such as fliers, email scripts, social media announcements
- Informed consent form or script for oral project
- “Instruments” such as Interview our focus group questions, surveys (some require specific questions - others allow themes)
- Human subjects training for all researchers
(IRB may ask for additional items such as site permission, FDA approval, copyright permission)
Best practices in research studies
Recruitment: be careful when talking to friends and family, snowball sampling, and sliding social media that personal information may not inadvertently be disclosed.
Always consider hierarchies and influences. Eg school emails are not really private
Incentives are usually discouraged for minimal risk studies - but if necessary, consider what is appropriate in the context. (EG international situation might create discord, or a poor person might feel pressured to do it for the money)
Informed consent is an ongoing process
True - participants should feel free to ask further questions, reconsider participation, retract certain data, or withdraw their data at any time
What is HIPAA?
The Health Insurance Portability and Accountability Act of 1996 - federal law that generally prohibits health care providers from disclosing protected health information (PHI) without written consent from the patient
What are indirect identifiers?
Data that, in combination with other data, might reveal an individual’s identity, especially with a small sample size. Eg:
- Age, sex gender, race
- Size of town, general location, community characteristics (industrial, education, etc)
- characteristics of family structure
- details of personal characteristics or expressions of individuality
Anonymity vs confidentiality vs privacy
Anonymity - days are completely de-identified meaning you do not know the identity of the respondent in connection with the data. (Interviews and focus groups can never be anonymous)
Confidentiality - agreement that the respondent’s identity will not be disclosed beyond the research team without explicit permission. You can rarely guarantee absolute confidentiality. Also impacted by mandatory reporting laws and the possibility of a breach via email or videoconferencing
Privacy - the degree to which an individual has control over sharing personal information (physical, behavioral, and intellectual) - must be protected.
General Data Protection Regulation (GDPR)
EU rules over individual privacy and agency. Stricter than US. Could apply if you put out a survey over social media - for example.