Modified on March 5, 2026 to remove the “subscribe” option. This blog has been retired and replaced by the S.P.I.R.I.T. newsletter.
Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, Legal Experts, and Investigators!
300+ subscribers and counting!
It’s mind blowing what’s transpired in 2025 so far (and we’re barely over the midpoint). I don’t solely mean on a personal level. So much has happened from a regulatory standpoint. It’s certainly difficult to keep up with everything. Life feels like it’s moving so fast.
Through my blog, I hope you feel this is a place where you can slow down and catch up. This blog is meant to serve you as an educational resource on-the-go (and at rest). I always welcome (and promote) feedback via comment on the blog or email: crest.innovation25@gmail.com
Today’s post will cover breakthroughs made in artificial intelligence (AI) in human research, healthcare, and medicine both domestically and internationally. AI research on the rise with no end in sight. It is essential to familiarize yourself with current best practices from industry experts.
I’d like to take a moment to thank these dedicated individuals who have devoted themselves to these working groups.
I am fortunate to know some of these folks through personal connection and applaud you. For those I don’t, I am grateful that you have willingly shared your expertise and time for this tremendous effort.
All your voices collectively are needed now more than ever. We are in an arms race with AI innovation and promoting the ethical conduct and use of AI in research.
As a general reminder, these are my own interpretations. Any legal information discussed within this post should be discussed with your institution or organization.
Let’s commend and review current progress in AI frameworks:
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World Health Organization’s (WHO) Ethics and governance of artificial intelligence for health: Guidance on large multi-modal models
From this initial guidance, potential risks and benefits were identified for the use of AI in healthcare.
Further, the following ethical principles were noted for governments, public sector agencies, researchers, companies, and implementers to consider:
Protect autonomy
Promote human well-being, human safety and the public interest
Ensure transparency, explainability and intelligibility
Foster responsibility and accountability
Ensure inclusiveness and equity
Promote AI that is responsive and sustainable
Through the current WHO guidance, it will:
Assist in mapping the benefits and challenges associated with use of LMMs for health and in developing policies and practices for appropriate development, provision and use
Provide recommendations for governance, within companies, by governments and through international collaboration, aligned with the guiding principles
The guidance is then broken down into two sections:
The first section details the applications, challenges, and risks of LMMs
Applications of AI for health include:
Diagnosis
This area is particularly promising given LMMs can see complex or rare cases of a diagnosis
Clinical care (along with public health surveillance)
With respect to patient-centered applications, AI is revolutionizing how patients are tending to their health (e.g., self-care chatbots and prediction tools).
I’m sure we’ve seen plenty of examples of this. However, the example mentioned here is the review of electronic health records to identify current clinical practice patterns. This could lead to the development of a new clinical practice
Healthcare administration
Here, AI could be used to reduce administrative burden (which could lead to a reduction in employee burnout)
Risk of using these LMMs include:
Overestimating benefits and underestimating risks
Accessibility and affordability
System-wide biases (such as exclusion of particular populations)
Impact on employment (likely due to AI automation)
Dependence of health systems on unsuitable LMMs (i.e., LMMs that are not maintained regularly)
Cybersecurity risks (e.g., malicious hacking)
Challenges noted for the use of these LMMs include:
Financial burden (e.g., having computers run continuously as well as training and deployment)
Attrition within universities and government agencies
The guidance highlights how faculty members who specialize in AI are being hired away from universities to work in industry (as industry LMMs are much larger and obtain greater investment towards the tool)
Lack of corporate commitment to ethics (given the elimination of employees dedicated to this effort)
The pressure to generate and maintain these LMMs tend to push ethics to the waste side
Lack of a moral compass (again, please read the article mentioned earlier about therapy chatbots)
The second section details the ethics and governance of LMMs in healthcare and medicine
Recommendations are provided to LMM developers for implementation to address these ethical risks:
Hiring individuals with AI expertise in science and engineering (e.g., via certification)
Ensure high data quality in training these LMMs as well as strict adherence to laws of informed consent and other privacy regulations (such as GDPR)
Design with human rights and values in mind (e.g., inclusiveness and transparency)
Environmental concerns should also be considered (e.g., carbon footprint and water usage)
With respect to governance:
Governments โshould have clear data protection laws and regulations for the use of health data and protecting individual rights, including the right to meaningful informed consentโ
Governments should have design and development standards as well as audits throughout LMM development
20 recommendations were listed with respect to open-source LMMs
UNESCO’s Red Teaming artificial intelligence for social good – The PLAYBOOK
UNESCO’s playbook begins with a short summary highlighting its intended use. The primary concept described is using Red Teaming for evaluating Gen AI systems for social good and exposing harms.
Red Teaming is described as a hands-on exercise where participants test Gen AI models for flaws and vulnerabilities that could unveil harmful behavior
A graphic is used to describe Red Teaming in four steps:
Find weaknesses in AI systems that could lead to errors, vulnerabilities, or bias
Set safety benchmarks
Collect diverse stakeholder feedback
Ensure models perform as expected
The playbook can be used for a vast range of professionals ranging from researchers to nonprofits to artists
When performing and preparing for Red Teaming exercises:
It’s essential to know the difference between unintended consequences and intended malicious attacks
Teams should have:
Clear objectives (i.e., defined challenge and prompts),
A diverse group of team members, and
Choose the appropriate format to conduct these exercises
Once exercises are complete, the playbook has the following recommendations when interpreting results:
Stay focused on team’s hypothesis
Avoid jumping to conclusions
Use different analytical tools for different sized datasets
The playbook also discusses potential challenges for implementing these exercises and how to overcome them
National Academy of Medicine’s (NAM) An Artificial Intelligence Code of Conduct for Health and Medicine: Essential Guidance for Aligned Action
The summary also highlights key stakeholder groups who contributed to the development of the AICC
Perspectives of these key stakeholders are described in great detail later in the AICC with respect to the six commitments
Common themes between these groups and distinct contributions from each group are also included
The framework continues with providing additional background information such as:
Defining AI and how it differs from other rule-based digital health technologies
Describing the use of AI in health, healthcare, and biomedical sciences
Risks associated with AI use and challenges AI use poses on governance and regulations
The AICC principles were updated based on public comment and NAM working group feedback. These principles are described in Table 3-2 in detail and are briefly listed here:
Engaged
Safe
Effective
Equitable
Efficient
Accessible
Transparent
Accountable
Secure
Adaptive
It is noted how these AICC principles and commitments can be applied to the AI life cycle. The AICC concludes with how these principles and commitments can potentially be regulated in a tight-loose-tight framework.
The Multi-Regional Clinical Trials (MRCT) Center of Brigham and Women’s Hospital and Harvard and WCG’s Framework for Review of Clinical Research Involving AI
This collaborative framework provides guidance to IRBs (and other reviewing committees) with actionable steps in reviewing AI research. Specifically, how to identify, assess, and mitigate risks to participants. The framework (also known as the toolkit) is broken down into logical sections:
A decision tree in determining if IRB review is required for the proposed AI research project with respect to the Common Rule and FDA regulations
A guide of questions and considerations to assess AI tool development and training data used in three phases:
Discovery
Translation
Deployment including:
Algorithm stability
Data identifiability, sources, and collection
Questions to consider with respect to the following ethical principles:
Human agency and oversight
Technical robustness and safety
Privacy, confidentiality, and data governance
Transparency
Representative and fairness
Informed consent
Finally, the toolkit provides a checklist when considering the use of AI in the administration of research. Though this may fall out of the IRB’s purview, examples of these types of activities include:
AI-enhanced data analysis
Human subject recruitment
Use of LLMs to help develop:
Protocols
Subject facing materials (e.g., informed consent forms, or recruitment materials)
Research instruments (e.g., questionnaires, data collection tools)
Transcription of interviews and generation of transcripts
LLM-generated responses to participant questions about the research
Any other operational roles where AI is not the primary intervention
European Medicines Agency’s (EMA) Review of AI/ML applications in medicines lifecycle
This brief report highlights AI/ML application publications relevant to future EMA activities. Publications were chosen based on specific inclusion and exclusion criteria (as this wasnโt meant to be a comprehensive review). Challenges and opportunities were explored with respect to:
Drug discovery
Nonclinical development
Clinical trials
Precision medicine
Product information
Manufacturing
Post-authorization phase
Finally, this report stressed the importance of data protection, data privacy, compliance with regulatory standards, and adapting frameworks to accommodate for the evolution of AI tool use.
Modified on March 5, 2026 to remove the “subscribe” option. This blog has been retired and replaced by the S.P.I.R.I.T. newsletter.
Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators!300+ blog subscribers and counting!
I hope everyone is doing well and had a fantastic 4th of July! It’s the perfect time to get away to spend time with family. Whether it be a staycation and even get something yummy on the grill. Or you actually get out of town for some R&R. Being in Arizona, it’s a little difficult to escape the heat.
I’ve been thinking a lot about my wonderful connections on LinkedIn. I encourage you to connect with me if you haven’t already! I love meeting new people and exchanging ideas.
I’m very fortunate to have knowledgeable people who are willing to share their expertise in my network. Especially when it comes to FDA-related material. I’ve learned a lot just from following along with what folks report. As well as their opinions on guidance documents. This by no means makes me an expert (yet), but I know with time I will get there. The FDA Clinical Investigator Training Course I completed last year really provided great exposure. In my mind I knew there was a plethora of information. But to actually see it and learn about it was a whole different animal! Which brings me to my next point.
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I have seen a handful of posts stating how OHRP and the FDA “silently” updatedtheir IRB Written Procedures guidance.
Due to the change in administration, I have been following OHRP and the FDA more diligently. I was aware that this guidance document was updated in February 2025. My error was assuming that other folks knew about this change. They always say don’t assume anything because “it makes an ass out of ‘u’ and ‘me’.” Alright, let’s move past the puns and get down to business!
I can understand why my connections referred to this as a “silent update.” There wasn’t necessarily a press release or formal announcement from either agency. Which got me thinking…there’s a need to make this information more well known. It would have been beneficial to have written about this back in January.
However, you’ll soon see why I’m glad I didn’t think of reporting this until now.
I would like to review the current guidance and share key takeaways. Further, I’d like to reveal why reporting this information to you now is even better than when it first occurred.
As a general reminder, these are my own interpretations. Any legal information discussed within this post should be discussed with your institution.
Let’s get ready to review:
2025 update on the FDA website
In February 2025, the FDA (in collaboration with OHRP) published the updated version of the IRB Written Procedures guidance. Before I dive into the key takeaways, I’d like to share the grand reveal. In other words, why I’m glad I didn’t think of posting about this until now.
Time to dig a little deeper
Just for giggles…
I decided to go to the OHRP website.
I anticipated that OHRP’s website would reflect the same guidance text as the FDA website. However, I was also hoping to see the 2018 version of this guidance document. I always love to compare prior versions with newer versions to see what changes were actually made. This would be useful when summarizing key takeaways.
Cue eyebrow raising…
When I finally located the guidance on OHRP’s website, I was greeted by an unexpected bulletin.
The bulletin reads (for those who may have visual difficulties from reading text from an image):
The June 2025 updates include revisions to item 34 of the table under โIRB Membership.โ
References in this guidance to HHS regulations at 45 CFR part 46, subpart A, are to this subpart in effect at the time this guidance was originally published, and not to subpart A as amended by a final rule published January 19, 2017 (82 Fed. Reg. 7149) and not to an interim final rule published January 22, 2018 (83Fed.Reg. 2885).
I’d like to highlight the following quote from the OHRP bulletin:
Item 34 describes diversity in IRB membership (e.g., representation of multiple professions, scientific and nonscientific members, nonaffiliated members). There is also reference to the two regulations related to IRB membership (45 CFR 46.107 and 21 CFR 56.107). I plan to discuss Item 34 (as well as any other potential changes) in the last section of this post. First, let’s touch base on the regulations and Trump’s EO.
Connecting the dots…
I immediately thought of two posts related to Trump’s EO.
Please note that the Federal Guidance Repository is no longer being updated. I am moving to a new platform. This is a slow moving project, but stay tuned for later this year (early next year)!
The first post provides a great description of Trump’s Gender Ideology EO for those who are unaware. The second post ties in nicely to helping us connect the dots.
Upon reflection, I realized that this was in reference to Trump’s definitions of “sex” versus “gender identity” within the EO.
The EO states that when administering or enforcing sex-based distinctions, every agency and all Federal employees acting in an official capacity on behalf of their agency shall use the term โsexโ and not โgenderโ in all applicable Federal policies and documents.
In my mind, this would include guidance documents and regulatory text.
To move our discussion forward, let’s review key information from the second post. When this was first published in February 2025, OHRP had the Common Rule regulation text available on their website. Under 45 CFR 46.107 you would have seen the following:
Image of 45 CFR 46.107 from OHRPโs website citing โsexโ versus โgenderโ
This would be aligned with Trump’s EO and the OHRP bulletin.
Interestingly enough, when you click on the aforementioned link the page no longer exists:
Screenshot of OHRP website for 45 CFR 46.107 stating the page is no longer available.
OHRP has removed their version of the regulatory text. It has replaced it with direct links to the Electronic Code of Federal Regulations (eCFR).
This got me thinking…
What does the eCFR say for OHRP’s regulation (45 CFR 46.107) and the FDA regulation (21 CFR 56.107) for IRB membership?
In both screenshots below, you will notice that “gender” is still referenced (as opposed to “sex”):
Screenshot of OHRP eCFR stating “gender” in IRB membershipScreenshot of FDA eCFR stating “gender” in IRB membership
Per the EO, agencies have 120 days to make changes to regulations, guidance, forms, and communications and share an update. This would put us at May 20, 2025. The screenshots for the FDA and OHRP eCFR were obtained July 3, 2025. I wonder when the eCFR will be changed to be compliant with the EO. Only time will tell!
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What has changed between the 2018 and 2025 version?
It took some digging, but I was able to find the original 2018 version via the Federal Register. Then, I navigated to Regulations.gov and looked up the specific FDA docket. I created a Google Spreadsheet to review updates in activities from 2018 – 2025. Upon review, I was surprised to see only ONE item has changed. Can you guess which one?
That’s right…only Item 34 (where reference to gender in 2018 was removed in the 2025 version).
The FDA and OHRP have either updated or released new guidance since 2018. To put this in perspective, I reviewed the FDA guidance documents database. The IRB written procedures guidance falls under the Good Clinical Practice (GCP) topic. Therefore, I filtered on GCP to see how many related guidance documents have been released since the original 2018 guidance. Not counting the 2025 guidance, the FDA has released 11 guidance documents of interest to IRBs.
You’re telling me there are no other recommended actions for IRBs to consider having written procedures for? Seven years have gone by since the last update.
As the author of this post, I’m unsure how to feel about this. As for my readers, I’m curious of how you feel about this. I strongly encourage you to leave a comment below.
Where do we go from here?
For my closing thoughts (as well as something to think about):
According to the 2018 Federal Register, the guidance at that time superseded the following documents:
OHRP’s July 1, 2011, โGuidance on Written IRB Proceduresโ
FDA’s 1998 โAppendix H: A Self-Evaluation Checklist for IRBsโ (formerly part of FDA’s Information Sheet Guidance for IRBs, Clinical Investigators, and Sponsors)
Therefore, it took seven years for OHRP to update and 20 years for the FDA to update (well…a collaborative update, but an update nonetheless)
Further, the 2025 guidance doesn’t have any notation that this guidance supersedes the 2018 document
How are IRBs supposed to interpret this?
Was the 2025 guidance simply updated in haste just to comply with Trump’s EO?
With staff limitations both at the FDA and OHRP, who knows when another formal update will be made.
Modified on March 5, 2026 to remove the “subscribe” option. This blog has been retired and replaced by the S.P.I.R.I.T. newsletter.
Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators!270+ blog subscribers and counting!
It makes me ecstatic to see more and more folks subscribing to the blog! I’m happy that this blog is a useful resource to you all. I aim to continue to provide meaningful, unique content. As I mentioned before, I love to explain complex topics in a simpler format. Speaking of learning and reinforcing concepts:
To solidify a concept, I like to see the content in various mediums (e.g., text, audio, visual).
Podcasts can be an excellent learning tool! Whether you are reinforcing concepts or would like to learn something new, podcasts can aid in this. If you love learning on the go, then this post is for you!
In this post, I will list the best podcasts for staying up to date on research, compliance, and administration.
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As a general reminder, these are my own interpretations. Any legal information discussed within this post should be discussed with your institution.
Let’s learn about these top-notch podcasts! Please note that these aren’t listed in any particular order.
Is there a podcast that you feel fits into this category that I didn’t mention? Please leave a comment below for myself and the community!
Dan Sfera aka “The Clinical Trials Guru” shares his thoughts on the clinical research industry, business, entrepreneurship, sports and really just about anything he feels like at the moment.
I absolutely love to follow Dan on LinkedIn. He offers extraordinary insights to the clinical research community. You can also check out the following resources related to Dan’s work:
This podcast discusses issues that impact scientific research monthly, from clinical research to ethical considerations. Hosted by Alexa McClellan.
There is a new episode each month. CITI Program’s blog also provides insights to their podcast episodes by breaking down the episode by podcast chapters and providing transcripts (example below):
Engaging with Online Communities: Ethical Considerations for Researchers (episode)
Engaging with Online Communities: Ethical Considerations for Researchers (blog)
This podcast discusses a broad range of technology ethics topics. Hosted by Daniel Smith.
There is a new episode each month. CITI Program’s blog also provides insights to their podcast episodes by breaking down the episode by podcast chapters and providing transcripts (example below):
This podcast discusses issues that impact higher education institutions. Hosted by Ed Butch.
There is a new episode each month. CITI Program’s blog also provides insights to their podcast episodes by breaking down the episode by podcast chapters and providing transcripts (example below):
Professional Development: A Conversation about Career Transitions (episode)
Professional Development: A Conversation about Career Transitions (blog)
This podcast dives into the intricacies of pre-award, post-award, compliance, communications, and all the essential elements in between. You can tune in on the last Thursday of every month for insightful discussions and expert insights for research administrators across the globe. The SRAI blog is also an excellent resource to deep dive into the complexities of research administration.
Though I haven’t personally checked out this podcast yet, these are my TOP THREE episodes I would check out first:
This podcast covers ethics and compliance-related topics and addresses issues ranging from FCPA to HIPAA to helplines.
Though I haven’t had the pleasure of listening to this podcast yet, I like how the episodes are succinct. If you’ve heard of the phrase, “Big things come in small packages”, this certainly applies! If you have a short attention span (which I tend to have at times), then this podcast is for you! Here are my TOP THREE episodes I plan to check out first:
This podcast is dedicated to helping scientists thrive. Brought to you by STEMCELL Technologies.
On their website, you can find excellent educational resources. With respect to podcasts, you can find summaries and video recordings of each episode here: Podcasts
JP Flores sets out to capture stories of resilience, scientific journeys, and inspiration that have built and shaped many diverse scientists.
I appreciate that this podcast strives to celebrate scientists. I haven’t had the opportunity to listen to this podcast yet, but these are the TOP THREE I am striving to check out first:
Advarra speaks with leading experts to dig into pressing issues and explore solutionswithin research and clinical trials.
Advarra has a plethora of resources ranging from their blog to on-demand webinars. This was my go-to podcast when I first started in compliance trying to learn the ropes. Though they haven’t had any recent episodes, I still find the information useful!
Modified on March 5, 2026 to remove the “subscribe” option. This blog has been retired and replaced by the S.P.I.R.I.T. newsletter.
Co-Author: Tasha Mohseni
Co-Author: Yefrenia Henriquez Taveras
Good morning, good afternoon, good evening Compliance Rockstars, Clinical Researchers, Ethics Educators, and Investigators from around the world!
We are so excited about sharing the second Show-and-Tell post within a highly educational series!
Before we get started, we wanted to share an important announcement:
This series was originally going to be 12 posts (i.e., a post per month).
However, due to the incredible feedback we received, we will no longer follow this format.
The series will conclude once all aspects of an IRB submission are covered! This may be a post per month (or multiple posts per month).
Your feedback is much appreciated, and we look forward to producing and providing this helpful content!
Before we give into this post:
We want to tell you about our methodology of assessing 16 biomedical IRB protocol templatesfrom various institutions.
Being in the compliance field, we are also passionate about research. More importantly, passionate about doing research ethically and in a reproducible way. We are going to summarize how we analyzed 16 biomedical IRB protocol templates from various institutions for commonalities:
We went to Google and typed in “IRB Templates”.
From here, we only reviewed templates with the following keywords:
“Biomedical”
“Bioscience”
“Medical”
Our initial plan (similar to the past post) was to stop once we browsed through 10 pages. Which we did and were hoping to have 50 records for review.
But…we encountered obstacles:
Some institutions had templates for consent and recruitment, but not for the protocol (perhaps this is an internal document in the electronic IRB submission system)
Some institutions relied on Federal agency templates (which is completely fine, but I said I would do my search on institutions)
Some institutions only had one type of protocol template (i.e., no difference between SBER or biomedical research) – again this is completely fine depending on the nature of the research at your institution
Some institutions required an institutional login to access their templates (hear, hear for additional security!)
Some institutions had protocol templates based on review type (exempt, expedited, vs. full board) – this is interesting to me because I wonder how these institutions have trained their investigators to know which template to use
Some institutions may have had biomedical protocol templates, but we were limited by the keywords we selected
After going through 10 pages of results, we decided to stop once we reviewed 16 institutions’ biomedical protocol templates.
We could have kept going, but we wanted to be consistent with the previous analysis we did in terms of the number of protocol templates reviewed
As we reviewed each template, we gathered the following data points:
A link to their PDF for future reference
Their institution only to avoid duplicate values (once we had 16 unique values – this column was deleted)
Sections within their protocol template
Then, with iterative prompting via ChatGPT-4, the GPT summarized the recurring themes within the protocol templates.
If you would like to review any of our references, please leave us a comment below.
Though we will have references throughout the post from the following agencies, it is recommended that you visit the Federal Guidance Repository to review these resources:
Office of Human Research Protections (OHRP) guidance documents
Secretaryโs Advisory Committee on Human Research Protections (SACHRP) recommendations
Food and Drug Administration (FDA) guidance documents
As a general reminder, you should consult with your institution’s IRB if you have any questions about the resources provided at the end of this post (or the recommendations within this post to ensure it is applicable to your institution). Additionally, check if your institution already provides specific templates that you can use:
Study Leadership and Resources Available
Title
This should hopefully be one of the easiest parts of your biomedical IRB protocol! The title of your protocol should give the IRB reviewer a sense of what your IRB protocol will be about.
Is there a grant associated with your study?
If so, I recommend reviewing sponsor requirements. Some sponsors may require that your protocol title must be the same title as your grant.
Principal Investigator (and Study Team)
The institution must know who is the lead investigator (i.e., the principal investigator (PI)) for the biomedical study. This is typically a faculty or staff member. If the research is student-led, then the student should check with their institution to see if they can be listed as the PI. Some institutions may be fine with this, but require a faculty member to be listed on the protocol as well. The protocol should also list all study team members associated with your study. Whether they are affiliated with your institution or an external collaborator, IRBs want to ensure that everyone has received the proper IRB/human subjects research training.
Institution Team Members
These are team members that are affiliated with your institution.
External Collaborators
These are team members that are not affiliated with your institution. If the collaborator is affiliated with an institution, they will need to reach out to their IRB. The collaborator’s IRB may require that the collaborator submit a study for review. Conversely, the collaborator’s IRB may not considered them engaged in research. You may not know this, but institutions have flexibility in how to apply the regulations.
Stay tuned for an upcoming post that will discuss the reliance process and the single IRBs!
Qualifications to Conduct Research
This section should establish the research team’s expertise and ability to conduct the study ethically and competently. The goal is to demonstrate that the research team is capable, experienced, and well-trained. This provides assurance to the IRB that participants will be protected and the study will be conducted ethically. It should include:
Principal Investigator (PI) and key personnel
Name, title, institutional affiliation, and role in the study.
Description of the PIโs research experience, particularly in the relevant area of study.
Previous experience conducting similar research (e.g., prior clinical trials, publications, or funded projects).
If applicable, any specific experience working with the study population (e.g., vulnerable populations, specific disease conditions).
Training and certifications
Completion of human subjects research training (e.g., CITI Program or NIH ethics training).
If the study involves medical interventions, confirmation of Good Clinical Practice (GCP) training.
Any other relevant compliance training (e.g., HIPAA, conflict of interest, biosafety).
Study team expertise and responsibilities
Description of co-investigators, study coordinators, research nurses, and other key personnel.
Each person’s role in the study and how their background supports the research objectives.
If specialized skills are required (e.g., phlebotomy, radiologic imaging, data analysis), documentation of relevant experience.
Resources Available
This section should detail the institutional and external resources available to ensure the study is feasible and well-supported.
Institutional resources and support
Describe the access to labs, clinical facilities, regulatory offices, and any core research services.
Include confirmation of adequate resources, including funding, personnel, infrastructure, and data management support.
Collaborations (if applicable)
Describe of external partners’ roles and expertise.
Document agreements such as:
Data Use Agreements (DUAs),
Memoranda of Understanding (MOUs), and
IRB reliance agreements (for multi-site research)
Study Background and Rationale
Background and Significance
This is also known as:
The study rationale (i.e., purpose) for the proposed research
The study aims and hypothesis
This is where you briefly introduce the purpose of your proposed study. If your research is funded, the study aims should be consistent with your grant. This is also where you would include your research question(s) and hypothesis. You should also provide a summary of research currently available (i.e., publications) to provide justification for the proposed study. I caution you here to avoid any technical terms or jargon. Remember, IRB reviewers aren’t as connected to your project as you are.
Therefore, this section should be written in a way that anyone can understand:
The main idea of the proposed research
Any published research that is related to the proposed research
Any current studies that are related to the proposed research (i.e., the ID number of any active studies related to the proposed research)
This helps IRB reviewers when they are making a determination for your study with respect to risk (i.e., no greater than minimal risk or above minimal risk)
Objectives (Primary and Secondary)
This section defines the specific goals of the study and differentiates between primary and secondary objectives.
Primary objective
This is the main goal of the study and is typically the primary outcome the research is designed to evaluate.
Example: To assess the efficacy of [intervention] in reducing [condition-specific outcome] over [time frame].
Secondary objective(s)
These are additional research questions that may provide supporting data or insights beyond the primary objective.
Example: To determine the effect of [intervention] on secondary markers such as [biomarkers, patient-reported outcomes, or other clinical indicators].
Exploratory Objectives (if applicable):
These are hypotheses that may not be powered for statistical significance but can inform future research.
Example: To explore the relationship between [genetic marker] and treatment response.
Objectives should be expressed as statements of purpose (e.g., to assess, to determine, to compare, to evaluate). Each objective should correspond to specific endpoints and hypotheses tested in the study.
Study Design and Methodology
Study Design and Endpoints (Safety and Efficacy)
This section describes the study framework, endpoints, and how safety and efficacy will be assessed.
Study design
Type of study: Clearly state whether it is an observational, interventional (clinical trial), randomized controlled trial (RCT), cohort study, etc.
Study population: Define the target population, inclusion/exclusion criteria, and recruitment strategy.
Study timeline: Outline key study phases, including screening, intervention, follow-up, and data analysis.
Study endpoints (safety and efficacy)
Endpoints are the measurable outcomes used to assess whether the study objectives are met. They should be directly linked to the studyโs hypotheses.
Primary endpoint:
The main measurement used to evaluate the primary objective.
Example: Reduction in [disease severity score] at [specific time point].
Secondary endpoints:
Additional outcomes that support the primary objective or assess other aspects of intervention effectiveness.
Example: Change in quality-of-life scores, biomarker levels, or patient adherence rates.
Safety endpoints:
Measures related to adverse events (AEs), serious adverse events (SAEs), laboratory test abnormalities, or other safety concerns.
Example: Frequency and severity of treatment-emergent adverse events.
Efficacy endpoints:
Clinical or laboratory-based measures that assess how well the intervention works.
Example: Percentage of patients achieving remission or symptom reduction.
Evaluation of safety and efficacy
Describe how safety and efficacy will be monitored, including data collection at study visits.
Specify when primary and secondary endpoints will be measured (e.g., baseline, 6 months, 12 months).
Comparison of Usual Care and Study Procedures
This section should clearly outline the differences between standard clinical care and the study-specific interventions or procedures. It helps the IRB assess whether the study introduces additional risks beyond routine medical care. If comparing an investigational intervention to standard care, explain why neither is considered superior at the time of study design.
Study Drug, Device, or Investigational Agents
This section describes the investigational product(s) used in the study and their regulatory status:
Provide the name, formulation, mechanism of action, and route of administration (if applicable)
If it is a device, describe its function, intended use, and classification (e.g., diagnostic, therapeutic)
Indicate whether the drug or device has FDA approval or is used under an Investigational New Drug (IND) or Investigational Device Exemption (IDE)
If approved for other indications, state how its use in this study differs from approved uses
Provide preclinical or clinical evidence supporting its use.
For device studies, detail how the device will be used, any required training, and safety precautions
Specify how adverse events, side effects, and safety concerns will be recorded and reported
As the section heading implies, this is where you would describe:
Criteria that makes the individual eligible for the proposed study
Criteria that makes the individual ineligible for the proposed study
Special Populations
If not obvious, you want to provide the scientific rationale for any exclusions of special populations. Special populations under The Common Rule (45 CFR 46) are:
There are other examples of special populations that aren’t covered in the regulations. An individual can be part of a special population if they can be considered vulnerable in the research:
Individuals with impaired decision-making capacity
Economically or educationally disadvantaged persons
Socially disadvantaged
Terminally ill or very sick
Racial or ethnic minorities
Institutionalized persons (e.g., persons in correctional facilities, nursing homes, or mental health facilities)
Dual role relationships (the investigator could be a manager or professor to the employee and/or student participant)
What is “vulnerability” in a research setting?
Below is a summarized table of when vulnerability can occur in a research setting:
Undue Influence
Coercion
Misusing a position of power to influence others to make a decision they would not normally make
A way to force or control someone
Number of Participants
In this section, you would indicate the number of anticipated participants you plan to enroll in your proposed study.
Recruitment Methods
Here, I like to take the “Five W’s” approach:
Who are you recruiting?
Why are you recruiting these potential participants?
What materials will be used for recruitment?
Where will potential participants be recruited?
When will recruitment begin?
Let’s look at these components one piece at a time.
The first question should be a concise statement of your inclusion criteria. When IRB reviewers ask who you will be recruiting, they aren’t looking for specific names. They are looking for the population of interest that will help answer your research question(s).
The second question is aiming towards providing justification for the population of interest. How will this particular population help you answer your research question(s)? What is it about this population that would benefit from the proposed research?
For the third question, IRB reviewers are trying to understand what materials you will be using to recruit participants. Will potential participants be contacted via email? What about social media? Do you plan to do in-person recruitment where you will distribute fliers related to your study?
Typically, the fourth and fifth questions are a combined statement. Something to keep in mind is in-person recruitment. Say you are going to an event where you plan to distribute recruitment fliers for the proposed research. Do you have permission to distribute recruitment fliers for research purposes? You will want to make note of any site permissions you have obtained for the proposed research. The IRB reviewer will likely want to review the site permission documentation as well. Be sure to include any explicit permissions within your submission.
Screening Procedures
Describe the screening process of how you will confirm that potential participants meet inclusion/exclusion criteria. Further, describe what will happen to screening/eligibility data for individuals who are not eligible to participate.
Informed Consent
The consent process should outline key information from the investigator that should be provided to participants. The key information here should facilitate the participantโs comprehension and voluntariness of potential participation in your study. Though there are standard required elements of consent (and additional requirements depending on your study), at minimum, your consent form should include:
The study activities
The duration of time the activities will take
Explanation of risks and benefits
Compensation and any limits to receiving it
Protections and limits of confidentiality
Stay tuned for a blog post describing the consent process in MUCH greater detail!
Study Interventions and Procedures
Procedures Involved
The IRB reviewer should be able to read and understand exactly what you are proposing to do with participants. Letโs pretend you are conducting a randomized controlled trial (RCT). The RCT will evaluate the effectiveness of a novel blood pressure medication in hypertensive patients. This section should include the following details:
Screening & Enrollment: Eligible participants (adults aged 40-65 with hypertension) will be screened and provide informed consent before study procedures begin
Study Visits: Participants will be randomized to receive either the investigational drug (Drug A, 10 mg daily) or a placebo for 12 weeks, with follow-ups at Weeks 4, 8, and 12 to monitor blood pressure, medication adherence, and side effects
Data Collection: Blood pressure readings, symptom diaries, and blood samples (baseline and Week 12) will assess treatment effects and safety
Safety Monitoring: Adverse events will be recorded, and a Data Safety Monitoring Board (DSMB) will oversee participant safety
Study Completion: At Week 12, final assessments will be conducted, and participants will receive follow-up care recommendations
For all study procedures, consider the five questions below:
Who on the study team is conducting the specific procedure?
What is the specific procedure?
How will the specific procedure occur?
When will the specific procedure occur?
Where will the specific procedure occur?
It is only important to note how the data collected from the specific procedures will be analyzed.
Study Intervention Discontinuation and Withdrawal of Participants
If a participant requests to withdraw from the study, the investigator should describe:
The scenarios under which they will be able to delete the participantโs data
The scenarios under which they will not be able to delete the participantโs data
For example, in a clinical trial assessing a new diabetes medication, the following scenarios would apply:
Data deletion allowed:
If the participant withdraws before any study procedures (e.g., before baseline assessments), their data can be fully removed
If withdrawal occurs before their data is incorporated into an analyzed dataset, identifiable information can be deleted upon request
Data deletion not allowed:
If the participant withdraws after study interventions have begun, de-identified data collected up to that point may still be used to maintain study integrity
If their data has already been aggregated or published, removal is not feasible
Participants will be informed of these conditions during the informed consent process, ensuring transparency.
Risk/Benefit Assessment and Safety Monitoring
Risk
Remember when we said IRB reviewers look at previous applications similar to the proposed research?
To reiterate, IRB reviewers when they are making a determination for your study with respect to risk (i.e., no greater than minimal risk or above minimal risk). Minimal risk (as defined by 45 CFR 46.102(j)) means that the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests. When the proposed research has risks, the investigator must have risk mitigation measures in place.
For example, if you are conducting a study on the psychological impact of childhood trauma, the IRB reviewer will evaluate whether participation could cause emotional distress. They will then check if:
Potential distress was disclosed in the informed consent process.
Risk mitigation measures (e.g., access to mental health resources, optional breaks, or the ability to skip sensitive questions) are in place.
The key is ensuring that the potential benefitsโwhether direct (e.g., therapeutic insights for participants) or indirect (e.g., advancing trauma research)โoutweigh the study’s risks.
Direct Benefit and Indirect Benefit
First, let’s define direct benefit and an indirect benefit:
Direct Benefit
Indirect Benefit
Refers to a positive outcome that directly results from the intervention being studied and is experienced by the research participants themselves
A positive outcome that arises from the research process but is not directly related to the intervention itself, often benefiting society at large or future research, rather than the individual participant in the study
Now, let’s look at a couple of examples:
Direct benefit: In a behavioral intervention testing a new stress relieving technique, a direct benefit would be the participant experiencing symptom relief from applying said technique to their daily routine
Indirect benefit: In a study on a new educational program, an indirect benefit could be the increased awareness of the topic among the wider community due to the research dissemination
It is also important to note that compensation is not considered a benefit.
Provisions to Monitor Participant Safety
Describe the plan to periodically evaluate the data collected regarding both harms and benefits to determine whether participants remain safe. The plan might include establishing a data monitoring committee and a plan for reporting data monitoring committee findings to the IRB and the sponsor. Specify the conditions that trigger an immediate suspension of the research. Specify any state laws related to mandatory reporting.
Biohazard Containment
This section should describe the potential biological hazards associated with the study. It should outline the measures in place to ensure safe handling, containment, and disposal of biohazardous materials.
Key considerations
Specify if the study involves the collection, storage, or processing of human-derived materials (e.g., blood, tissue, saliva, or other bodily fluids)
Indicate if any infectious agents, recombinant DNA, or genetically modified materials are used
Identify the biosafety level (BSL-1, BSL-2, BSL-3, or BSL-4) required for the study
Confirm that research will comply with institutional biosafety protocols and CDC/NIH biosafety guidelines
If recombinant DNA is involved, state whether Institutional Biosafety Committee (IBC) approval is required
Outline proper handling, labeling, and storage of biohazardous materials
Specify protective measures, such as personal protective equipment (PPE) and engineering controls (e.g., biosafety cabinets, fume hoods)
Describe approved methods for disposal of biohazardous waste, such as autoclaving, chemical disinfection, or incineration
Confirm compliance with institutional and regulatory waste management policies.
Provide procedures for responding to accidental exposures, spills, or contamination events
Describe how incidents will be reported to biosafety officers, institutional review boards (IRB), and regulatory agencies if necessary
Compensation and Economic Burden Considerations
Compensation for Participation
As mentioned above, compensation is not a benefit. Rather, compensation is a token of appreciation for participating in the research. It is not required to provide compensation. If you do not plan to offer compensation, you would simply include a statement regarding this. If you do plan to offer compensation, ensure the following details are included:
The amount of compensation
The form of compensation (e.g., if it is a gift card, identify where the gift card is to)
The justification for the amount of compensation
When and how compensation will be provided to participants
It is important to note that IRBs are not reviewing the amount of compensation to determine if it’s “enough”. IRBs review compensation amounts to ensure the amount is not coercive. As we know from the section above, coercion can make any individual vulnerable in research.
Compensation for Research-Related Injury
This section should describe whether and how the institution or study sponsor will provide medical care and/or financial compensation for injuries that occur as a direct result of study participation. Consider the following when drafting this section:
Specify whether the institution has a policy regarding treatment or reimbursement for research-related injuries.
If the study is industry-sponsored, clarify whether the sponsor assumes financial responsibility for treatment of study-related injuries. Ensure alignment with the clinical trial agreement (CTA) and institutional policies.
Define what is covered, such as:
Medical treatment for study-related injuries
Whether participants will be reimbursed for costs incurred
Exclusions (e.g., injuries from procedures intended for direct medical benefit)
Specify if the institution or sponsor does not provide financial compensation beyond medical treatment
Ensure that this section aligns with the informed consent document and does not conflict with institutional liability policies
If applicable, include information on how participants can seek assistance in the event of a study-related injury (e.g., contact information for research oversight offices or legal resources).
Economic Burden to Participants
Describe any costs that participants may be responsible for because of participation in the research. If applicable, include whether medical insurance will cover costs.
Privacy, Confidentiality, Data Management, and Future Use of Data
Privacy and Confidentiality
First, let’s define the difference between “privacy” and “confidentiality”:
Privacy
Confidentiality
Refers to the right to control access to ourselves and our personal information
Refers to agreements made between investigators and participants, through the consent process, about if and how researchers will protect participant’s information
Now, this section of a research protocol is vital for ensuring ethical standards are upheld and participant trust is maintained. Below are key elements researchers should address to create a robust plan for protecting participant data:
Outline how participant privacy will be safeguarded throughout the project
For instance, provide private and secure environments for interviews or survey completion
Specify where and how all data typesโpaper, electronic, or multimediaโwill be stored and managed
Data must be stored securely, such as in password-protected databases or locked filing cabinets in restricted-access areas
Highlight additional security measures like data encryption for electronic records
Clearly state who will have access to the data, limiting it to essential study personnel to minimize risk
For studies involving audio or video recordings, specify the retention period and handling procedures
For example, recordings may be deleted after transcription and verification or within six months of collection
During retention, secure storage methods, such as encrypted drives or locked cabinets, should be employed to prevent unauthorized access
If a master list or key is used to link participant identities to data, describe its management
Explain how it will be securely stored separately from study data (e.g., on a different encrypted server or in a separate locked cabinet)
Identify who will have access to the master list and ensure access is limited to essential personnel
Additionally, specify when the master list will be destroyed
State the minimum retention period for study data, typically three years after project completion, as per regulatory requirements
Except for master lists or keys and audio/video recordings, which should be destroyed at the earliest opportunity, all other data should be securely retained until the retention period ends
To maintain confidentiality, include methods for secure destruction, such as shredding paper files or securely wiping electronic data
If data will be shared or moved outside your institution, provide a detailed plan (such as a data use agreement)
Specify the type of data that will be shared, the recipient(s), the circumstances under which sharing will occur, and the timeline for these actions
Include any additional security measures to ensure data confidentiality during transfer
Data Management
For this aspect, the IRB reviewer will look for:
A statement of the types of study data collected
A statement of who has access to study data
A statement of how data will be stored
A statement of when data will be destroyed
A statement of how study data will be de-identified (if applicable)
A statement of how identifiable study data will be managed
Stay tuned for a future blog post regarding methods on how to de-identify your study data!
Future Use of Data
This section requires explanation only if you plan to share data outside of your institution. The investigator should provide a plan for any data movement or sharing outside of their institution. This section should also specify what data will be provided, to whom, under what circumstances, and when. This should also be disclosed in the consent form.
Protected Health Information (PHI), HIPAA Compliance, and HIPAA Authorization Waiver
This section should include:
A description of the creation, use, and/or disclosure of protected health information (PHI),
A statement whether HIPAA authorization will be obtained from all or some participants or a description of what alternatives will be used,
List everyone who will have access to PHI (including IRB, sponsors, FDA, data safety monitoring boards, and others),
A list of what PHI will be collected, used, and/or disclosed including the source(s), and
Why PHI obtained for this research are the minimum information needed to meet the research objectives
Additionally, describe the plan to protect and store PHI from improper use and disclosure. It should also specify and justify the earliest opportunity to destroy PHI and how it will be destroyed. If PHI will not be destroyed, provide a justification.
You will also need to explain how the use or disclosure of PHI involves no more than minimal risk to the privacy of individuals. It should also state why the research could not be practicably conducted without access to and use of PHI.
or
If the study qualifies for a waiver of HIPAA authorization, provide information explaining why the research meets the waiver criteria at 45CFR164.512(i)(2)(ii). Include the following
If you are requesting a waiver for the entire project (authorization will not be sought from participants) or recruitment only (identify eligible participants who then sign an authorization),
Whether the waiver will adversely affect the privacy rights of the participant,
An explanation as to why the research could not be practicably carried out without the waiver, and
An explanation that the research could not practicably be conducted without access to and use of protected health information
Sharing of Study Results and Incidental Findings with Participants
Describe whether results will be shared with participants or others (e.g., the participantsโ primary care physicians) and if so, describe how the results will be shared. Types of results include:
Study results
Individual participant results e.g., results of investigational diagnostic tests, genetic tests, or incidental findings
Study Timeline and Locations
Study Duration and Timeline
Describe the expected number and duration of contacts/meetings/procedures. In addition to the time commitment for participants and include an approximate end date of the study (including data analysis). Include a diagram/table/graph if appropriate. Outline if participation increases the duration of clinical care.
Study Setting and Locations (Including International Research)
Describe all sites/locations where your research team will conduct the research (e.g., where recruiting participants, research procedures will be performed, etc.), including any external sites conducting analytical procedures with project data. Please note any affiliated sites taking part in the research (e.g., sites with an existing reliance agreement). If you will be receiving/sending data to and from another institution, indicate which institution.
If you will also be conducting research at or with international sites, assess the relevance of the research to the region/country and the local context that affects the research, such as cultural norms. Explain the research teamsโ qualifications/expertise for conducting research in the locale(s). Describe the plan for monitoring the international components of the research. Additionally, explain any site requirements, laws relevant to the research (e.g. GDPR, PIPL), or state department warnings regarding travel to the international location(s).
Multi-Site Research Considerations
This section should describe considerations for research conducted across multiple sites, ensuring consistency in study implementation and compliance with ethical and regulatory standards.
Key considerations
Indicate whether each site will seek separate IRB approval or rely on a single IRB (sIRB) under NIH or Common Rule mandates
Describe how protocol consistency will be maintained across all sites, including investigator training and adherence to standardized procedures
Explain how data will be collected, stored, and transmitted securely across sites, ensuring compliance with HIPAA or international data privacy regulations
Outline mechanisms for reporting adverse events, protocol deviations, and updates to the lead institution and IRB
Coordinating Center Research
This section applies if the study is managed through a coordinating center responsible for protocol oversight, data management, or regulatory compliance.
Key considerations
Define responsibilities such as centralized data collection, regulatory submissions, monitoring, and reporting
Explain how the coordinating center will interact with study sites, ensuring protocol compliance and consistency
Describe how monitoring visits, audits, and data verification will be conducted
Specify how safety data, protocol deviations, and regulatory reports will be handled across sites
Analysis and Statistical Considerations
Data Analysis Plan and Statistical Considerations
This section should provide an overview of the statistical methods used to analyze the study data:
Indicate whether interim analyses will be conducted and any predefined stopping rules
Define how endpoints will be analyzed, including primary efficacy and safety measures
Describe the statistical power analysis used to determine the study sample size
Specify statistical tests (e.g., t-tests, ANOVA, regression modeling) and any planned subgroup analyses
Explain how missing or incomplete data will be addressed (e.g., imputation techniques)
Study Outcomes and Endpoints
This section should detail the primary and secondary outcomes measured in the study:
Define the main outcome(s) that the study is designed to assess, ensuring alignment with the primary study objective
Describe additional measures that support the studyโs findings or provide further insights
Outline when data for each outcome will be collected (e.g., baseline, follow-up visits)
Specify if outcomes are based on objective assessments (e.g., biomarkers, imaging) or subjective reports (e.g., patient-reported outcomes)
Ensure endpoints reflect clinically meaningful improvements beyond just statistical significance
We hope you found the second post of this blog-series helpful!
Modified on March 5, 2026 to remove the “subscribe” option. This blog has been retired and replaced by the S.P.I.R.I.T. newsletter.
Author
Tasha Mohseni
Good morning, good afternoon, good evening IRBers, Clinical Research Educators, and Investigators from around the world!
I’m so excited about sharing the very first Show-and-Tell post within a highly educational series!
I’m sure by the title you can tell what this post is going to be about. But first…
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And then…
I want to tell you about my methodology of assessing 17 social, behavorial, education research (SBER) IRB protocol templatesfrom various institutions.
Being in the compliance field, I am also passionate about research. More importantly, passionate about doing research ethically and in a reproducible way. I am briefly going to summarize how I analyzed 17 SBER IRB protocol templates from various institutions for commonalities:
I went to Google and typed in “IRB Templates”.
From here, I only reviewed templates with the following keywords:
“SBER”
“Social/Behavioral”
“Social/Behavioral/Educational”
My initial plan was to stop once I browsed through 10 pages. Which I did and was hoping to have 50 records for review.
But…I encountered obstacles:
Some institutions had templates for consent and recruitment, but not for the protocol (perhaps this is an internal document in the electronic IRB submission system)
Some institutions relied on Federal agency templates (which is completely fine, but I said I would do my search on institutions)
Some institutions only had one type of protocol template (i.e., no difference between SBER or biomedical research) – again this is completely fine depending on the nature of the research at your institution
Some institutions required an institutional login to access their templates (hear, hear for additional security!)
Some institutions had protocol templates based on review type (exempt, expedited, vs. full board) – this is interesting to me because I wonder how these institutions have trained their investigators to know which template to use
Some institutions may have had SBER protocols, but I was limited by the keywords I selected
Could I have assumed that surveys/focus groups/observations fall under SBER? Sure…but how do I know they aren’t also applicable to a biomedical component? Further, I set my keywords and that does not fit the criteria
After going through 20 (LONG) pages of results, I decided to stop once I reviewed 17 institutions’ SBER protocol templates.
As I reviewed each template, I gathered the following data points:
A link to their PDF for future reference
Their institution only to avoid duplicate values (once I had 19 unique values – this column was deleted)
Sections within their protocol template
Then, with iterative prompting in my personal ChatGPT-4 account, the GPT summarized the recurring themes within the protocol templates.
If you would like to review any of my references, please leave me a comment or email me at tmohseni@renovationinirbeducation.org.
Poll created in LinkedIn to determine an investigator’s problem area when creating a SBER protocol.
Though only one person voted (thank you!), they gave me some great insight. This is a common issue I see. Providing too little detail doesn’t give the IRB reviewer an idea of what the proposed research is about. More importantly, by providing little detail, you lose the significance behind your very important research!
Now, let’s take a deep dive into the various sections of a SBER protocol template. At the end, I will have a list of of applicable Office of Human Research Protections (OHRP) guidance documents and Secretaryโs Advisory Committee on Human Research Protections (SACHRP) recommendations. You should consult with your institution’s IRB if you have any questions about the resources provided at the end of this post (or the recommendations within this post to ensure it is applicable to your institution):
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Title
This should hopefully be one of the easiest parts of your SBER IRB protocol! The title of your protocol should give the IRB reviewer a sense of what your IRB protocol will be about.
Is there a grant associated with your study?
If so, I recommend reviewing sponsor requirements. Some sponsors may require that your protocol title must be the same title as your grant.
Principal Investigator (and Study Team)
The institution must know who is the lead investigator (i.e., the principal investigator (PI)) for the SBER study. This is typically a faculty or staff member. If the research is student-led, then the student should check with their institution to see if they can be listed as the PI. Some institutions may be fine with this, but require a faculty member to be listed on the protocol as well. The protocol should also list all study team members associated with your study. Whether they are affiliated with your institution or an external collaborator, IRBs want to ensure that everyone has received the proper IRB/human subjects research training.
Institution Team Members
These are team members that are affiliated with your institution.
External Collaborators
These are team members that are not affiliated with your institution. If the collaborator is affiliated with an institution, they will need to reach out to their IRB. The collaborator’s IRB may require that the collaborator submit a study for review. Conversely, the collaborator’s IRB may not considered them engaged in research. You may not know this, but institutions have flexibility in how to apply the regulations.
Stay tuned for an upcoming post that will discuss the reliance process and the single IRB mandate!
Background and Objectives
This is also known as:
The study significance and rationale (i.e., purpose) for the proposed research
The study aims and hypothesis
This is where you briefly introduce the purpose of your proposed study. If your research is funded, the study aims should be consistent with your grant. This is also where you would include your research question(s) and hypothesis. You should also provide a summary of research currently available (i.e., publications) to provide justification for the proposed study. I caution you here to avoid any technical terms or jargon. Remember, IRB reviewers aren’t as connected to your project as you are.
Therefore, this section should be written in a way that anyone can understand:
The main idea of the proposed research
Any published research that is related to the proposed research
Any current studies that are related to the proposed research (i.e., the ID number of any active studies related to the proposed research)
This helps IRB reviewers when they are making a determination for your study with respect to risk (i.e., no greater than minimal risk or above minimal risk)
Inclusion and Exclusion Criteria
As the section heading implies, this is where you would describe:
Criteria that makes the individual eligible for the proposed study
Criteria that makes the individual ineligible for the proposed study
Special Populations
If not obvious, you want to provide the scientific rationale for any exclusions of special populations. Special populations under The Common Rule (45 CFR 46) are:
There are other examples of special populations that aren’t covered in the regulations. An individual can be part of a special population if they can be considered vulnerable in the research:
Individuals with impaired decision-making capacity
Economically or educationally disadvantaged persons
Socially disadvantaged
Terminally ill or very sick
Racial or ethnic minorities
Institutionalized persons (e.g., persons in correctional facilities, nursing homes, or mental health facilities)
Dual role relationships (the investigator could be a manager or professor to the employee and/or student participant)
What is “vulnerability” in a research setting?
Below is a summarized table of when vulnerability can occur in a research setting:
Undue Influence
Coercion
Misusing a position of power to influence others to make a decision they would not normally make
A way to force or control someone
Number of Participants
In this section, you would indicate the number of anticipated participants you plan to enroll in your proposed study.
Recruitment Methods
Here, I like to take the “Five W’s” approach:
Who are you recruiting?
Why are you recruiting these potential participants?
What materials will be used for recruitment?
Where will potential participants be recruited?
When will recruitment begin?
Let’s look at these components one piece at a time.
The first question should be a concise statement of your inclusion criteria. When IRB reviewers ask who you will be recruiting, they aren’t looking for specific names. They are looking for the population of interest that will help answer your research question(s).
The second question is aiming towards providing justification for the population of interest. How will this particular population help you answer your research question(s)? What is it about this population that would benefit from the proposed research?
For the third question, IRB reviewers are trying to understand what materials you will be using to recruit participants. Will potential participants be contacted via email? What about social media? Do you plan to do in-person recruitment where you will distribute fliers related to your study?
Typically, the fourth and fifth questions are a combined statement. Something to keep in mind is in-person recruitment. Say you are going to an event where you plan to distribute recruitment fliers for the proposed research. Do you have permission to distribute recruitment fliers for research purposes? You will want to make note of any site permissions you have obtained for the proposed research. The IRB reviewer will likely want to review the site permission documentation as well. Be sure to include any explicit permissions within your submission.
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Informed Consent
The consent process should outline key information from the investigator that should be provided to participants. The key information here should facilitate the participantโs comprehension and voluntariness of potential participation in your study. Though there are standard required elements of consent (and additional requirements depending on your study), at minimum, your consent form should include:
The study activities
The duration of time the activities will take
Explanation of risks and benefits
Compensation and any limits to receiving it
Protections and limits of confidentiality
Stay tuned for a blog post describing the consent process in MUCH greater detail!
Risk and Benefit Assessment
Risk
Remember when I said IRB reviewers look at previous applications similar to the proposed research?
To reiterate, IRB reviewers when they are making a determination for your study with respect to risk (i.e., no greater than minimal risk or above minimal risk). Minimal risk (as defined by 45 CFR 46.102(j)) means that the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests. When the proposed research has risks, the investigator must have risk mitigation measures in place.
Let’s look at the example below:
Say you are conducting an anonymous survey regarding the mental health of college students. The IRB reviewer will review the survey questions to see if any of these questions could cause distress to participants. Then, the IRB reviewer will look at your protocol to see if:
The possibility of distress from answering these survey questions was disclosed
Distress mitigation measures (e.g., a list of mental health/therapy resources)
The key here is that any potential benefits (whether direct or indirect) should outweigh the proposed study’s risks.
Direct Benefit and Indirect Benefit
First, let’s define direct benefit and an indirect benefit:
Direct Benefit
Indirect Benefit
Refers to a positive outcome that directly results from the intervention being studied and is experienced by the research participants themselves
A positive outcome that arises from the research process but is not directly related to the intervention itself, often benefiting society at large or future research, rather than the individual participant in the study
Now, let’s look at a couple of examples:
Direct benefit: In a behavioral intervention testing a new stress relieving technique, a direct benefit would be the participant experiencing symptom relief from applying said technique to their daily routine
Indirect benefit: In a study on a new educational program, an indirect benefit could be the increased awareness of the topic among the wider community due to the research dissemination
It is also important to note that compensation is not considered a benefit.
Study Design and Procedures
The IRB reviewer should be able to read and understand exactly what you are proposing to do with participants. Let’s pretend you’re wanting to conduct a survey to see how folks feel social media impacts their mental health. This section should include the following details:
A statement of how the survey will be disseminated (paper or electronic)
If electronic, indicate if the collection of IP addresses or email addresses will be disabled (as this is identifiable information)
A statement regarding how long it should take to complete the survey
A statement of whether participants are allowed to skip questions they are not comfortable answering
Stay tuned for the blog post related to online research considerations for a more detailed explanation of this!
For all study procedures, consider the five questions below:
Who on the study team is conducting the specific procedure?
What is the specific procedure?
How will the specific procedure occur?
When will the specific procedure occur?
Where will the specific procedure occur?
It is only important to note how the data collected from the specific procedures will be analyzed.
Compensation
As mentioned above, compensation is not a benefit. Rather, compensation is a token of appreciation for participating in the research. It is not required to provide compensation. If you do not plan to offer compensation, you would simply include a statement regarding this. If you do plan to offer compensation, ensure the following details are included:
The amount of compensation
The form of compensation (e.g., if it is a gift card, identify where the gift card is to)
The justification for the amount of compensation
When and how compensation will be provided to participants
It is important to note that IRBs are not reviewing the amount of compensation to determine if it’s “enough”. IRBs review compensation amounts to ensure the amount is not coercive. As we know from the section above, coercion can make any individual vulnerable in research.
Privacy, Confidentiality, Data Management, and Future Use of Data
Privacy and Confidentiality
First, let’s define the difference between “privacy” and “confidentiality”:
Privacy
Confidentiality
Refers to the right to control access to ourselves and our personal information
Refers to agreements made between investigators and participants, through the consent process, about if and how researchers will protect participant’s information
Now, this section of a research protocol is vital for ensuring ethical standards are upheld and participant trust is maintained. Below are key elements researchers should address to create a robust plan for protecting participant data:
Outline how participant privacy will be safeguarded throughout the project
For instance, provide private and secure environments for interviews or survey completion
Specify where and how all data typesโpaper, electronic, or multimediaโwill be stored and managed
Data must be stored securely, such as in password-protected databases or locked filing cabinets in restricted-access areas
Highlight additional security measures like data encryption for electronic records
Clearly state who will have access to the data, limiting it to essential study personnel to minimize risk
For studies involving audio or video recordings, specify the retention period and handling procedures
For example, recordings may be deleted after transcription and verification or within six months of collection
During retention, secure storage methods, such as encrypted drives or locked cabinets, should be employed to prevent unauthorized access
If a master list or key is used to link participant identities to data, describe its management
Explain how it will be securely stored separately from study data (e.g., on a different encrypted server or in a separate locked cabinet)
Identify who will have access to the master list and ensure access is limited to essential personnel
Additionally, specify when the master list will be destroyed
State the minimum retention period for study data, typically three years after project completion, as per regulatory requirements
Except for master lists or keys and audio/video recordings, which should be destroyed at the earliest opportunity, all other data should be securely retained until the retention period ends
To maintain confidentiality, include methods for secure destruction, such as shredding paper files or securely wiping electronic data
If data will be shared or moved outside your institution, provide a detailed plan (such as a data use agreement)
Specify the type of data that will be shared, the recipient(s), the circumstances under which sharing will occur, and the timeline for these actions
Include any additional security measures to ensure data confidentiality during transfer
Data Management
For this aspect, the IRB reviewer will look for:
A statement of the types of study data collected
A statement of who has access to study data
A statement of how data will be stored
A statement of when data will be destroyed
A statement of how study data will be de-identified (if applicable)
A statement of how identifiable study data will be managed
Stay tuned for a future blog post regarding methods on how to de-identify your study data!
Future Use of Data
This section requires explanation only if you plan to share data outside of your institution. The investigator should provide a plan for any data movement or sharing outside of their institution. This section should also specify what data will be provided, to whom, under what circumstances, and when. This should also be disclosed in the consent form.
Withdrawal of Participants
If a participant requests to withdraw from the study, the investigator should describe:
The scenarios under which they will be able to delete the participantโs data
The scenarios under which they will not be able to delete the participantโs data
Let’s look at a couple of examples:
If you are conducting an anonymous survey, you likely would have no way of identifying the participantโs individual responses. Therefore, when a participant opts to withdraw, there would be no way to delete their data (i.e., their responses).
If you are conducting interviews, you could delete a participantโs interview transcript when a master list is in existence. However, you may not be able to do so until after the master list is destroyed.
I hope you found the first post of this blog-series helpful! Did you find this post informative for your SBER IRB protocol application? If so, please scroll on down and leave a comment below!