Category: Lessons Learned

  • Emerging Breakthroughs in AI Frameworks in HSR (Mid-2025 Review)

    Emerging Breakthroughs in AI Frameworks in HSR (Mid-2025 Review)

    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

    You can review the guidance here: Ethics and governance of artificial intelligence for health: Guidance on large multi-modal models

    The WHO guidance begins with an executive summary highlighting the following points:

    • The brief introduction of the concept of AI and large multi-model models (LMMs) are introduced along with their initial work with this in 2021: Ethics & Governance of Artificial Intelligence for Health
      • 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).
        • Research and drug development
          • 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 โ€œshould 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

    You can review the guidance here: 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

    You can review the guidance here: An Artificial Intelligence Code of Conduct for Health and Medicine: Essential Guidance for Aligned Action

    Similar to the WHO guidance, the NAM AI Code of Conduct (AICC) opens with an executive summary:

    • The objective of the AICC is to harmonize the existing principles, address identified gaps, and map these principles to the NAMโ€™s Learning Health System (LHS) Shared Commitments
    • The AICC framework highlights six commitments:
      • Advance humanity
      • Ensure equity
      • Engage impacted individuals
      • Improve workforce well-being
      • Monitor performance
      • Innovate and learn
    • 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

    You can review the guidance here: 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

    You can review the guidance here: 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 wasnโ€™t 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.


    I hope you found this summary useful!

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  • Subscriber Spotlight: Preparing a Readable Consent Form

    Subscriber Spotlight: Preparing a Readable Consent Form

    Authored by:

    Mila Babaev

    Reviewed by:

    Tasha Mohseni

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators! 260+ blog subscribers and counting!

    I hope everyone is doing well! I can’t believe we are already halfway through 2025. If you’ve been subscribed to the blog from the beginning, you know that I have always promoted collaboration. I love to feature guest authors in my blog.

    Check out the collaborative posts that have been published thus far listed below!

    To highlight these contributors moving forward, I have developed a new type of post called “Subscriber Spotlight”.

    For these posts, you can expect to see:

    • An introduction of the valued subscriber,
    • How long the individual has been a subscriber,
    • Relevant social media and/or publications, and
    • A brief description of what they would like to share with you all!

    As a general reminder, these are solely the author’s interpretations (and none of their employer or associated affiliations). Any legal information discussed within this post should be discussed with your institution.

    Let’s get started:


    Who is Mila Babaev?

    Mila Babaev, CIP has been a loyal subscriber since December 2024. Per her LinkedIn profile:

    • She is an IRB and Compliance professional with over a decade of experience supporting Principal Investigators and study teams.
    • Further, she is versed in federal, state, and institutional level regulations and policy pertaining to the protection of humanโ€subjects research.
    • She is currently pursuing a Masterโ€™s degree in Research Administration and Compliance
      • Her goal is to gain new knowledge from this degree and move into a management role.
    • Lastly, she was recently given the opportunity to conduct internal audits/quality reviews on research trials at Atlantic Health System.

    Let’s dive into her piece on “Preparing a readable consent form”.

    Relevant regulatory requirement

    In reference to research consent forms, 45 CFR 46.116, requires that:

    โ€œThe information that is given to the subject or the legally authorized representative shall be in language understandable to the subject or the legally authorized representative.โ€

    • However, many consent forms submitted to the IRBs I have worked for in my 10 years as an IRB administrator contain language which far exceeds the 6th-8th grade recommended language.
    • The literature is in line with my experience; a review of written consent forms in 2018 revealed that most are written at a 10th grade reading level or higher across all medical specialties.

    In my conversations with researchers, it became clear that some do not even realize the terms aren’t in Layman’s terms.

    The guidance offers two useful ways to detect whether there is an issue with lay language and readability, in general…

    1. Read the form out loud to others and gather feedback
    2. Check grade level via a word processing tool, such as Microsoft Word

    To check the readability via Microsoft Word:

    1. On the โ€œFileโ€ tab, click the โ€œOptionsโ€ button
    2. Then, on the โ€œProofingโ€ tab, under โ€œWhen correcting spelling and grammar in Wordโ€, make sure โ€œCheck grammar with spellingโ€ is selected
    3. Next, under โ€œWhen correcting spelling and grammar in Wordโ€, select the โ€œShow readability statisticsโ€ check box
    4. After the grammar check is complete, Word displays a message box showing you the readability grade-level

    This tool can be valuable to researchers as well as IRB members when completing their reviews.

    Of course, it would be wonderful to have a tool that pinpoints exactly which words need to be defined in lay terms, so that none are missed. With the current AI wave, I think a tool designed for this purpose can be developed. At present, ChatGPT seems to do a decent job. I copy/pasted all the language in this text up to this point into ChatGPT and posed the question Is any of this language not in lay terms, appropriate for 6th-8th grade reading level? Quite a few responses came up, amongst them โ€œlegally authorized representative.โ€


    You can see other key readability tips outlined in the Johns Hopkins article below:

    • Use active verbs
    • Write concise sentences; You can divide one sentence into two
    • Limit each paragraph to one idea
    • Keep words to three syllables or less, if possible
    • Describe study design procedures such as โ€œdouble blind,โ€ and โ€œplacebo/controlledโ€ at first use

    References

    1. 45 CFR 46.116
    2. Johns Hopkins Informed Consent Guidance-How to Prepare a Readable Consent Form
    3. Hadden, K. B., Prince, L. Y., Moore, T. D., James, L. P., Holland, J. R., & Trudeau, C. R. (2017). Improving readability of informed consents for research at an academic medical institution. Journal of Clinical and Translational Science, 1(6), 361โ€“365. doi:10.1017/cts.2017.312

    We hope you found this content useful!

    Thank you again, Mila, for your continued support of this blog! Sharing your knowledge with the research and compliance community is truly appreciated. Looking forward to more collaboration with you on human research.

  • Sharpenย Yourย Review:ย Practicalย Adviceย forย Reviewers

    Sharpenย Yourย Review:ย Practicalย Adviceย forย Reviewers

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators from around the globe! 230+ subscribers and counting!

    I hope everyone has been doing well! It feels good to be writing to you all again. I absolutely love knowledge sharing and learning from others. As Iโ€™ve also mentioned in a previous post, writing has always been beneficial towards my mental health. Whatโ€™s even better is knowing that blog posts can help folks in the research and compliance space to think differently. Or perhaps, enhance their current thinking on a particular subject.

    In essence, I love to help people and explain complex topics in an easy format.

    I would like to share top strategies to sharpen how to review your institution’s protocols. As a general reminder, these are my own interpretations. Any legal information discussed within this post should be discussed with your institution.

    Sharpen your pencils folks and let’s begin:


    Research the research

    Have you ever been confused by an investigator’s proposed research protocol?

    Perhaps the investigator is using jargon only well known in their field. The same can go for undefined acronyms. Just because the investigator knows their proposed research so well, doesn’t mean the reviewer has that same level of knowledge. The easy route would be to send back as one of your revisions the following:

    “Avoid using technical jargon and define acronyms. This should be written in a way that anyone can understand.”

    Of course, this can be one of your revisions…but what I’m proposing here is to dig deeper. See what you can learn about the proposed research yourself.

    With everyone extremely busy, it can feel like you’re trying to just pump out reviews as fast as you can. Let me provide an example:

    Maybe your first go-to resource is seeing how other IRBs have reviewed similar research proposals.

    Sure, you can do this. This is a great way to see how other reviewers at other institutions review similar projects. Consider the following hypothetical example:

    • The researcher would like to see how well their device can measure the average calories participants burn in a day.
    • Their device is a wearable (i.e., a wristband).
    • They want to compare this device with a device currently on the market (e.g., Fitbit).
    • Their device is also linked to an app they created that will be downloaded to a participant’s phone.
    • From the app, the researcher would like to obtain physiological and geospatial data.

    At first glance, you may think…wow there are a lot of moving parts here. You may automatically wonder if FDA regulations apply in addition to the Common Rule. Or maybe, your head is spinning because you have no clue where to start. I urge you to think about the study design itself:

    1. You know the study team plans to compare their device to a Fitbit.
    2. You may already know that Fitbit has an app that is downloaded to a user’s phone.

    By researching the research, I propose to take the following action…

    1. Read through the Fitbit instruction manual,
    2. Review the instructions provided:
      • How to install the Fitbit app on your phone,
      • How to care for the Fitbit,
      • How to troubleshoot for an error, etc.
    3. Any potential risks listed by using the Fitbit,
    4. Any permissions required to ensure the Fitbit app accurately tracks your data

    By understanding the mechanism behind the proposed research, you will start to notice your questions coming together:

    1. Did the study team provide instructions on how to use the device?
    2. Did the study team consider all potential risks and how to mitigate these risks?
    3. Did the study team indicate the specific data measures that’ll be collected from the device’s app?
    4. Did the study team list what permissions are required from the participant’s phone to successfully use the app?
    5. Did the study team consider if their app must be integrated with other apps on the participant’s phone (e.g., the Health app)?

    By researching the research, you will find yourself asking the more critical questions. You should always consider what others are doing and regulations but try to put yourself in the researcher’s shoes. Help the researcher make their proposal that much more thought-out! By working together, we can help the researcher improve their protocol design. As a reviewer, you will start to think about the more in-depth questions to ensure adequate participant protections.

    The split-screen hack

    As a reviewer, we know we can have countless documents to review. This can be a daunting task in itself.

    On top of that, it can take a lot of time to ensure consistencies within various sections of the protocol.

    I would argue that the protocol is the most important document in a researcher’s proposal. The protocol how many important sections ranging from objectives to data collection methods, and so forth. I propose to use the “split-screen” function in Microsoft Word when reviewing the protocol document.

    What is the “split” function in Microsoft Word?

    By enabling this function, it essentially “splits” the document in half horizontally:

    • You will notice two scroll bars on the upper and lower half of the screen.
    • On the upper half of the screen, you can look at a certain section of the document.
    • On the lower part of the screen, you can look at a completely different section within the same document!

    Why would this be helpful, you may ask?

    This is particularly useful with long protocol documents. Let’s take the example of reviewing a study’s objective against the data collection methods. In a perfect world, these two sections within the protocol would be consistent with one another. Sometimes, they aren’t. Also, depending on the protocol, the objectives could be the first section of the protocol. Then, the data collection methods could be somewhere in the middle of the protocol.

    In lieu of scrolling back and forth in hopes you catch the inconsistencies; this ensures you absolutely catch any inconsistencies!

    This hack is a time saver.

    You can access this function in Microsoft Word using the steps below:

    1. Under the “Review” ribbon, within the “Window” section select “Split”.
    2. When you no longer need to use this, simply select “Remove Split” following the same steps listed in Step 1.

    Streamline documenting common errors you see on protocols

    What type of research does your institution typically review? Perhaps SBER?

    Let’s roll with this example. Say within SBER, you notice many of the submission you review conduct surveys and interviews. Maybe these submissions include observations or focus groups as data collection methods. Now, I want you to take a moment and reflect. Are there common errors you see within protocols that you always need the researcher to address?

    If you said “Yes”, then I recommend streamlining common errors you see into a template.

    By this, I mean creating a document with standard reviewer comments. The document should contain standard verbiage that can be easily copied, pasted, and fine-tuned depending on the study you’re reviewing. It’s difficult to have standardized verbiage for proposed research, so I recommend starting with what you see the most. You can slowly build your list of common errors as you see different types of proposed research.

    This efficiency tip isn’t just for you. This is something that should be shared!

    I encourage you all to share these standard errors you commonly see within protocols with your team members. Help the team be efficient in the review process. You can even make it a living document where team members can comment on what they see in their reviews. It’s always important to have multiple sets of eyes for something like this. Someone else can think of something you didn’t even consider. It’s important to not only develop yourself, but also help your team thrive! Dive into success together.

    Promote transparency in your communication with investigators

    Has anyone ever told you to do something, and you ask why this action is necessary?

    I know I have! I personally love to understand how things work. So, if someone says, “Hey, go do this”, I need to know why I have to. I need to understand why this particular step is important in the process. The same goes for researchers. They are inquisitive in nature. Therefore, if you’re asking a researcher to make a specific change in their protocol, tell them why this change matters.

    Say you’re reviewing a consent form within the researcher’s application, and you notice there isn’t a statement about participant risk.

    The researcher comes back and says, “Well, there isn’t any major risk to my study. I don’t see a point in saying this.”

    This is where the “why” to your “ask” comes into play. Sure, you state that addressing risk is a regulatory requirement (i.e., basic element of consent). You should also state that the participant should be aware if risks are present. The participant should have all the details necessary for them to make an informed decision to participate. If there are no foreseeable risks or discomforts, then the participant should be aware of this. This can impact the participant’s decision-making process. By explaining these concepts to the researcher, they will be more inclined to incorporate this statement into the consent form. They will also be mindful of this in future submissions.

    Reflect on oddball situations

    Have you ever had a submission that was outside of the norm? Did the review process require additional steps that typically wouldn’t be required?

    Now – I want you to imagine you came across another submission of this nature. Do you remember everything you did when you came across this oddball review the first time? Did you do your due diligence and document the process? Maybe you intended to but were caught up in another task and oops…you forgot. Here, I’d like to promote the IRB Precedent Tool. This is a structured way of documenting these oddball situations.

    You can incorporate key details of:

    • The situation itself,
    • Steps you took during the review process,
    • Any regulatory information that assisted you in making a determination, etc.

    Unsure what I’m talking about? You can read more about this brilliant approach here: Steps toward a System of IRB Precedent: Piloting Approaches to Summarizing IRB Decisions for Future Use

    Stay current with regulations and developments in the field

    This…I must admit is a tough tip to implement.

    With all the regulatory updates and publications coming out like clockwork, this can feel overwhelming. You can attempt this via:

    • Signing up for various agency newsletters (e.g., FDA if you have mainly biomedical research). Another great one is the Office of Human Research Protections (OHRP).
    • Rely on newsletters from various organizations such as PRIM&R for these types of updates.
    • Check the Federal Register daily for any new rules or notices.
    • Check agency websites daily for any regulatory updates.
    • Review journals on a daily basis for developments in the field (e.g., Ethics and Human Research).

    You can split the proposed tips above if you have multiple team members. One person (or multiple) can focus on regulatory updates while others focus on recent publications.

    But what about those with small HRPP offices where there could be only 1-2 people?

    Time for a little self-promotion. An excellent starting point would be to follow along this blog’s monthly posts (even if you aren’t in a small HRPP):

    • Research Compliance Chronicle (see the first edition here): a comprehensive review of regulatory updates from the previous month including:
      • Agency-specific news, policy updates, and new rules
      • Presidential actions (i.e., executive orders)
      • Proposed bills that can potentially impact research and compliance
    • RAC Digest (see the first edition here): a comprehensive review of recent developments in the research administration and compliance fields from the previous month including updates from journals such as:
      • Accountability in Research,
      • AJOB Empirical Bioethics,
      • JAMA, and many more!

    Leverage experiences from senior personnel

    Knowledge sharing is a hallmark in an optimal institution’s review committee.

    You might remember what it was like when you first started your career as a research reviewer. Remember being overwhelmed – thinking – how could I possibly learn all this? Well, this is where knowledge sharing comes into play. Senior personnel are the hidden gems within a review committee. Why? They’ve likely seen many types of proposed research throughout their career. Not only common types of research projects, but also oddball scenarios. Leverage their expertise and learn from them. Explain your thought process on a particular scenario. Senior personnel will likely provide insights that you didn’t initially think about.

    Consult with subject-matter experts

    Having a diverse network of subject-matter experts to consult can aid the review process.

    Engage with subject-matter experts when the particular topic within the proposed research is out of your purview. Similar to the tip above, these folks can provide the specific knowledge needed to ensure a comprehensive review. An example of this could include security concerns about an app the research proposes to use in their project. Building this diverse network of these folks can give you a shoulder to lean on to ensure adequate participant protection.


    I hope you found this post useful!

  • Top Career Hacks for Compliance Professionals

    Top Career Hacks for Compliance Professionals

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators! 190 blog subscribers!

    I hope everyone has been doing well! I know it has been a while since I’ve published a post. I’ve been attempting to follow all the compliance news occurring. It seems as though something new happens every week, if not every day. There is certainly a lot of stress and uncertainty within the research and compliance world.

    Which is why I feel this post couldn’t be shared at a more appropriate time.

    I would like to share top career hacks for compliance professionals. Not only can you apply these hacks to your career, but also in your life.

    In these times of uncertainty, it is crucial to take a step back and reconnect with yourself.

    As much as we talk about emotional intelligence and empathy towards others, self awareness is just as important. We should always take active steps to center ourselves.

    As a general reminder, these are my own interpretations. Any legal information discussed within this post should be discussed with your institution.

    Let’s take a moment to reflect on these career and personal wellness hacks:


    It’s okay to say “I don’t know”

    Have you ever been asked a question during a presentation or meeting you weren’t sure how to answer?

    Did the question seem out of left field? Was it about a topic that you didn’t account for? Maybe it was related to something that you deemed irrelevant?

    As you imagine this scenario, I want you to try to remember how you felt. Did it make you feel incompetent? Were you caught off guard? How about your physical state? Were your palms sweaty? Did your jaw clench? Did you feel shortness of breath?

    As someone with anxiety, I have certainly had these moments. Just sheer panic and fear of what someone would think of me. But you know what I’ve learned? It’s worse to pretend like you know the answer.

    The best thing to say is, “I don’t have the answer right now. I can certainly look into this and get back to you.”

    or

    Another option I like is to say, “This is an excellent question and something I didn’t consider. Let me get back to you once I learn more information.”

    By admitting you don’t know something, it shows integrity to your audience. It’s important to be candid. You should try not to focus on feeling incompetent. If anything, this is an opportunity for growth. You get to learn something new!

    You can apply this in your personal life as well. You could be having a conversation with someone, and you have no clue what they’re saying. Again, in lieu of being embarrassed, take a leap and learn more about it! I always like to say that I am a “forever student”. I truly enjoy learning on my own, but even more so from others. Especially if they are passionate about the topic.

    Build your network

    Ever heard of the proverb, “it takes a village”?

    Well, that’s because it does! You can read all the policies and procedure pertinent to your compliance area. You can watch all the videos you want from experts discussing a topic in depth. What you have to learn to accept is that you possibly couldn’t learn all of this on your own. And that’s okay. There’s a reason why we have different folks for various compliance areas. Sometimes, IRB professional needs to connect with a COI team for potential conflicts of interest related to an investigator’s research. Perhaps that same IRB professional needs to check in with Export Security for an investigator’s travel plans.

    Recognizing that it takes a village is another positive step forward towards career growth. I urge you to build your network. Get to know folks from various fields in research administration/operations at your institution. Have lunch with them and ask them what it is they do. Ask them how does your area of expertise intersect with their daily tasks.

    What about folks who were multiple compliance hats at their institution?

    These folks should look at building their network outside of their institution. Of course, institutions have their own sets of policies and procedures. The key is to connect with folks who may have encountered the same or similar issue that you have. How did these folks handle the situation at their institution? Can you directly apply the resolution at your institution? If not, can you adapt certain aspects of the resolution?

    When you have a group of folks you can ask questions and bounce ideas off of, this is called your network. Applying this concept to your personal life, we call this a support system. To compare, your support system is comprised of individuals that you can count on. These are the people you go to when you’re in a pickle and you don’t know what to do. These are the people you can also bounce ideas off of. This is why human connection is so important both at work and outside of the workplace.

    Give yourself mental resets

    Have you ever worked on a project where you just stared at your screen for hours? You wanted to make progress but felt stuck.

    Perhaps you’re setting up decorations for your child’s birthday party. You have a vision of how the decorations should look, but you’re overwhelmed with frustration. Things aren’t turning out as you pictured in your mind.

    If this has ever happened to you, you’re not alone. At moments like these when all seems lost, you need to step back. This is what we call a mental reset. By taking a break from the situation, you are allowing yourself that space to be gentle with yourself. Sometimes closing the laptop or stepping into another room away from the decorations can provide the clarity you need.

    You can take mental resets by:

    • Simply stepping away from what is causing you frustration.
    • Going for a walk and getting fresh air.
    • Taking deep breaths to steady your mind.
    • Practicing meditation or prayer.
    • Doing something that brings you joy. Maybe a book you’ve been reading.
    • For anxiety, trying the grounding technique and stimulating your senses.
    • Washing your face with cold water to refresh yourself.

    Whichever method you choose, I guarantee that you will feel much better at tackling your issue. These mental resets will help you figure out how to solve your problem. The beautiful thing is that there aren’t limits to the number of mental resets one can take. Take as many mental resets (i.e., breaks) as needed to center yourself and start again.

    Celebrate your triumphs

    Did you just receive an award at work for outstanding performance? Maybe you finally organized that storage closet that you never let your house guests see.

    Whatever the achievement may be, no matter how big or small, should be celebrated! It doesn’t have to be an elaborate celebration with a lot of people and balloons. It can be something simple as buying that shirt you’ve had in your cart for months. Or maybe you take a day trip to enjoy nature. Celebrating your triumphs can promote your self-worth. As much as you remember the bad times, take the space to embrace the good times. Fill your heart and life with as much joy as you can. Life is too short not to be celebrated.

    Group similar tasks together

    In today’s world, it is so easy to be overwhelmed.

    You can find yourself drowning in reviewing submissions, emails, meetings, and spontaneous tasks that fall in your lap. Days such as these are often unpredictable. It’s essential to take a step back and pause before you react.

    At the start of your day, look at your calendar and compare this to any anticipated daily tasks.

    Are there any daily tasks that coincide with a particular meeting you have scheduled that day?

    • If so, group those tasks together and prioritize completion based on when the meeting will start. If you’re unsure which tasks to complete first with respect to the meeting, review the meeting agenda (if available). Then, complete the tasks in the order of the meeting agenda.
    • If an agenda is unavailable, complete the tasks in a logical order that aligns with your compliance area’s process flow. When you present your task deliverables in this format, meeting attendees will be able to follow along with ease.

    What if your free of meetings for the day and you have this daunting to-do list?

    Again, review this list and see which tasks are similar to one another. Once you have grouped similar tasks together, consider how these tasks should be completed:

    • Are any of these task groups dependent on one another?
    • Can any of these task groups be completed quicker than other task groups?
    • Do any of these task groups depend on an action from a collaborator?
    • Can any of these task groups be streamlined via automation (e.g., creating a mail merge file)?

    You can also apply this methodology in your personal life.

    Again, let’s consider the following:

    • Are any of these task groups dependent on one another?
    • Can any of these task groups be completed quicker than other task groups?
    • Do any of these task groups depend on an action from another household member?
    • Can any of these task groups be streamlined (e.g., setting up automatic withdrawals on bill payments)?

    By pausing to plan and group tasks together, you’ll find that your daunting, busy day won’t seem so grim. If something seems impossible:

    • Take a mental reset to acknowledge you are unsure how to proceed. Remember, it’s okay if you don’t know the answer.
    • Reach out to your network (i.e., support system) for guidance.
    • Work through your tasks at your own pace. I promise you there isn’t a time limit.
    • Give yourself a pat on the back for taking care of business. You made it! Celebrate it!

    I hope you found this post insightful!

  • Top Tips on Making Training Documents Accessible

    Top Tips on Making Training Documents Accessible

    Good morning, good afternoon, and good evening Compliance Rockstars, Clinical Researchers, Ethics Educators, and Investigators from around the globe!

    I hope you are doing well! This has been one crazy year so far. To think we are already in March. I wanted to take the time to have a step back from these current events that have occurred. Though the previous posts have relevance to the research and compliance world…

    I wanted to get back to the basics of this blog.

    As the name suggests, the purpose of this blog is to promote scientific trust and research ethics education. In light of this, I also find it important to discuss how we should be teaching research ethics.

    In today’s post, I want to describe how to make your training documents more accessible. If you have been following from the beginning, you may be thinking to yourself…

    What a minute…didn’t Tasha already write a post like this?

    Well, you’re right. I did write about a similar topic. However, I wanted to revamp this post to discuss what I have learned over the course of my careers.

    You may not know this about me, but I didn’t always work in research and compliance. I’ve also been trained as an auditor and an analyst. This may explain why I am detail oriented.

    Financial analysis and project management are tough topics. I remember being humbled my first semester of accounting. I thought to myself, if I can do calculus and differential equations, accounting should be a breeze. Boy, was I wrong! Though I had my tail between my legs, I still managed to rise to the occasion.

    Even within these careers, I have always been fascinated with training and outreach. I thrive on understanding how people learn and if folks are engaged with what I’m attempting to teach. I also look for ways to make complex topics easier. I don’t like to over-complicate things. The simpler I can make something for someone, the better I feel I understand it.

    They always say teaching something is the best way to become an expert at a topic. Even with this mindset, I prefer to “always be a student of my craft”. It’s natural to constantly be learning and evolving, as we all know life isn’t stagnant.

    Therefore, I want to share top tips I’ve learned to make documents more inclusive. You won’t find the old post as it has been deleted (bye-bye, gone). 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 learn!


    What is accessibility?

    When I look up what accessibility means, there are various definitions depending on the context. I really like how California State University Long Beach defines this term:

    Accessibility is about providing a means for users with disabilities to access the same information and services that users without disabilities are able to access.

    I like to think of accessibility as making training documents easy to comprehend and review for everyone. Accessibility makes it a level playing field. When it comes to folks with disabilities, the top ones to me are those with visual or hearing disabilities. Someone with color blindness or hard-of-hearing should be able to use the same training materials I create for someone who doesn’t have these disabilities.

    Why is accessibility important?

    Aside from the humanity aspect, it’s the law! Directly from the website itself, the Americans with Disabilities Act (ADA) protects people with disabilities from discrimination.

    It is a Federal civil rights law that protects people with disabilities from discrimination in many areas of life.

    Accessibility as a tenet of research ethics

    Circling back to a statement I made earlier:

    The purpose of this blog is to promote scientific trust and research ethics education.

    In light of this, I feel we should understand how accessibility can be viewed as a tenet of research ethics. When I think of human subjects research ethics, I automatically think of the Belmont Report. If you’ve conducted research with human subjects or taken a bioethics course, you may be familiar with this report. The Belmont Report has three principles:

    • Respect for persons
    • Beneficence
    • Justice

    With respect to accessibility, I’d like to discuss the Justice principle. Directly from the Belmont Report:

    Who ought to receive the benefits of research and bear its burdens? This is a question of justice, in the sense of “fairness in distribution” or “what is deserved”.

    Justice can also be understood as:

    Equals ought to be treated equally.

    The formulations of Justice include:

    • To each person an equal share,
    • To each person according to individual need,
    • To each person according to individual effort,
    • To each person according to societal contribution, and
    • To each person according to merit

    I really spent some time trying to find the perfect image to describe the Justice principle with respect to accessibility. I finally came up with the image below:

    McMaster University’s representation of “equality”, “accommodation”, and “accessibility” (also known as “equity”).

    Simply treating everyone as equals doesn’t fulfill the accessibility requirement. Referring to the picture, we can see the unfair distribution represented by “equality”. The Justice principle indicates that equals should be treated as equals. But what about those who are “unequal” to the “group of equals”? You can certainly provide accommodations, but accessibility is really about equity. Equity can be described as the formulations listed in the Justice principle.

    Equity is about treating people fairly in accordance with their needs.

    Top tips for training document accessibility

    Tip #1: Ensure you have documents available as a PDF and a Microsoft Word document

    I love this tip! This isn’t something I necessarily learned from a training session or workshop. Word documents are great because you can edit them and make notes.

    I used to do this all the time when I was learning something new (especially in college). It would be helpful for me to make my own annotations directly into a handout.

    Conversely, PDFs are great for distribution. If you just want a “clean copy” of a training handout, this is the best way to go. When you’re creating training handouts at your institution, you should strive to have both types of files available.

    This is especially important if you embed objects in your files. This is when you link a file into your working file. The user will be able to click on the file and access it. If you only have a PDF version of your working file, the user will not be able to access the embedded object. This is why you should have a Word version and a PDF version.

    Tip #2: Use Alt Text for images in your Microsoft Word document

    What is Alt Text?

    Short for alternative text, is a short description of an image in a training document. Typically, 1-2 sentences is the sweet spot for describing an image.

    You may be wondering to yourself…

    How is this different than adding a caption to your picture?

    Though I’ll define captions below, alt text is specifically for individuals who have visual disabilities. Alt text is meant to quite literally describe the image in the handout.

    Let’s review the picture used above from McMaster University. The text underneath is a caption adding a description of the image. An example of alt text of the image would be:

    There are three whiteboards at varying lengths and with standing prop stools. At each whiteboard, there are two people standing and one person in a wheelchair.

    As you can see, alt text literally describes the image itself. While a caption provides additional context or explanation about the image.

    Tip #3: Always use the headers feature to separate topics (and to use the cross-reference feature)

    The next three tips are related to formatting your training documents. Now, let me explain why I especially love this tip:

    I like to think of this tip as a “two-for-one” combo!

    Using headers in your training handouts is a great way to make different topics stand out. This helps folks visually see what you plan to discuss. Be sure to make your headers meaningful (i.e., the header should be concise and accurately describe the context beneath it).

    Headers also work well if your training handout has a table of contents. When you use headers, you will be able to use the cross-reference feature. This essentially serves as a hyperlink. When you go to your training handout’s table of contents and click on the link, it will take you directly to that section in the handout!

    Say goodbye to doom-scrolling! With the cross-reference, you can get to the desired section in seconds.

    Tip #4: Use ordered (numbered) and/or unordered (bulleted) lists in lieu of long-winded paragraphs

    Now if you’ve seen my profile picture on the About Us page, you may have noticed that I wear glasses. Interestingly enough, this does NOT fall under the Americans with Disabilities Act.

    Even though I technically don’t have a visual disability, I do have ADHD!

    Therefore, I strongly appreciate this tip! I hate reading through long-winded sentences and paragraphs. Lists just make life easier! Regardless if you have ADHD or not. I’d take lists over long paragraphs any day. With my attention span, lists are much better for me (and in general…for everyone who also suffers from short attention spans).

    Tip #5: Use descriptive text when adding hyperlinks to your documents

    Now, I’m totally guilty of this…

    How many of you when writing an email or updated a website have written something along these lines?

    “Click here for more information”.

    That’s a HUGE NO NO! You should always use descriptive text when inserting a hyperlink to your training handouts. In lieu of the statement above, you could say:

    “Click the following link for Tasha’s Insights“.

    This way, the user of the file knows what the hyperlink is actually to!

    BONUS TIP: Get feedback on your training document’s accessibility by those with individuals with disabilities

    This is the ULTIMATE tip!

    I absolutely love getting feedback from folks. Especially if it’s a product I developed for them. You should also do this at your institution, especially from folks with disabilities. This way, if they find the document readable…or should I say accessible, then you know you’re on the right track.


    I hope you found this content useful in developing your training materials!