Tag: ethics

  • Navigating Research and Regulatory Certifications: PRIM&R, SOCRA, ACRP, and HCCA Explained

    Navigating Research and Regulatory Certifications: PRIM&R, SOCRA, ACRP, and HCCA Explained

    Published on 5/26/2025; Revised on 5/28/2025

    • Thank you, Kim Serpico, Ed.D., CIP, for your thoughtful suggest of including cost within the summary certification table!

    Feedback is always welcomed by my readers to ensure I am disseminating information in the most helpful way.

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators! 250+ blog subscribers and counting!

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    Imagine this…

    • You have more than two years of experience in your research compliance and regulatory role.
    • You’ve had exposure to various research areas (e.g., SBER, biomedical, clinical trials).
    • You’re wondering what to do next to boost your professional development.
      • Maybe, you think about taking a course or an intensive training specializing in a specific topic.

    Or maybe, you’re thinking bigger. You’re thinking about obtaining a certification to showcase your expertise. A certification may even secure a promotion for you. Then, the questions pour in:

    • Which certification best aligns with my career goals?
    • What are the requirements to obtain the certification I’m interested in?
    • Are there any application fees?

    Or maybe, you already have a certification, and you ask yourself:

    Which certification would complement my current certification to help further advance my career?

    I would like to discuss 10 certifications related to research and regulatory compliance. For this post, you can expect:

    • Summary tables comparing key features of each certification.
    • A breakdown of the organizations offering these certifications.
    • A breakdown of each individual certification.

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

    Let’s explore these certifications:


    PRIM&R, SOCRA, ACRP, and HCCA Certification Quick Comparison

    PurposeCostExam Content (Domains)Regulatory and Ethical Frameworks to Review
    PRIM&R: Certified IRB Professional (CIP)Constitutes formal recognition of an IRB professionalโ€™s broad knowledge of IRB functions and expertise about HRPPs.Testing in the US: $425.00 exam fee

    Testing outside the US (internationally): $535.00 exam fee

    $110.00 exam fee cost will be waived if international test takers opt for online-remote proctoring
    1. Human subjects protections
    2. IRB responsibilities
    3. Institutional responsibilities
    CIP exam references and resources
    (Detailed links will be provided below)
    SOCRA: Certified Clinical Research Professional (CCRP)Created as an internationally accepted standard of knowledge, education, and experience by which clinical research professionals will be recognized by the clinical research community.Current members: $395.00

    Non-members: $450.00

    Computer based testing (testing center or home proctoring):
    1. Additional $115 (North America – USA, Canada, Mexico)
    2. Additional $175 countries outside North America
    1. Research study start-up
    2. Research study implementation
    3. Research study closure
    Preparation resources
    (Detailed links will be provided below)
    ACRP: ACRP Certified Professional (ACRP-CP)Formally recognizes clinical research professionals of all types, regardless of their roles or functional activities on the clinical study team. Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.1. Domains
    2. Knowledge statements
    3. Tasks
    Exam content
    (Detailed links will be provided below)
    ACRP: Certified Clinical Research Associate (CCRA)Formally recognizes clinical research professionals with experience monitoring and supervising the conduct and progress of clinical trials on behalf of a sponsor.Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.1. Domains
    2. Knowledge statements
    3. Tasks
    Exam content
    (Detailed links will be provided below)
    ACRP: Certified Clinical Research Coordinator (CCRC)Formally recognizes clinical research professionals with experience coordinating and facilitating clinical trial activities in adherence to GCP, under the direction of a principal investigator.Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.1. Domains
    2. Knowledge statements
    3. Tasks
    Exam content
    (Detailed links will be provided below)
    ACRP: ACRP Medical Device Professional (ACRP-MDP)Formally recognizes clinical research professionals with specialized knowledge in medical device clinical trials.Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.1. Domains
    2. Knowledge statements
    3. Tasks
    Exam content
    (Detailed links will be provided below)
    ACRP: ACRP Project Manager (ACRP-PM)Formally recognizes clinical research professionals with specialized knowledge in project management.Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.1. Domains
    2. Knowledge statements
    3. Tasks
    Exam content
    (Detailed links will be provided below)
    HCCA: Certified in Healthcare Research Compliance (CHRC)Showcase knowledge of relevant regulations and expertise in research compliance processes sufficient to assist the healthcare industry organizations in understanding and addressing legal obligations, and promote organizational integrity through the operation of effective research compliance programs.Current members (SCCE or HCCA): $350.00

    Non-members: $450.00
    Detailed content outline (PDF)Exam resources
    (Detailed links will be provided below)
    HCCA: Certified in Healthcare Compliance (CHC)Showcase knowledge of relevant regulations and expertise in compliance processes sufficient to assist the healthcare industry organizations in understanding and addressing legal obligations, and promote organizational integrity through the operation of effective compliance programs.Current members (SCCE or HCCA): $350.00

    Non-members: $450.00
    Detailed content outline (PDF)Exam resources
    (Detailed links will be provided below)
    HCCA: Certified in Healthcare Privacy Compliance (CHPC)Showcase knowledge of relevant regulations and expertise in privacy compliance processes sufficient to assist the healthcare industry organizations in understanding and addressing legal obligations, and promote organizational integrity through the operation of effective privacy compliance programs.Current members (SCCE or HCCA): $350.00

    Non-members: $450.00
    Detailed content outline (PDF)Exam resources
    (Detailed links will be provided below)
    Table 1: Research and regulatory certifications broken down by certification purpose, cost, exam content, and regulatory/ethical frameworks to review.
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    The Organizations Behind These Certifications

    Public Responsibility in Medicine and Research (PRIM&R)

    PRIM&R is a nonprofit,โ€ฏfounded in 1974 that works to ensure the highest ethical standards in research by:

    • Providing education,
    • Membership, and
    • Other professional resources to the research and research oversight community, including those who work with:
      • Human research protections programs (HRPPs),
      • Institutional review boards (IRBs),
      • Animal care and use programs,โ€ฏand
      • Institutional animal care and use committeesโ€ฏ(IACUCs).โ€ฏ

    You can read more PRIM&R’s mission, values, and membership here: PRIM&R homepage.

    The Society of Clinical Research Associates (SOCRA)

    SOCRA is a non-profit, charitable and educational membership organization incorporated in 1991 committed to providing:

    • Education,
    • Certification, and
    • Networking opportunities to all persons involved in clinical research activities. 

    You can read more SOCRA’s mission, values, and membership here: SOCRA homepage.

    The Association of Clinical Research Professionals (ACRP)

    ACRP is a registered charitable organization whose mission is to promote excellence in clinical research. Their vision ensures that clinical research is performed ethically, responsibly, and professionally everywhere in the world. ACRP is moving the people and practice of clinical research forward by:

    • Being the Most Passionate Advocate for the Clinical Research Profession.
    • Providing the Tools Clinical Research Professionals Need to Build Their Own Career Journeys.
    • Creating Connections through Community.
    • Empowering Organizations to Trust that Their Studies Are in the Hands of Qualified Professionals.
    • Leading the Way for Workforce Development in Clinical Research.

    You can read more ACRP’s mission, values, and membership here: ACRP homepage.

    Health Care Compliance Association (HCCA)

    • Established in 1996, HCCA supports healthcare compliance professionals as part of the overarching mission of SCCE & HCCA, a member-based professional association with more than 19,000 members in over 100 countries.
    • SCCE & HCCA is dedicated to enabling the lasting success and integrity of organizations worldwide by:
      • Promoting high standards in compliance and ethics programs,
      • Nurturing a community of compliance and ethics practitioners, and
      • Offering knowledge-rich educational opportunities.

    You can learn more about each of these organizations below (though only HCCA will be discussed in this post):

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    PRIM&R: Certified IRB Professional (CIP)

    Brief overview

    • Consists of 130 objective, multiple-choice questions, and covers human subjects protection regulations, IRB responsibilities, and institutional responsibilities.
    • Exam length is three hours long and is a computer-based exam.
    • No notes or reference materials are allowed while taking the exam.

    Certification fee

    • Testing in the US: $425.00 exam fee
    • Testing outside the US (internationally): $535.00 exam fee
      • $110.00 exam fee cost will be waived if international test takers opt for online-remote proctoring

    Eligibility requirements (education and employment)

    • Education:
      • None specified.
    • Employment:
      • Two years of full-time, relevant Human Research Protection Program (HRPP) experience, completed within two weeks of the conclusion of the chosen testing period.
      • Relevant HRPP experience must include:
        • Managing HRPP policies and procedures
        • Managing pre-review of IRB materials
        • Managing review of IRB materials
        • Managing exempt study review determinations
        • Managing research protocol approval or reliance
          process
        • Managing regulatory documentation
        • Managing IRB records and databases
        • Facilitating IRB meeting (e.g., ensure quorum, distribute
          meeting materials)
        • Developing and provide education on IRB regulations
          and processes
        • Providing consultation on IRB submission
        • Monitoring for changes in federal regulations and
          guidance
        • Managing review of noncompliance and unanticipated
          problems
        • Managing IRB meeting minutes

    Exam domain breakdown

    • Human subjects protection (29%)
      • Historical background
      • Research ethics
        • Belmont principles
        • International codes and standards
          • Nuremburg Code
          • Declaration of Helsinki
          • ICH GCP-E6
      • Regulatory applicability
        • Common Rule
        • FDA (e.g., human subjects, drugs/biologics,
          devices)
        • Other FDA (e.g., HUD, expanded access,
          emergency use)
        • Agency differences (e.g., DOD, DOJ, NIH)
    • IRB responsibilities (54%)
      • IRB membership and authority
      • Levels of review
      • Types of review
      • Regulatory criteria for approval
      • Informed consent
      • Privacy and confidentiality considerations (e.g., HIPAA, CoC)
      • Vulnerable populations
      • Monitoring and review of reportable events (e.g., unanticipated problems, noncompliance, research misconduct)
      • Meeting minutes
    • Institutional responsibilities (17%)
      • Cooperative research (e.g., reliance, local context, sIRB)
      • Policies, procedures, and IRB Records
      • Conflict of interest (e.g., IRB, researchers, institutional)
      • Regulatory reporting obligations
      • Document management and retention
      • Educational programs

    Resources to review

    FDA Regulations

    OHRP Regulations

    Other Regulations

    Other Agencies
    Privacy and Confidentiality

    Ethical Codes

    Training Modules

    FDA Guidance

    Below is a table of FDA guidance documents with the following keywords: Institutional Review Board, IRB, and Clinical Investigator (as stated within CIP Exam Reference sheet)

    • Further, both draft and final guidance documents have been provided for convenience (as the resource list doesn’t clarify this aspect).
    SummaryDocumentIssue DateGuidance Status
    Institutional Review Boards Frequently Asked Questions: Guidance for Institutional Review Boards and Clinical Investigators02/05/2025Final
    Cancer Clinical Trial Eligibility Criteria: Laboratory Values: Draft Guidance for Industry, IRBs, and Clinical InvestigatorsPDF04/25/2024Draft
    Cancer Clinical Trial Eligibility Criteria: Washout Periods and Concomitant Medications: Draft Guidance for Industry, IRBs, and Clinical InvestigatorsPDF04/25/2024Draft
    Cancer Clinical Trial Eligibility Criteria: Performance Status: Draft Guidance for Industry, IRBs, and Clinical InvestigatorsPDF04/25/2024Draft
    Key Information and Facilitating Understanding in Informed Consent Guidance for Sponsors, Investigators, and Institutional Review BoardsPDF03/01/2024Draft
    Institutional Review Board (IRB) Review of Individual Patient Expanded Access Submissions for Investigational Drugs and Biological Products: Guidance for IRBs and Clinical InvestigatorsPDF09/11/2023Final
    Informed Consent: Guidance for IRBs, Clinical Investigators, and SponsorsPDF08/15/2023Final
    Research Involving Children as Subjects and Not Otherwise Approvable by an Institutional Review Board: Process for Referrals to Food and Drug Administration and Office for Human Research Protections: Draft Guidance for Institutional Review Boards, Investigators, and SponsorsPDF03/30/2023Draft
    Clinical Investigator Administrative Actions – Disqualification: Guidance for Institutional Review Boards, Clinical Investigators, and SponsorsPDF12/01/2022Final
    Ethical Considerations for Clinical Investigations of Medical Products Involving Children: Draft Guidance for Industry, Sponsors, and IRBsPDF09/26/2022Draft
    Information Sheet Guidance for Sponsors, Clinical Investigators, and IRBs Frequently Asked Questions Statement of Investigator (Form FDA 1572) (Revision 1): Draft Information Sheet Guidance for Sponsors, Clinical Investigators, and IRBs Frequently Asked Questions Statement of Investigator (Form FDA 1572) (Revision 1)PDF05/19/2021Draft
    Nonclinical Testing of Individualized Antisense Oligonucleotide Drug Products for Severely Debilitating or Life-Threatening Diseases Guidance for Sponsor-Investigators: Draft Guidance for Sponsor-InvestigatorsPDF04/26/2021Draft
    Certificates of Confidentiality: Guidance for Sponsors, Sponsor-Investigators, Researchers, Industry, and Food and Drug Administration StaffPDF11/13/2020Draft
    Live Case Presentations During Investigational Device Exemption (IDE) Clinical Trials: Guidance for Institutional Review Boards, Industry, Clinical Investigators, and Food and Drug Administration StaffPDF07/11/2019Final
    Impact of Certain Provisions of the Revised Common Rule on FDA-Regulated Clinical Investigations: Guidance for Sponsors, Investigators, and Institutional Review BoardsPDF10/11/2018Final
    Payment and Reimbursement to Research Subjects: Guidance for Institutional Review Boards and Clinical Investigators01/29/2018Final
    Investigational IVDs Used in Clinical Investigations of Therapeutic Products: Draft Guidance for Industry, Food and Drug Administration Staff, Sponsors, and Institutional Review BoardsPDF12/18/2017Draft
    FDA Categorization of Investigational Device Exemption (IDE) Devices to Assist the Centers for Medicare and Medicaid Services (CMS) with Coverage Decisions: Guidance for Sponsors, Clinical Investigators, Industry, Institutional Review Boards, and Food and Drug Administration StaffPDF12/05/2017Final
    Waiver of IRB Requirements for Drug and Biological Product Studies: Guidance For Sponsors, Clinical Investigators, and IRBsPDF10/03/2017Final
    Minutes of Institutional Review Board (IRB) Meetings: Guidance for Institutions and IRBsPDF09/25/2017Final
    Form FDA 3674 – Certifications To Accompany Drug, Biological Product, and Device Applications/Submissions: Guidance for Sponsors, Industry, Researchers, Investigators, and Food and Drug Administration StaffPDF06/07/2017Final
    Factors to Consider When Making Benefit-Risk Determinations for Medical Device Investigational Device Exemptions: Guidance for Investigational Device Exemption Sponsors, Sponsor-Investigators and Food and Drug Administration StaffPDF01/13/2017Final
    Use of Electronic Informed Consent in Clinical Investigations โ€“ Questions and Answers: Guidance for Institutional Review Boards, Investigators, and SponsorsPDF12/15/2016Final
    FDA Decisions for Investigational Device Exemption Clinical Investigations: Guidance for Sponsors, Clinical Investigators, Institutional Review Boards, and Food and Drug Administration StaffPDF08/19/2014Final
    Considerations When Transferring Clinical Investigation Oversight to Another IRB: Guidance for IRBs, Clinical Investigators, and SponsorsPDF05/23/2014Final
    Design Considerations for Pivotal Clinical Investigations for Medical Devices: Guidance for Industry, Clinical Investigators, Institutional Review Boards and FDA StaffPDF11/07/2013Final
    Investigational New Drug Applications (INDs) – Determining Whether Human Research Studies Can Be Conducted Without an IND: Guidance for Clinical Investigators, Sponsors, and IRBsPDF09/10/2013Final
    IRB Responsibilities for Reviewing the Qualifications of Investigators, Adequacy of Research Sites, and the Determination of Whether an IND/IDE is Needed: Guidance for IRBs, Clinical Investigators, and SponsorsPDF08/27/2013Final
    Exception from Informed Consent Requirements for Emergency Research: Guidance for Institutional Review Boards, Clinical Investigators, and SponsorsPDF04/01/2013Final
    Financial Disclosure by Clinical Investigators: Guidance for Clinical Investigators, Industry,and FDA StaffPDF02/01/2013Final
    Safety Reporting Requirements for INDs (Investigational New Drug Applications) and BA/BE (Bioavailability/Bioequivalence) Studies: Guidance for Industry and InvestigatorsPDF12/20/2012Final
    Safety Reporting Requirements for INDs and BA/BE Studies: Guidance for Industry and InvestigatorsPDF12/20/2012Final
    IRB Continuing Review After Clinical Investigation Approval: Guidance for IRBs, Clinical Investigators, and SponsorsPDF02/27/2012Final
    Questions and Answers on Informed Consent Elements, 21 CFR ยง 50.25(c): Guidance for Sponsors, Investigators, and Institutional Review BoardsPDF02/01/2012Final
    Frequently Asked Questions โ€“ Statement of Investigator (Form FDA 1572): Guidance for Sponsors, Clinical Investigators, and IRBsPDF06/04/2010Final
    FDA Inspections of Clinical Investigators: Guidance For IRBs, Clinical Investigators, and SponsorsPDF06/01/2010Final
    Frequently Asked Questions – IRB Registration: Guidance for Institutional Review Boards (IRBs)PDF07/09/2009Final
    Adverse Event Reporting to IRBs โ€” Improving Human Subject Protection: Guidance for Clinical Investigators, Sponsors, and IRBsPDF01/14/2009Final
    Data Retention When Subjects Withdraw from FDA-Regulated Clinical Trials: Guidance for Sponsors, Clinical Investigators, and IRBsPDF10/01/2008Final
    Process for Handling Referrals to FDA Under 21 CFR 50.54 – Additional Safeguards for Children in Clinical Investigations: Guidance for Clinical Investigators, Institutional Review Boards and SponsorsPDF12/01/2006Final
    Guidance on Informed Consent for In Vitro Diagnostic Device Studies Using Leftover Human Specimens that are Not Individually Identifiable : Guidance for Sponsors, Institutional Review Boards, and Food and Drug Administration StaffPDF04/25/2006Final
    Using a Centralized IRB Review Process in Multicenter Clinical Trials: Guidance for IndustryPDF03/16/2006Final
    FDA Institutional Review Board Inspections: Guidance For IRBs, Clinical Investigators, and SponsorsPDF01/01/2006Final
    Frequently Asked Questions About Medical Devices: Guidance For IRBs, Clinical Investigators, and SponsorsPDF01/01/2006Final
    Significant Risk and Nonsignificant Risk Medical Device Studies: Guidance For IRBs, Clinical Investigators, and SponsorsPDF01/01/2006Final
    The Use of Clinical Holds Following Clinical Investigator Misconduct: Guidance for Industry and Clinical InvestigatorsPDF09/02/2004Final
    IRB Review of Stand-Alone HIPAA Authorizations Under FDA Regulations: Guidance for IndustryPDF08/16/2003Final
    Protection of Human Subjects: Categories of Research That May Be Reviewed by the Institutional Review Board (IRB) Through an Expedited Review Procedure: Guidance for Institutional Review Boards and Clinical InvestigatorsPDF11/09/1998Final
    Use of Investigational Products When Subjects Enter a Second Institution: Guidance for Institutional Review Boards and Clinical Investigators01/01/1998Final
    Emergency Use of an Investigational Drug or Biologic: Guidance for Institutional Review Boards and Clinical Investigators01/01/1998Final
    Cooperative Research: Guidance for Institutional Review Boards and Clinical Investigators01/01/1998Final
    Non-local IRB Review : Guidance for Institutional Review Boards and Clinical Investigators01/01/1998Final
    Sponsor – Investigator – IRB Interrelationship: Guidance for Institutional Review Boards and Clinical Investigators01/01/1998Final
    Recruiting Study Subjects: Guidance for Institutional Review Boards and Clinical Investigators01/01/1998Final
    Screening Tests Prior to Study Enrollment: Guidance for Institutional Review Boards and Clinical Investigators01/01/1998Final

    OHRP Guidance

    Certification handbook

    To learn more about this certification, review the link here: CIP Exam Handbook

    SOCRA: Certified Clinical Research Professional (CCRP)

    Brief overview

    • Consists of 130 multiple choice questions.
    • The test questions are designed to be straightforward and easily understood.
    • The questions are reviewed by experts in test question development and SOCRA language representatives for fairness and readability.
    • The exam is updated at least annually to assure it is up-to-date and reflective of the current regulatory environment.

    Certification fees

    • Current members: $395.00
    • Non-members: $450.00
    • Computer based testing (testing center or home proctoring)
      • Additional $115 (North America – USA, Canada, Mexico)
      • Additional $175 countries outside North America

    Eligibility requirements (education and employment)

    • There are three categories based on the level of experience and/or education you have. See: Candidate eligibility.

    Exam domain breakdown

    • Research study start-up (approximately 40 questions)
      • Coordinate the development of initial research study protocol
      • Create or obtain research study documents (e.g., informed consent, essential documents, case report forms, financial disclosure statements)
      • Obtain research study approval from necessary stakeholders (i.e., IRB, research study sponsor, and relevant regulatory authorities)
      • Obtain research study product, related materials, equipment, tools and aids
      • Select research study sites
      • Train research study staff members
      • Evaluate research studyโ€™s compliance with relevant local, state and provincial laws
    • Research study implementation (approximately 50 questions)
      • Execute research study in accordance with the protocol
      • Assure regulatory compliance
      • Manage research study product (e.g., treatment, procedure, medication, medical device, questionnaire)
      • Identify, document & report research study anomalies 
      • Manage subjects
      • Maintain the research study
      • Communicate with research study stakeholders
      • Perform/participate a research study audit
    • Research study closure (approximately 10 questions)
      • Perform/participate a research study closeout visit 
      • Develop & submit research study closure reports
      • Archive/retrieve research study records

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: CCRP Certification Exam Handbook.

    ACRP: ACRP Certified Professional (ACRP-CP)

    Brief overview

    • The exam consists of 125 multiple choice questions that must be answered within 180 minutes.
    • The exam is referenced only to the International Conference on Harmonization (ICH) Guidelines.
    • No other regulatory framework is tested, including country-specific regulations (i.e., FDA or EMA).
    • You can read more about how the exam is developed here: How Are Certification Exams Developed.

    Certification fees

    Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.

    Eligibility requirements (education and employment)

    There are two pathways based on work experience and if a waiver is applicable. You can read about these in detail here: ACRP-CP Certification Eligibility.

    Exam domain breakdown

    • Ethical and Participant Safety Considerations
      • Standard of care vs. clinical research protocol requirements
      • Clinical equipoise vs. therapeutic misconception
      • Content of the key documents ensuring subject protection (e.g., IB, protocol, informed consent documents)
      • Considerations for vulnerable populations
      • Past and current ethical issues in clinical research (e.g., diversity)
      • Risks vs. benefits in the selection of research subjects
      • Unblinding procedures
      • Confidentiality and privacy
      • Elements and process of informed consent/assent
      • Protocol deviation/violation identification, documentation, and reporting processes
      • Recruitment and retention plan/strategies
      • Safety monitoring and reporting
      • Subject discontinuation criteria/procedures
      • Conflict of interest in clinical research
      • Fraud and misconduct
    • Clinical Research Standards and Guidelines
      • Stakeholders and regulatory institutions and frameworks in clinical research
      • Phases of clinical research
      • Regulatory reporting requirements (e.g., pre- and post-approval, safety)
      • Standards for handling hazardous goods, materials, and biological samples
      • Audit and inspection processes (preparation, participation, documentation, and follow-up)
      • IRB/IEC role, composition, purpose, and reporting requirements
      • Protocol submission, approval, and amendment processes
      • Efficacy and safety evaluation milestones (e.g., interim analysis result, DSMB review)
    • Clinical Trial Operations (GCPs)
      • Conduct, documentation, and management of clinical trials
      • Study staff roles, training, qualifications, and delegation of responsibilities
      • Control, storage, and dispensation of investigational products/devices
      • Adverse event classification, reporting, and management
      • Study reporting requirements (e.g., SAEs, deviations, INDs, IRB)
      • Study monitoring
      • Audits and inspections
      • Protocol/GCP deviation identification and management
      • IRB/IEC requirements such as submission, review, and approval of documents
      • Corrective and preventive action (CAPA) processes
      • Source data review and verification
      • Site selection activities
      • Principal investigator responsibilities
      • Roles of various clinical trial entities (e.g., CROs, sponsors, regulatory authority)
      • Site initiation, maintenance, and closeout activities
    • Study and Site Management
      • Quality management activities in the conduct of clinical research
      • Responsibilities and obligations involved in the conduct of a clinical trial
      • Oversight requirements of PIs, sponsors, contract research organizations (CROs), and regulatory authorities
      • Contractual agreements (e.g., budgets, clinical trial agreement)
      • Maintenance and use of equipment and supplies
      • Investigational product/device accountability and documentation requirements
      • Investigational product/device reference materials (e.g., Investigator brochure, instructions for use, user manual)
      • Non-compliance management
      • Sample collection, storage, disposal, and shipment requirements
      • Assessment of subject compliance
      • Study evaluation for feasibility
      • Record retention and destruction practices and requirements
      • Essential documents for the conduct of a clinical trial (e.g., trial master file)
    • Research Design and Data Management
      • Clinical trial design (e.g., double-blind, cross-over, randomization)
      • Elements of a protocol
      • Elements and purpose of an Investigational Brochure (IB) and Instructions for Use
      • Rationale for subject eligibility requirements
      • Study objectives, hypotheses, and end points/outcomes
      • Basic concepts of biostatistics and informatics in research
      • Flow of data throughout clinical research
      • Data collection, correction, and queries (e.g., electronic data capture, audit trails)
      • Data quality systems and privacy principles
      • Study documentation practices (ALCOA-C)

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: ACRP Certification Handbook.

    ACRP: Certified Clinical Research Associate (CCRA)

    Brief overview

    • The exam consists of 125 multiple choice questions that must be answered within 180 minutes.
    • The exam is referenced only to the International Conference on Harmonization (ICH) Guidelines.
    • No other regulatory framework is tested, including country-specific regulations (i.e., FDA or EMA).
    • You can read more about how the exam is developed here: How Are Certification Exams Developed.

    Certification fees

    Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.

    Eligibility requirements (education and employment)

    There are two pathways based on work experience and if a waiver is applicable. You can read about these in detail here: ACRP-CP Certification Eligibility.

    Exam domain breakdown

    • Scientific Concepts and Research Design
      • Elements of a protocol
      • Elements of an Investigational Brochure (IB) and/or investigational device use (instructions for use)
      • Rationale for participant eligibility requirements
      • Rationale for trial design
      • Study design characteristics (e.g., double-blind, crossover, randomized))
      • Study objective(s) and end points/outcomes
      • Use of comparator or control product in study design
      • Treatment assignments (e.g., randomization, open label, registries)
      • Stages of product development
    • Ethical and Participant Safety Considerations
      • Adverse events definitions/classification, documentation, and reporting (e.g., SAE, AESI, SUSAR)
      • Blinding/unblinding procedures
      • Elements of eligibility required by IRB/IEC
      • Confidentiality and privacy requirements
      • Risks and benefits of the safety profile
      • Elements of the informed consent
      • Informed consent process requirements
      • Protection of human subjects (e.g., IRB/IEC requirements, Declaration of Helsinki, participant compensation)
      • Protocol deviation/violation identification, documentation, and reporting processes
      • Recruitment and retention plan/strategies
      • Safety monitoring
      • Participant discontinuation criteria/procedures
      • Vulnerable participant populations
      • Conflicts of interest in clinical research (e.g., financial for PI or staff, family and site participation in trial)
      • Elements of potential fraud and misconduct
    • Regulatory Requirements
      • IRB/IEC reporting requirements and communication
      • IRB/IEC purpose, role, and composition
      • Protocol and protocol amendment submission and approval processes
      • Regulatory authority reporting requirements and communication (e.g., safety, CSR)
    • Clinical Trial Operations (GCP)
      • Elements of an effective root cause analysis and corrective and preventive action (CAPA) plan
      • Elements of and rationale for monitoring plan(s)
      • Monitoring responsibilities (e.g., purpose, extent, procedures)
      • Principal investigator responsibilities
      • Principles of risk-based monitoring/data governance
      • Project feasibility considerations
      • Responsibilities of various clinical trial entities/personnel (e.g., CROs, sponsors, regulatory authority, data manager)
      • Audits and inspection processes (preparation, participation, documentation, and follow-up)
      • Pre-study and site selection activities
    • Study and Site Management Activities
      • Communication documentation requirements (e.g., phone, email)
      • Equipment and supplies use and maintenance
      • Investigational product/device management (e.g., accountability, dispensing shipment, storage, labeling, and documentation requirements)
      • Processes and management of non-compliance (e.g., IRB, GCP, CFR, protocol)
      • Roles of various clinical trial entities/plan (e.g., medical monitor, vendors, IRB/IEC, sponsor, CRO)
      • Sample/diagnostic collection, shipment, verification, reporting, and storage requirements (e.g., lab, imaging, raters)
      • Participant compliance and responsibilities for study participation
      • Contracts and budgets (e.g., participant compensation, site payments)
      • Management of study site documentation (e.g., ISF/TMF reconciliation)
      • Delegation, qualification, and training of appropriate responsibilities at site
      • Site initiation activities
      • Interim visit activities
      • Site close-out activities
      • Essential document requirements (e.g., Trial Master File, Investigator Site File)
    • Data Quality
      • Data privacy principles and access to site/participant records (e.g., paper vs. EMR)
      • Elements and purposes of data collection tools (e.g., CRF/eCRF, patient reported outcome devices)
      • Elements of and process for data query (e.g., query writing)
      • Purpose of pharmacovigilance (e.g., CIOMS, IDMC/DSMB, safety databases)
      • Record retention and destruction practices and requirements
      • Source data review (SDR) and source data verification (SDV) purpose and process
      • Source documentation requirements and GDP (e.g., ALCOA+)
      • Critical variables and critical processes
      • Impact of efficacy and safety (e.g., interim analysis result, DSMB review)

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: ACRP Certification Handbook.

    ACRP: Certified Clinical Research Coordinator (CCRC)

    Brief overview

    • The exam consists of 125 multiple choice questions that must be answered within 180 minutes.
    • The exam is referenced only to the International Conference on Harmonization (ICH) Guidelines.
    • No other regulatory framework is tested, including country-specific regulations (i.e., FDA or EMA).
    • You can read more about how the exam is developed here: How Are Certification Exams Developed.

    Certification fees

    Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.

    Eligibility requirements (education and employment)

    There are two pathways based on work experience and if a waiver is applicable. You can read about these in detail here: ACRP-CP Certification Eligibility.

    Exam domain breakdown

    • Scientific Concepts and Research Design
      • Elements of a protocol
      • Elements of an Investigational Brochure (IB) and/or investigational device use
      • Elements of and rationale for subject eligibility requirements
      • Rationale for complying with a protocol
      • Statistical principles related to study design (e.g., sample size, screen fail rate)
      • Study design characteristics (e.g., double-blind, crossover, randomized)
      • Study objective(s)
      • Study endpoints/outcomes
      • Rationale for using supplemental/rescue/comparator product in study design
      • Treatment assignments (e.g., randomization, open label, registries)
    • Ethical and Participant Safety Considerations
      • Adverse events classification, documentation and reporting
      • Blinding/unblinding procedures
      • Components of subject eligibility requirements
      • Confidentiality and privacy requirements
      • Elements of the IB related to identifying risks and benefits
      • Elements of the informed consent form
      • Informed consent process requirements (e.g., paper, eConsent, assent)
      • Protection of human subjects including vulnerable subject populations
      • Protocol deviation/violation identification, documentation, and reporting processes
      • Subject recruitment and retention plan/strategies (e.g., social media, digital, print)
      • Safety monitoring and elements of pharmacovigilance and/or product/device vigilance (e.g., CIOMS, IDMC/DSMB, safety databases)
      • Subject discontinuation criteria/procedures
      • Subject safety
      • Conflicts of interest in clinical research
      • Ethical responsibilities including fraud and misconduct
    • Product Development and Regulation
      • Audit and inspection processes (preparation, participation, documentation, and follow-up)
      • Clinical development process (e.g., preclinical, clinical trial phases, device class)
      • Clinical trial registries and requirements
      • Elements of fraud and misconduct
      • IRB/IEC and other regulatory body reporting requirements
      • IRB/IEC role, composition, and purpose
      • Protocol and protocol amendment submission and approval processes
      • Safety reporting requirements
      • Significant milestones in the evaluation of efficacy and safety (e.g., interim analysis result, DSMB review)
    • Clinical Trial Operations (GCPs)
      • Site staff qualifications for delegation of responsibilities, duties, and training requirements
      • Elements of effective corrective and preventive action (CAPA) process(es) and plan(s)
      • Monitoring activities (frequency of visits, data review, and follow-up)
      • Pre-study/site selection criteria and visit activities
      • Principal investigator oversight responsibilities
      • Project feasibility considerations
      • Roles of various clinical trial entities (e.g., CROs, sponsors, regulatory authority)
      • Site initiation and close-out activities
      • Site staff qualifications
      • Study close-out activities
    • Study and Site Management
      • Communication documentation requirements between all study entities
      • Content of contract and study budget
      • Equipment and supplies use and maintenance
      • Investigational product accountability and documentation requirements
      • Study staff training procedures and documentation requirements
      • Investigational product characteristics, labeling requirements, and packaging
      • Investigational product shipment
      • Investigational product storage
      • Non-compliance management
      • Project timelines (e.g., data lock, enrollment period, recruitment/retention)
      • Purpose of and process(es) for protocol compliance
      • Sample collection, processing, shipment, and storage requirements
      • Subject compliance assessment
      • Subject responsibilities for study participation and visit activities
      • Vendor management
    • Data Management and Informatics
      • Data management activities including data privacy
      • Elements and purposes of data collection tools (e.g., eCRF, EDC, IWRS blinding)
      • Elements of and process for data query
      • Reporting requirements for pharmacovigilance and/or product/device vigilance (e.g., CIOMS, IDMC/DSMB, safety databases)
      • Essential Documents for the conduct of a clinical trial (e.g., paper/electronic, trial master file)
      • Record retention, certified copy, and destruction practices and requirements
      • Source data review (SDR) and source data verification (SDV) purpose and process
      • Study documentation practices and requirements (Accurate, Legible, Complete, Original, Attributable, Contemporaneous, Consistent, Enduring, Available (ALCOA+))

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: ACRP Certification Handbook.

    ACRP: ACRP Medical Device Professional (ACRP-MDP)

    Brief overview

    • Consists of 60 multiple choice questions that must be answered within 90 minutes.
    • The ACRP-MDP exam is referenced to the International Conference on Harmonization (ICH) Guidelines and International Organization for Standardization Guideline (ISO) 14155:2011.
    • The exam assesses your proficiency in medical devices related to clinical research.

    Certification fees

    Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.

    Eligibility requirements (education and employment)

    To be eligible for this exam, you must have one of the following ACRP certifications:

    Exam domain breakdown

    The domains, knowledge statements, and tasks can be reviewed in the table provided here: ACRP-MDP Exam Content Outline.

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: ACRP Certification Handbook.

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    ACRP: ACRP Project Manager (ACRP-PM)

    Brief overview

    • Consists of 60 multiple choice questions that must be answered within 90 minutes.
    • The exam is referenced only to the International Conference on Harmonization (ICH) Guidelines.
    • No other regulatory framework is tested, including country-specific regulations (i.e, FDA or EMA).

    Certification fees

    Exam and application fees differ based on time of year (spring versus fall) and the year itself. It is recommended that you review the ACRP Certification Handbook for the most recent fee schedule.

    Eligibility requirements (education and employment)

    To be eligible for this exam, you must have one of the following ACRP certifications:

    Exam domain breakdown

    The domains, knowledge statements, and tasks can be reviewed in the table provided here: ACRP-PM Exam Content Outline.

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: ACRP Certification Handbook.

    HCCA: Certified in Healthcare Research Compliance (CHRC)

    Brief overview

    The examination will be scored on participantsโ€™ responses to 100 of the 120 multiple-choice questions spread across all subject areas.

    Certification fees

    • Current members (SCCE or HCCA): $350.00
    • Non-members: $450.00

    Eligibility requirements (education and employment)

    Requirements vary based on job experience and continuing education units (CEUs). These can be reviewed in greater detail within the specific certification’s handbook: CHRC Candidate Handbook.

    Exam domain breakdown

    You can review the table of the exam content here (which was also highlighted in the summary table at the beginning of this post): Detailed content outline (PDF)

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: CHRC Candidate Handbook.

    HCCA: Certified in Healthcare Compliance (CHC)

    Brief overview

    The examination will be scored on participantsโ€™ responses to 100 of the 120 multiple-choice questions spread across all subject areas.

    Certification fees

    • Current members (SCCE or HCCA): $350.00
    • Non-members: $450.00

    Eligibility requirements (education and employment)

    Requirements vary based on job experience and continuing education units (CEUs). These can be reviewed in greater detail within the specific certification’s handbook: CHC Candidate Handbook.

    Exam domain breakdown

    You can review the table of the exam content here (which was also highlighted in the summary table at the beginning of this post): Detailed content outline (PDF)

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: CHC Candidate Handbook.

    HCCA: Certified in Healthcare Privacy Compliance (CHPC)

    Brief overview

    The examination will be scored on participantsโ€™ responses to 100 of the 120 multiple-choice questions spread across all subject areas.

    Certification fees

    • Current members (SCCE or HCCA): $350.00
    • Non-members: $450.00

    Eligibility requirements (education and employment)

    Requirements vary based on job experience and continuing education units (CEUs). These can be reviewed in greater detail within the specific certification’s handbook: CHPC Candidate Handbook.

    Exam domain breakdown

    You can review the table of the exam content here (which was also highlighted in the summary table at the beginning of this post): Detailed content outline (PDF)

    Resources to review

    Certification handbook

    To learn more about this certification, review the link here: CHPC Candidate Handbook.


    I hope you found this post useful!

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  • How to Write a Clear Biomedical Protocol

    How to Write a Clear Biomedical Protocol

    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 templates from 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:

    1. We went to Google and typed in “IRB Templates”.
      • From here, we only reviewed templates with the following keywords:
        • “Biomedical”
        • “Bioscience”
        • “Medical”
    2. 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
    3. 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
    4. 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
    5. 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
    • Secretaryโ€™s 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 PIโ€™s 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 studyโ€™s 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
    • Outline participant monitoring requirements (e.g., lab tests, imaging, physical exams)

    Participant Population and Recruitment

    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 InfluenceCoercion
    Misusing a position of power to influence others to make a decision they would not normally makeA 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.

    The consent process should outline key information from the investigator that should be provided to participants. The key information here should facilitate the participantโ€™s 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. Letโ€™s 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 participantโ€™s data
    • The scenarios under which they will not be able to delete the participantโ€™s data

    For example, in a clinical trial assessing a new diabetes medication, the following scenarios would apply:

    1. 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
    2. 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:

    1. Potential distress was disclosed in the informed consent process.
    2. 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 benefitsโ€”whether direct (e.g., therapeutic insights for participants) or indirect (e.g., advancing trauma research)โ€”outweigh the study’s risks.

    Direct Benefit and Indirect Benefit

    First, let’s define direct benefit and an indirect benefit:

    Direct BenefitIndirect Benefit
    Refers to a positive outcome that directly results from the intervention being studied and is experienced by the research participants themselvesA 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.

    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”:

    PrivacyConfidentiality
    Refers to the right to control access to ourselves and our personal informationRefers 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 typesโ€”paper, electronic, or multimediaโ€”will 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 studyโ€™s 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!

  • 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!

  • April 2025: RAC Digest

    April 2025: RAC Digest

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators! 200+ blog subscribers and counting!

    Welcome to the RAC Digest!

    RAC stands for “Research Administration and Compliance”.

    The RAC Digest will feature select publications from the previous month from journals related to research administration and research compliance.

    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 started:


    Expanding Roles for Research Administration and Research Development Professionals: A Team Science Coaching Program

    • Addressing Interdisciplinary Challenges:
      • Interdisciplinary research teams often face issues like:
        • Misaligned goals,
        • Leadership struggles, and
        • Communication barriers.
      • The program aims to mitigate these challenges by introducing structured team coaching.
    • Training RA and RD Professionals as Coaches:
      • The initiative trained RA and RD staff to serve as team coaches, equipping them with skills to:
        • Support team formation,
        • Collaboration, and
        • The development of research outputs.
    • Utilization of Team Science Tools:
      • Coaches employed tools informed by the Science of Team Science (SciTS) to facilitate effective team dynamics and project progression.
    • Natural Extension of RA and RD Roles:
      • Many found the coaching role to be a seamless addition to their existing responsibilities, although interpretations varied among individuals.
    • Focus on Teamwork and Taskwork:
      • Coaches addressed both interpersonal dynamics (teamwork) and project-related tasks (taskwork), ensuring comprehensive support for research teams.
    • Support for Diverse and Virtual Teams:
      • The coaching model proved particularly beneficial for teams integrating diverse perspectives and collaborating virtually over extended periods.
    • Implications for Research Administration:
      • The program highlights the potential for RA and RD staff to play a more active role in facilitating interdisciplinary research.
      • This suggests shift towards more integrated support structures within research institutions.

    The Representative Studies Rubric: A Tool for Diversity in Clinical Trials

    • The Representative Studies Rubric (RSR) was created to promote diversity in clinical trials.
      • This 12-item questionnaire that assessed whether protocols included or excluded underrepresented groups such as:
        • People of all ages,
        • Women (cis and trans),
        • Gender nonbinary individuals,
        • People who inject drugs, and
        • Pregnant people.
      • It also evaluated the use of inclusive statistical practices, community engagement, and stigmatizing language.
    • Many current HIV trials still exclude underrepresented populationsโ€”often without justification.
      • The retrospective review of 47 NIH-funded HIV/AIDS trials showed frequent unjustified exclusions of:
        • Transgenders,
        • Gender nonbinary people, and
        • People who inject drugs.
    • Pregnant people are frequently excluded, limiting critical safety and efficacy data.
      • This occurred without clear scientific rationale of exclusion.
    • Only half of the studies included specific enrollment goals for diverse populations.
    • As a result, the NIH-funded HIV/AIDS Clinical Trials Networks mandated RSR use for future protocols to proactively promote diversity.

    If your institution can’t access the publication, you can download the article here: The Representative Studies Rubric: A Tool for Diversity in Clinical Trials

    “Dear Editor, may I speak with you?”

    • Many journals prohibit appeals and limit communication after manuscript rejection, preventing authors from understanding editorial decisions.
    • Factors such as an author’s prestige, institutional affiliation, or editorial board membership can unfairly influence publication decisions.
    • Restricting the number of peer-review rounds can prevent authors from fully addressing feedback and improving their work.
    • There is a call for advocacy for greater editor-author communication to foster fairness and mutual understanding in the review process.
    • Authors should investigate journal policies before submission, while editors should embrace transparent, responsive practices in the process.

    If your institution can’t access the publication, you can download the article here: “Dear editor, may I speak with you?”

    Perceptions of network-level ethics in an engineering research center: Analysis of ethical issues & practices reported by scientific & engineering participants

    • There were significant variations in how authorship was assigned e.g., some labs used structured discussions.
      • A major concern from participants was unequal contributions to the research.
    • Many engineers deferred ethical considerations to biomedical partners, viewing ethics as outside their domain.
    • Ethics and regulatory concerns (e.g., FDA requirements) were not deeply integrated into daily research decisions.
      • Some participants feared over-regulation could suppress innovation.
    • While collaboration was a central goal, early-stage efforts were often informal or idea-based.
    • Participants wanted clearer, network-wide policies on data sharing, authorship, and ethics training.
    • Many participants admitted limited understanding of ethics beyond lab-level compliance expressed desire for more training.

    If your institution can’t access the publication, you can download the article here: Perceptions of network-level ethics in an engineering research center: Analysis of ethical issues & practices reported by scientific & engineering participants

    SPIRIT 2025 Statement: Updated Guideline for Protocols of Randomized Trials

    • SPIRIT 2025 is an updated guideline for writing protocols of randomized trials.
      • The revised checklist within the guidance integrated contemporary issues like open science, patient involvement, and transparency in reporting.
    • Several other items were revised for clarity and completeness such as:
      • Data sharing,
      • Conflicts of interest,
      • Blinding, and
      • Statistical methods.
    • SPIRIT 2025 incorporates elements from CONSORT Harms 2022, SPIRIT-Outcomes 2022, and the TIDieR checklist.

    If your institution can’t access the publication, you can download the article here: SPIRIT 2025 Statement: Updated Guideline for Protocols of Randomized Trials

    Preserving Research Ethics Oversight Amid Decimation of the Research Enterprise

    • The following actions of the Trump administration has threatened the funding and functioning of IRBs:
      • Cutting grants,
      • Capping indirect costs, and
      • Reducing regulatory staff
        • All three of these components are essential for protecting research participants and maintaining public trust.
    • IRBs play a vital, legally mandated role in ensuring ethical conduct in human subjects research.
      • Their effectiveness depends on institutional support and federal guidance.
    • Massive cuts to OHRP and the termination of SACHRP weaken the federal governmentโ€™s ability to enforce ethical standards.

    If your institution can’t access the publication, you can download the article here: Preserving Research Ethics Oversight Amid Decimation of the Research Enterprise

    CONSORT 2025 Statement: Updated Guideline for Reporting Randomized Trials

    • CONSORT 2025 introduces a 30-item checklist for reporting randomized trials. Some new changes included:
      • Reporting on data sharing,
      • Conflicts of interest, and
      • Patient/public involvement.
    • Items from related CONSORT extensions (e.g., on harms, outcomes, nonpharmacological treatments) and guidelines like TIDieR were incorporated.
    • Revisions to existing items emphasize transparency about protocol access and changes made after trial commencement.
    • The checklist aligns more closely with SPIRIT 2025 providing consistent guidance from protocol design to trial reporting.

    If your institution can’t access the publication, you can download the article here: CONSORT 2025 Statement: Updated Guideline for Reporting Randomized Trials

    Generalizability of FDA-Approved AI-Enabled Medical Devices for Clinical Use

    • Only 56% of the 903 FDA-approved AI-enabled medical devices reported clinical performance studies at the time of approval, raising concerns about the depth of evaluation.
    • Fewer than one-third of clinical studies included sex-specific or age-specific data, limiting assessments of device performance across diverse patient populations.
    • Lastly, the study emphasized:
      • The need for continuous post-market monitoring,
      • Improved reporting standards, and
      • Stricter regulatory oversight to ensure safety, effectiveness, and generalizability of AI-enabled devices in real-world clinical settings.

    I hope you found this content useful!

  • Research Compliance Chronicle: April 2025 Edition

    Research Compliance Chronicle: April 2025 Edition

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, and Investigators! 193 blog subscribers and 580 followers on LinkedIn!

    I hope everyone has been doing well! In lieu of the live regulatory reporting I was doing in the past, I have come up with the following newsletter concept:

    Research Compliance Chronicle:

    • At the beginning of each month, I will summarize key regulatory news related to research compliance from the previous month.
      • It can be easy to miss key information in today’s world – especially with the uncertainty in the research realm.
    • Consider this your one-stop shop for “ICYMI regulatory update”!

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

    Time to rewind April 2025:


    Federal agencies

    FDA Announces Plan to Phase Out Animal Testing Requirement for Monoclonal Antibodies and Other Drugs

    • The FDA aims to reduce, refine, or potentially replace animal testing via AI-based computational models.
    • Software models will be used to simulate monoclonal antibodies throughout the human body to predict side effects and drug distribution.
    • Further, the use of lab-grown human โ€œorganoidsโ€ and organ-on-a-chip systems (i.e., mimic human organs) to test drug safety.
    • These techniques should help speed up the drug development process.

    NSF launches new sexual assault crisis helpline for research community

    • This is an anonymous and secure helpline available to:
      • NSF awardees, grantees, scientists, contractors and
      • those affiliated with supporting the mission of NSF,
      • including all those supporting NSFโ€™s mission throughout Antarctica and the Arctic.

    NIH to prioritize human-based research technologies

    • This aligns with the aforementioned FDA initiative to reduce the use of animals in research.
    • NIH intends to establish the Office of Research Innovation, Validation, and Application (ORIVA) within NIHโ€™s Office of the Director.
      • The new office will:
        • Coordinate NIH-wide efforts to develop, validate, and scale the use of non-animal approaches across the agencyโ€™s biomedical research portfolio and
        • Serve as a hub for interagency coordination and regulatory translation for public health protection.

    Presidential actions

    Transparency Regarding Foreign Influence At American Universities

    • The purpose of this policy is to:
      • End the secrecy surrounding foreign funds in American educational institutions,
      • Protect the marketplace of ideas from propaganda sponsored by foreign governments, and
      • Safeguard Americaโ€™s students and research from foreign exploitation.
    • The Secretary of Education shall require complete and timely disclosure by higher education institutions of foreign funding.
      • The Secretary of Education will work with the Attorney General and the heads of other executive departments, agencies, and offices as needed.

    Proposed bills

    H.R.3054 – To require the Director of the Office of Science and Technology Policy to develop a consistent set of policy guidelines for Federal research agencies to address financial instability of graduate researchers and postdoctoral researchers, and for other purposes.

    • Jennifer McClellan reintroduced the Relieving Economic Strain to Enhance American Resilience and Competitiveness in Higher Education and Research (RESEARCHER) Act.
    • The RESEARCHER Act was originally introduced in 2023.
    • A direct quote from the McClellan press release states, โ€œThe RESEARCHER Act would support our young researchers, invest in their scientific and economic contributions, and build the STEM workforce of tomorrow. โ€

    H.R.3043 – To prohibit the use of taxpayer dollars to support animal experimentation in the laboratories of adversarial nations.

    • Lisa McClain and Don Davis introduced the Accountability in Foreign Animal Research (AFAR) Act.
    • According to this press release, this act would prevent U.S. tax dollars from being used to conduct or support research on animals in China, Iran, North Korea, Russia, or other adversarial countries.
    • The bill text can be reviewed here: AFAR Act.

    H.R.2855 – Protecting Medical Research Funding Act

    • I was unable to locate a press release, but the bill was proposed by Timothy Kennedy.
    • The bill proposes to limit the impoundment, transfer, or reprogramming of Federal funds made available for the National Institutes of Health (NIH), and for other purposes.

    H.R.2821 – FDA Modernization Act 3.0

    • According to this press release, Earl โ€œBuddyโ€ Carter proposed a bill to direct the FDA to reduce unnecessary animal testing for drug development.
    • The bill can be reviewed here: FDA Modernization Act 3.0

    I hope you found this post insightful and worth sharing with your colleagues!