AAHRPP/Advance
IRB
bashing
revised, 12/1/2011
Strategies to Address IRB Bashing
Complaints about IRBs have existed
as long as IRBs themselves. But according to directors of human research
protection programs (HRPPs) at three accredited institutions, that doesn’t mean
complaints are inevitable, and it certainly doesn’t mean they should be
ignored.
“IRBs are a fairly easy target
because, to some researchers, the requirements for comprehensive review seem
more like an impediment than a necessity,” says Moira Keane, M.A., C.I.P.,
Executive Director, HRPP, University of Minnesota (U of M), and Chair, AAHRPP Council on Accreditation.
Although much of the criticism is
unwarranted, “some complaints have a lot of merit,” she says. “IRBs need to
listen, to understand when they’re over-interpreting and overstepping and, if
necessary, to make changes.”
Ms. Keane and two of her colleagues
and fellow AAHRPP site visitors—Sharon Friend, M.S., C.I.P., Director, Office
of the HRPP (OHRPP), University of California, Los
Angeles (UCLA),
and Karen Hale, R.Ph., M.P.H., C.I.P., Interim Director, Office of Responsible Research
Practices (ORRP), the Ohio State University―have maintained strong, ethical research programs while
winning over IRB critics. Below they share some strategies for addressing and
preventing IRB bashing.
[bulleted text should link
to the appropriate sections, below]
·
Educate your customers and IRB staff.
·
Streamline
the process whenever possible.
·
Involve
faculty and researchers in decision making.
- Forge and strengthen
connections with researchers.
- Keep pace with the changing research
landscape.
- Make yourselves available to
those who need help.
·
Above
all, listen.
Educate your customers and IRB staff. When faculty and researchers understand the role of the
IRB, they are less likely to criticize. U of M has made a concerted effort to
educate investigators about the regulations governing research with human
participants, the need for often-rigorous review, and the benefits of that
review to the research enterprise. Ohio State views quality improvement visits as
opportunities to educate researchers and IRB staff. “We talk to them about the
process and answer their questions, and they give us a better sense of what’s
going on in the field,” Ms. Hale says.
Both Ohio State and UCLA emphasize
staff education as a way to enhance professionalism and improve customer
service. As a result, at Ohio State, all eligible ORRP staff members have
earned their Certified IRB Professional credentials. “They are well-educated
and able to respond creatively when necessary,” Ms. Hale says.
Streamline the process whenever possible.
The
three institutions use expedited review procedures for studies that pose
minimal risk to research participants. All three have simplified the system for
making minor changes to research proposals. Ohio State has added staff to
improve the turnaround time both for amendments and for expedited review of
research.
Perhaps
the most dramatic changes have been at UCLA, which has seen a marked
improvement in the relationship between researchers and the IRB. When Ms.
Friend joined the OHRPP three years ago, one of the biggest complaints was that
too few protocols were reviewed using an expedited process. Now, of the approximately
4,000 studies submitted for review each year, roughly 2,800 qualify for the expedited
procedure. About 1,000 are reviewed by the convened IRB, and the rest are
exempt.
Involve faculty and researchers in
decision making. When
researchers and IRB staff work together, they gain a better understanding of
each other’s perspectives—and of the reasoning behind policies and procedures. Equally
important, if faculty and researchers are involved in shaping the review
process, their colleagues are more likely to accept it. At UCLA, for example,
when people question the application process, “I can tell them it reflects
faculty input, and they’re less likely to object,” Ms. Friend says.
Forge and strengthen connections with researchers. At all three institutions, involvement works
both ways. IRB staff don’t just extend invitations; they also are quick to
accept them. Ms. Friend set the tone for her staff at UCLA when, on her second
day there, she accepted an invitation to attend a meeting to field complaints
with faculty. At Ohio State, ORRP members often agree to serve on institutional
committees to help build bridges and raise the department’s profile with
faculty. Recently, an ORRP member took part in a committee’s work to implement the
medical center’s new electronic medical records system. The motivation was
twofold: to determine appropriate ways to access medical records for research,
and to connect with other committee members.
Keep pace with the changing research landscape. Part of the IRB’s role is to facilitate research
in a changing environment. “Instead of standing in the way, we try to figure
out how to say yes,” Ms. Hale says. In keeping with that philosophy, Ohio State
is developing policies and procedures for research conducted via the Internet.
The university also is helping to draw up protocols for creating a data and
specimen bank that about 100 institutions engaged in collaborative research
projects will share.
Make yourselves available to those who need help. Many problems between IRBs and investigators can
be prevented by giving assistance upfront. UCLA and Ohio State offer to help
new researchers complete their IRB applications. All three institutions provide
online resources to guide researchers through the review process. All three
also encourage researchers to contact staff, via phone or email, with any
questions.
Above all,
listen. It’s
standard practice at all three
institutions to solicit feedback and respond either with an explanation or with
appropriate action. One of the most striking examples comes from Ohio State,
where researchers want to be able to submit applications online. The university
is developing an electronic submission system, but it will take time. As an
interim solution, the ORRP set up “IRB Submit” to allow researchers to upload
files in any format to a Web-based document management system. “In a perfect
world, we wouldn’t introduce something we weren’t going to stay with,
especially since this will be more work for our office,” Ms. Hale says. “We’re
really doing this just for our customers, until we can offer the ability for
them to complete forms online.”
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