Profile of Institutional Review Board Characteristics Prior to the 2019 Implementation of the Revised Common Rule

Sandra H. Berry, Dmitry Khodyakov, David Grant, Alexandra Mendoza-Graf, Elizabeth Bromley, Gina Karimi, Barbara Levitan, Karin Liu, Sydne J. Newberry

ResearchPublished Jul 31, 2019

The United States adopted the Common Rule in the 1970s to protect human subjects in research, and research organizations created institutional research boards (IRBs) to ensure the protection of human research participants. A set of proposed changes to the Common Rule was first proposed in 2011 and eventually adopted in 2019.

To assess possible changes in attitudes about IRBs as the Revised Common Rule takes effect, a baseline is needed. This report details the results of surveys of IRB chairs, administrators, and members, as well as principal investigators, to obtain baseline information on their demographics and their attitudes about their IRB's efficacy and efficiency and the likely effects of proposed changes in the Revised Common Rule. Where possible, the authors also compare the survey results with the 1998 Bell Report, which used a similar survey to evaluate IRBs' perspectives on the protection of human subjects.

Key Takeaways

The landscape of IRBs is extensive and varied

  • There is considerable variation in IRB sizes and resources, suggesting wide variation in the ability of IRBs to fully understand and operationalize complexity in the regulations and guidance for implementing change.
  • Many IRBs have taken on or have been assigned additional roles within their institutions, beyond protection of human subjects. In many institutions, the IRB review process provides a convenient checkpoint for ensuring that other kinds of review occur.
  • IRB chairs, administrators, and members are very satisfied with their performance in terms of protecting the rights and welfare of human subjects.
  • Most IRB chairs, administrators, and members reported that they were at least somewhat familiar with the Revised Common Rule, which was scheduled to go into effect in January 2019, and most administrators said that they were extremely or very familiar with it.
  • There was disagreement among survey respondents about whether proposed changes to the IRB review process would positively or negatively affect the scientific quality of research. This likely reflects varying beliefs regarding the role of IRBs in assessing scientific quality versus the quality of human subjects protections afforded by the study design.

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Berry, Sandra H., Dmitry Khodyakov, David Grant, Alexandra Mendoza-Graf, Elizabeth Bromley, Gina Karimi, Barbara Levitan, Karin Liu, and Sydne J. Newberry, Profile of Institutional Review Board Characteristics Prior to the 2019 Implementation of the Revised Common Rule. Santa Monica, CA: RAND Corporation, 2019. https://www.rand.org/pubs/research_reports/RR2648.html.
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