Conducting Research at Lincoln IRB/HRPP Policies, Procedures & Good Clinical Practices B Kanna MD, MPH, FACP Associate Program Director of Internal Medicine IRB Chairman Associate GME Director for Research Lincoln Medical & Mental Health Center, New York

IRB / HRPP IRB – Institutional Research Review Board HRPP – Human Research participants protection

Guiding Ethical Principles Nuremberg Code of 1947 Declaration of Helsinki, 1964 (last updated in 2004) Belmont Report 1979

Belmont Principles 1) Respect for persons:  Individuals should be treated as autonomous agents (such as providing informed consent);  Persons with diminished autonomy may need additional protections. 2) Beneficence:  Researchers should do all they can to maximize possible benefits and minimize possible harm to their research subjects. 3) Justice:  Researchers must treat participants fairly and equitably  Including the equitable selection of subjects (in terms of who may bear the risks and who may receive the benefits of the research)

Historical facts Second World War camps – Nuremberg Code Hepatitis study Tuskegee study

IRB Regulations 45 CFR* CFR 50; 56; 312; 812 *CODE OF FEDERAL REGULATIONS IRBs are required by federal law to review human research that is either federally funded or subject to FDA oversight.

Functions of the IRB The IRB is an administrative body established to protect the rights and welfare of human research subjects recruited to participate in research activities conducted under the auspices of the institution with which it is affiliated. The IRB has the authority to approve, require modifications in, or disapprove all research activities that fall within its jurisdiction as specified by both the federal regulations and local institutional policy. Research that has been reviewed and approved by an IRB may be subject to review and disapproval by officials of the institution. However, officials may not approve research if it has been disapproved by the IRB

IRB Committee Scientific members Non-scientific members Community members Meets monthly in Lincoln Conducts voting on new studies before approval

IRB review of studies All human research must be reviewed and approved by IRB e.g. Clinical trials; observational studies; chart review studies What do you do if you are not sure ? Contact IRB before you plan any study X 5339 (Nikol Celestine,IRB Administrator)

Initial steps You have an idea for a research study Discuss this with your mentor or research director Prepare a draft protocol Contact IRB Prepare a full protocol and other documents Know what is an IRB review and what happens at the IRB meeting

IRB pre-review Occurs before IRB review Principal investigator and IRB administrator review the protocol and document requirements Type of review is determined Date for IRB review is planned

IRB initial review Types of review: Full; Expedited and exempt Full reviews must be reviewed at IRB meeting Expedited review will be reviewed by the IRB Chair or IRB member Exempt review is determined by IRB – not by the investigator

IRB initial review Full review More than minimal risk Reviewed by an IRB member ( primary reviewer) Submit all documents 2 weeks prior to next meeting Investigator required to present briefly the protocol at the IRB meeting

Documents for Initial review Full protocol Lay summary Consent/Waiver HIPAA/waiver Conflict of Interest CV/HIPAA training & HPPER certificate Contracts/Budgets for funded studies Fliers/brochures, etc

Initial Review Submit all documents to IRB Fill out Application for initial review REASON application system for administrative review and approval

Administrative Review Separate from IRB review Is a LMMHC/HHC requirement REASON application system Review occurs in parallel with IRB review

Deadlines Full review submission: 2 weeks before IRB meeting Expedited review: 1 week before IRB meeting Other reports: As per IRB operating procedures IRB meeting: 2nd Tuesday of every month Approval time: 2-4 weeks

Expedited initial review 45 CFR 46 provides guidelines 9 categories under expedited review Need not be discussed in IRB meetings Approved by IRB Chair or member Still needs administrative review Deadline for submission: 1 week before IRB meeting Approval time: 2- 4 weeks

Initial Approval No study can be started unless final HHC Central Office approval is obtained in written IRB approval is a part of final approval Approval is maximum for 1 year period PI must remember this and submit continued review in 1 year PI will be reminded 1-2 months before end of initial approval period

Continued review All studies that have been reviewed and approved by IRB must be re-reviewed within 1 year Dates are very important A summary of the study must be available If no subjects enrolled – justification to continue study must be made clear CR approval for additional 1 year maximum until study is closed

Additional IRB review An adverse event; unanticipated event must be reported to IRB immediately Document requirements specific for each event Time lines are very important in reporting e.g – loss of data; side effects of rx

Study Closure Must be reported to IRB Study summary and required documents must be submitted Reason for study closure If PI is leaving institution, must be cleared by IRB on the seperation form

IRB Guidelines IRB standard operating procedures OHRP website 45 CFR 46 IRB website IRB Office Research Director /IRB member

IRB templates Initial review: –Application for initial review –COI –HIPAA/Waivers –Consent/Waivers Continued review: –CR application Study closure: –Closure form Adverse events: –AE form –Safety updates form

IRB templates IRB reviewer –Initial review ( Full & expedited) –CR ( Full & Expedited) –Consent review template IRB administrator –Determination of type of review –OHRP tool for audits

IRB information IRB website IRB representative from department IRB Office: –X 5339 –Nikol Celestine, IRB administrator

Old model Institution IRB New model Director Patient Advocates Biosafety Research compliance Radiation Safety Education AO DSMB QA/QI Pharmacy Sponsors Grants & Contracts Chief of Staff Medical Records Public Affairs IRB Investigators Study Coordinators Conflict of Interest Committee Finance Office Clinical managers Subjects

Questions ?