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HRPP Innovation & Demonstration Initiative

The Michigan Initiative includes two types of process improvements:

  • Innovations - Outright changes to institutional policies, processes or procedures
  • Demonstrations - Temporary changes to policies, processes or procedures that are piloted to ensure that the change reduces administrative burden without increasing risk or adversely impacting subjects' rights or welfare.  

Considerations for Implementing Demonstration Projects

1.  Modification/development of policies, procedures, and IRB materials, including but not limited to:​

  • Standard Operating Procedures
  • Guidance and policy materials
  • Determination letters to inform PIs about additional responsibilities

2.  eResearch system changes/additions, including but not limited to:

  • IRB application and workflow 
  • System notifications (new, reminder)
  • Reporting mechanisms for tracking and monitoring

3.  Training of IRB staff and IRB membership 

4.  Education of PIs and study teams 

5.  Monitoring to assure subject safety and compliance with demonstration partners

6.  Informing AAHRPP when submitting any (re)accreditation materials

U-M Demonstration Status

ORCR assessment (conducted via survey and select interviews) confirmed no increased risk to subjects or non-compliance from the demonstrations.

All U-M demonstrations to date have been adopted as permanent processes covered by HRPP polices. Each IRB determines the extent to which they adopt these processes.

The HRPP Policy Innovation & Demonstration Initiative ("Michigan Initiative") is an ongoing effort to review current U-M human subjects protection polices and procedures to reduce administrative burden and streamline processes for investigators and staff.  The Michigan Initiative focuses on utilizing the flexibility allowed by federal regulations and identifying standards for areas where these regulations do not apply, while maintaining the ethical standards that form the basis for protecting human subjects in research.

Innovations

The University of Michigan Office of Research (UMOR) and the IRBs work together to develop institutional innovations to reduce regulatory burdens. Innovations implemented to date include:

  1. Streamlining the IRB application paths in eResearch for:
    • Secondary use of existing data/records/specimens
    • Exempt human subjects research
    • Activities not regulated as human subjects research
    • Requests for review by a Non-UM IRB
  2. Updating IRB policies regarding staff roles for:
    • Exempt Reviews - authorization for IRB staff to make exempt determinations
    • Scheduled Continuing Reviews - authorization for qualified IRB Health Sciences and Behavioral Sciences (IRB-HSBS) staff to conduct expedited review of non-federally funded research
  3. Implementing U-M guidelines regarding:
  4. Expanding the interpretation of federal exemption category #5 to cover public benefit and service programs sponsored by the State of Michigan 

Demonstrations

Since U-M elects to apply its Federalwide Assurance to only research sponsored by federal agencies that require adherence to 45 CFR 46, we are positioned to create alternative processes and procedures for review of non-federally funded human research through demonstration projects.  

Demonstration project criteria

  1. The research must be determined to pose no more than minimal risk to subjects
  2. The research must not include:
    • Federal sponsorship, including federal training grants
    • FDA regulated components
    • Sponsor or other contractual restrictions requiring adherence to federal regulations for clinical interventions (including clinical behavioral interventions)
    • Prisoners as subjects
    • NIH-issued Certificate of Confidentiality
  3. The project must evaluate the impact of procedural improvements, including the:
    • Compatibility with the current electronic IRB application
    • Ease of training and informing investigators, study teams, and IRB staff
    • Ability to monitor the projects
  4. The project must signify the impact of procedural improvements on the research community, such as:
    • Elimination of regulatory excess that is not protective of human subjects
    • Enhanced regulatory outcomes for minimal risk research
    • No increase in effort required for investigators

Demonstration projects to date

  1. Extended definition for federal exemption #2 (proposed by IRB-HSBS, 2013; adopted by all U-M IRBs)
    Federal exemption category 2 applies to projects involving education tests, surveys, interviews, or observation of public behavior.  It does not allow for any other research intervention in conjunction with the survey, etc., regardless of the risk.  U-M Exemption #2a expands the federal definition to minimal-risk research with adults that involves a non-invasive intervention followed by data collection via survey, interview (including focus groups) or observation. Examples of non-invasive interventions include, but are not limited to: 
    • Reading a story of vignette
    • Playing an electronic game
    • Using a computer program or website
    • Watching a video
    • Using a robot arm or device
    • Being exposed to stimuli, such as color, light or sound (within safe limits) 

  2. Two-year approval periods (proposed by IRB-HSBS, 2007;  adopted by IRB-Flint, 2014; IRBMED, 2015)
    Federal regulations require continuing review of research at least annually, depending on the degree of risk to the subjects. For research projects posing no more than minimal risk to subjects, U-M postulated that lengthening the review period beyond one year was unlikely to increase risks to subjects.
     

  3. Exemption for Analysis of Identifiable Data:  U-M Exemption #7 (proposed by IRB-HSBS, 2007; adopted by all U-M IRBs)
    Federal regulations require annual continuing review for all studies, including minimal risk studies where research activity is limited to analysis of identifiable data. U-M proposed that for research involving no direct interaction or intervention with human subjects, the requirement to submit annual continuing reviews does not enhance subject safety. A new exemption category was created to provide appropriate review and subsequent exemption from regulatory oversight.

Combined anticipated benefits included:

  • Reduction of administrative workload for investigators
  • Reduction of application volume for IRB staff and reviewers
  • Reduced turn-around time for application review (U-M Exception #7)

Questions?

The HRPP encourages members of the research community to suggest new innovations and demonstrations. Contact hrppumich@umich.edu with your ideas.