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1 UCSF Program in Medical Ethics, University of California, San Francisco, San Francisco, Calif
2 Office for Human Research Protections, US Department of Health and Human Services, Washington, DC
CORRESPONDING AUTHOR: Leslie E. Wolf, JD, MPH, UCSF Program in Medical Ethics, 521 Parnassus Ave, Suite C-126, San Francisco, CA 94143-0903, lwolf{at}medicine.ucsf.edu
PURPOSE This article explores the challenges that practice-based research networks (PBRNs) face with respect to the regulatory requirements for institutional review board (IRB) review and the protection of human subjects in research.
METHODS We used a regulatory and literature review, our previous research involving PBRN researchers, and our experience to identify issues in regulatory compliance and human subjects protections that present challenges to PBRNs and to suggest possible responses.
RESULTS We identified 3 challenges that PBRNs face with respect to regulatory compliance and human subjects protections. First, ensuring compliance with federal regulations governing human subjects research across all participating practices may be difficult. Clinicians may be unfamiliar with the regulatory requirements and may not have access to an IRB that can provide the required protocol review; moreover, different IRBs may impose inconsistent requirements. Second, conducting research in the practice setting presents unique issues regarding identification of human subjects, consent, and confidentiality. Finally, the use of electronic databases across practices for research raises concerns about how to respect the wishes of participants when combining data and how to maintain confidentiality of data.
CONCLUSIONS PBRN research makes unique contributions to the clinical evidence base by collecting data in community settings where most clinical care is provided. Such research, however, also presents unique challenges to human subject protections and regulatory compliance. Addressing these challenges is necessary to maintain public trust in and support for PBRN research. With careful planning, these ethical and regulatory challenges can be overcome.
Key Words: Practice-based research • ethics committees, research • institutional review boards • research subjects • legislation, medical • public policy
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