Research governance: regulating risk and reducing harm?

Inclusion of American Indians and Alaskan Natives in Large National Studies: Ethical Considerations and Implications for Biospecimen Collection in the HEALthy Brain and Child Development Study

This manuscript is the result of an interdisciplinary team approach to examine the ethical and cultural considerations of biospecimen collection among American Indian and Alaskan Native (AIAN) communities for the planned Healthy Brain and Child Development (HBCD) study. We begin by reviewing a brief history of the treatment of AIAN communities by the US government and within research studies. Based in part on this history, we highlight the overlapping and intersecting vulnerabilities of AIAN communities, including historical trauma, poverty, lack of healthcare access, and environmental hazards. After consideration of ethical and legal implications, we introduce our recommendations for biospecimen collection/biobanking with AIAN communities in the context of population-representative, multi-site, national studies. We recommend the following key considerations: (1) authentic partnership development; (2) beneficence to the community; (3) culturally respectful research design; (4) meaningful consent to support enrollment and retention; (5) culturally appropriate data management. Adherence to a culturally aware approach for inclusion of underrepresented communities assures external validity in the national studies and increases likelihood of bidirectional value exchange.

A Nationwide Study of Young Adults' Perspectives on Participation in Bereavement Research

Background: Young adults represent a minority in research; they are often considered too young or too old for participation. There is sparse information, especially in bereavement research, regarding how this age group perceives research participation and what they consider beneficial or harmful. Aim: To explore how parentally bereaved and nonbereaved young adults perceive research participation. Design: Qualitative analysis of free-text comments collected in a Swedish nation-wide survey. Setting/Participants: Parentally cancer-bereaved and nonbereaved young adults between 18 and 25 years old living in Sweden. Results: Five categories were identified from the free-text comments, three among the cancer-bereaved: (1) therapeutic to remember the deceased, (2) valuable to help others and improve care, and (3) short-term distressful-long-term beneficial, and two among the nonbereaved: (1) increased reflection and awareness about life, and (2) an opportunity to help others. Conclusions: It is important to invite young adults to participate in bereavement research. The results suggest that potential harm is minimal and that participating in bereavement research can have a beneficial effect on young adults.

Research governance review of a negligible-risk research project: Too much of a good thing?

There are increasing concerns that research regulatory requirements exceed those required to manage risks, particularly for low- and negligible-risk research projects. In particular, inconsistent documentation requirements across research sites can delay the conduct of multi-site projects. For a one-year, negligible-risk project examining biobank operations conducted at three separate Australian institutions, we found that the researcher time required to meet regulatory requirements was eight times greater than that required for the approved research activity (60 hours versus 7.5 hours respectively). In total, 76 business days (almost four months) were required to obtain the necessary approvals, and site-specific processes required twice as long (52 business days/approximately 10 weeks) as primary Human Research Ethics Committee and Research Governance Office processes (24 business days/ approximately five weeks). We describe the impact of this administrative load on the conduct of a one-year, externally-funded research project, and identify a shared set of application requirements that could be used to streamline and harmonise research governance review of low- and negligible-risk research projects.

The Department of Health's research governance framework remains an impediment to multi-centre studies: findings from a national descriptive study

Objective

We describe our experience of using the standard application form, designed to streamline applications for multicentre research, to seek approval from all primary care organizations (PCOs) in England and Wales to undertake a single telephone interview with a health service manager.

Design

We sent applications ( n=316), by email to each PCO, or consortium of PCOs, attaching a completed standard application form, the 15 required documents, and the approval we had been granted by the lead NHS organization. We maintained detailed records of the responses to our application, subsequent correspondence, additional paperwork requested, and time spent on the approval process.

Setting

The UK Research Governance Framework, which regulates all research conducted in health and social care settings.

Participants

All PCOs in England and Wales.

Interventions

None.

Main outcome measures

Time taken to obtain approval to undertake a telephone interview with a health service manager.

Results

We were unable to establish contact with 13 (4%) PCOs. Six months after submitting our application we had received approval from 259/316 (82%) PCOs and were still awaiting a verdict from 41 (13%). The median time to approval was 56 days (IQR 42-72). Overall, an estimated 318 staff-hours were spent completing supplementary forms, providing additional information and chasing up dormant applications.

Conclusions

Recent initiatives to ‘streamline’ research governance approval have failed to address the problems that face researchers undertaking multi-centre studies. There is an urgent need to develop a simpler process that allows low risk research to take place without threatening staff morale and endangering the quality of the research outputs. In the meantime, we advise researchers to allow far greater time than might reasonably be envisioned to obtain research governance approval.

Research with bereaved families

Theoretical debates about the nature of grief and bereavement draw attention to the sensitivity of carrying out research with bereaved people, the possible threats that this may pose and the ethical considerations required to ameliorate potentially damaging outcomes. The authors of this article present a framework for ethical decision-making that has been successfully developed in the context of research with bereaved families. The discussion focuses on application and evaluation of the framework during research with family members who were approached about the donation of a deceased relative’s organs and/or tissues for transplantation. Practical strategies of relevance to the processes of participant recruitment, the interview encounter and follow-up care in the post-interview period are identified and discussed. Concerns about the possible impact of bereavement research are balanced with the views of family members who gave credence to the therapeutic and cathartic benefits of participating in sensitive, death-related research.

Regulation and the social licence for medical research

Regulation and governance of medical research is frequently criticised by researchers. In this paper, we draw on Everett Hughes' concepts of professional licence and professional mandate, and on contemporary sociological theory on risk regulation, to explain the emergence of research governance and the kinds of criticism it receives. We offer explanations for researcher criticism of the rules and practices of research governance, suggesting that these are perceived as interference in their mandate. We argue that, in spite of their complaints, researchers benefit from the institutions of governance and regulation, in particular by the ways in which regulation secures the social licence for research. While it is difficult to answer questions such as: "Is medical research over-regulated?" and "Does the regulation of medical research successfully protect patients or promote ethical conduct?", a close analysis of the social functions of research governance and its relationship to risk, trust, and confidence permits us to pose these questions in a more illuminating way.

Whose Interest? British Newspaper Reporting of use of Medical Records for Research

Objective

There is increasing debate about the ethics of using medical records for research. We aimed to characterize newspaper reporting in this area.

Method

We searched Lexis-Nexis to find newspaper reports about the use of medical records for research from 1 June 2005 to 30 November 2006. Following screening for relevance, we generated a coding scheme and classified articles using this, assisted by QSR N6 software.

Results

Our analysis shows that much newspaper coverage portrays the use of medical records as uncontentious, but also presents ethical arguments for and against such research. Arguments in favour of access to medical records emphasize the public interest and patients’ legitimate expectations that research will be carried out. Arguments against such use emphasize the importance of confidentiality and the violation of rights of privacy. Our findings highlight that there is no single dominant position on the rights and wrongs of access to medical records by researchers. Within newspaper reporting in this area, patient voices are currently noticeable by their absence.

Conclusions

Use of medical records for research raises important ethical questions, in particular regarding the balance between the rights and interests of the individual and the public interest benefits of the research. Understanding how these positions are represented within the mass media is important because the media can inform and influence the public's views and public policy. Empirical research into patient views is needed.

Research governance impediments to clinical trials: a retrospective survey

OBJECTIVE

We sought to evaluate the delays, between-centre variations in practice, and opportunity costs attributable to delays in research governance approval of clinical trials in the United Kingdom.

DESIGN

Retrospective survey.

SETTING

Research and Development (R&D) departments at 50 UK National Health Service hospital trusts governing 57 hospital sites.

PARTICIPANTS

R&D departments participating in four randomized multicentre clinical trials coordinated by our Neurosciences Trials Unit.

INTERVENTIONS

None.

MAIN OUTCOME MEASURES

Median delay between application and research governance approval.

RESULTS

Only half of the R&D departments used the UK online R&D form. Only a single copy of the application was required by 96% of R&D departments. The median delay between application and research governance approval was 44 working days (inter-quartile range 23-80). A delay of >20 working days was incurred by 43 applications (75%), of which 24 (56%) were not explicable and 11 (20%) were attributable to local funding negotiations. Based on the trial randomization rates at each centre, 108 patients (17% of all patients randomized) could have been randomized during the delay, at a crude cost to funding agencies of 53,743 pounds; if a four week delay was deemed acceptable, 75 patients (12% of all patients randomized) could have been randomized during unacceptable delays, at a crude cost to funding agencies of 37,700 pounds.

CONCLUSIONS

The UK research governance system incurs unacceptably long and costly delays for clinical trials. Urgent reform is needed, including rapid design and uniform implementation of the 'bureaucracy busting' measures in Best Research for Best Health.