["This is Not at All Foreseeable from the Outset" - Research Ethics in Qualitative Health Services Research: A Survey of Researchers]

BACKGROUND

Health services research is multidisciplinary and involves the use of a plurality of research methods. Medicine as a discipline serves as an important reference, also in terms of addressing ethics issues in research. At the same time, however, the highly formalized ethical reviews common in medicine, are controversial within the social sciences, especially among qualitative researchers. So far, little is known about which research ethics issues arise in qualitative health services research.

METHODS

In summer 2019, an online survey was conducted among health services researchers on two main topics: a) research ethics issues in qualitative health services research and b) experiences with the ethics review procedures. The questionnaire contained ten open questions; the responses were analyzed for content. The first topic (ethical issues) is addressed within this article.

RESULTS

A total of 73 researchers with heterogeneous professional background and an average of more than seven years of work experience in health services research participated in the survey. The following were reported as central research ethics issues: a) legitimacy and anticipation of ethical challenges in the planning of research, b) field access, consent and burdens during data collection, c) anonymization and data protection in data processing, d) data analysis, e) publication of results and data and f) general topics such as central principles and goals of research as well as the role of researchers. The main formats for dealing with these issues were exchange and consultation as well as referring to texts and regulations.

CONCLUSIONS

On the one hand, the data documents typical central research ethics questions that researchers are confronted with in the context of qualitative health services research; on the other hand, they also point to gaps and less considered topics. A systematizing ethical reflection could take up these findings in order to develop health services research-specific principles and strategies for handling research ethics issues.

Seeking Approval from Universities to Research the Views of Their Staff. Do Gatekeepers Provide a Barrier to Ethical Research?

A "gatekeeper" controls access to an organization; "gatekeeper approval" is often needed before external research can take place within an organization. We explore the need for gatekeeper approval for research with university staff employing, as a case study, a project which collected data in Australia. This case study addresses known issues, seemingly rarely addressed in the literature. The Human Research Ethics Committee (HREC)'s requirement for approval from individual universities to approach their staff brought significant consequences, exacerbated by the lack of university procedures for such approvals. Simultaneously, since invitations could legitimately be distributed via other avenues, such approval was superfluous. We recommend the HREC's blanket requirement for institutional approval instead be considered on a case-by-case basis depending on the risk of the research, and perhaps waived for low-risk research where participants are able to provide informed consent, and that universities establish processes to deal with requests from external researchers.

The ethics of facing the Other in suicide

Despite a plethora of existing literature on the topic of suicide, very little attention has been given to research ethics in practice in research on suicide. When suicide research does pay attention to the ethical issues researchers are likely to face, the focus is on the roles institutional human ethics review committees fulfil to ensure ethical conduct in all stages of research. In response to this problem, this article focuses on the philosophical relationship between qualitative methodology and research ethics in the context of researching queer youth suicide. In so doing, I draw on my experiences of interviewing gender-and sexually diverse young people about their familiarity with suicide. These experiences are based on a qualitative pilot study I conducted on queer youth suicide, which used the unstructured interview technique to collect data. Drawing on the works of Emmanuel Levinas and Judith Butler, I examine what it means to face the alterity of the suicidal 'Other', and what this facing entails in terms of research ethics as relational. I argue that facing reveals not only myself as more vulnerable than I anticipated, but also the suicidal 'Other' as agentic instead of only vulnerable and at-risk of suicide.

Modeling Ethics: Approaches to Data Creep in Higher Education

Though rapid collection of big data is ubiquitous across domains, from industry settings to academic contexts, the ethics of big data collection and research are contested. A nexus of data ethics issues is the concept of creep, or repurposing of data for other applications or research beyond the conditions of original collection. Data creep has proven controversial and has prompted concerns about the scope of ethical oversight. Institutional review boards offer little guidance regarding big data, and problematic research can still meet ethical standards. While ethics seem concrete through institutional deployment, I frame ethics as produced. Informed by my ethnographic research at a large public university in the U.S., I explore ethics through two models: ethics as institutional procedures and ethics as acts and intentions. The university where I conducted fieldwork is the development grounds for a predictive model that uses student data to anticipate academic success. While students consent to data collection, the circumstances of consent and the degree to which they are informed are not so apparent, as many data are a product of creep. Drawing from interviews and participant observation with administrators, data scientists, developers, and students, I examine data ethics, from a larger institutional model to everyday enactments related to data creep. After demonstrating the limits of such models, I propose a remodeling of ethics that draws on recent works on data, justice, and refusal to pose generative questions for rethinking ethics in institutional contexts.

How ethics committees and requirements are structuring health research in the Philippines: a qualitative study

BACKGROUND

The last few decades have seen the rising global acknowledgment of the importance of ethics in the conduct of health research. But research ethics committees or institutional review boards (IRBs) have also been criticized for being barriers to research. This article examines the case of the Philippines, where little has been done to interrogate the health research and IRB culture, and whose circumstances can serve as reflection points for other low- and middle-income countries.

METHODS

Semi-structured interviews were conducted from July to October 2020 to elicit health researchers' perspectives and experiences regarding IRBs and the ethics approval process in the country, as well as counterpoint narratives from researchers who have also worked for IRBs.

RESULTS

Across the fields of clinical, public health, and social science research, the issue of ethics review revealed itself to be foremost an issue of inequity. IRB processes serve as a barrier for those outside the academe; those belonging to institutions, cities, or entire regions without their own accredited IRBs; and researchers working independently, without ample budget, or on highly specialized topics-more so for non-clinical researchers who must grapple with the primarily biomedical framework of most IRBs. Consequently, the research landscape invariably favors those with the resources to do research, and researches that tend to attract funding.

CONCLUSION

The broader challenge of equity in health research will entail more fundamental reforms, but proximal interventions can be done to make the ethics approval process more equitable, such as enhancing institutional oversight, regulating IRB fees, and enabling a more supportive and welcoming environment for early-career, student, independent, and non-clinical health researchers. This article ends by reflecting on the implications of our findings toward the larger research culture.

Ethics review of big data research: What should stay and what should be reformed?

BACKGROUND

Ethics review is the process of assessing the ethics of research involving humans. The Ethics Review Committee (ERC) is the key oversight mechanism designated to ensure ethics review. Whether or not this governance mechanism is still fit for purpose in the data-driven research context remains a debated issue among research ethics experts.

MAIN TEXT

In this article, we seek to address this issue in a twofold manner. First, we review the strengths and weaknesses of ERCs in ensuring ethical oversight. Second, we map these strengths and weaknesses onto specific challenges raised by big data research. We distinguish two categories of potential weakness. The first category concerns persistent weaknesses, i.e., those which are not specific to big data research, but may be exacerbated by it. The second category concerns novel weaknesses, i.e., those which are created by and inherent to big data projects. Within this second category, we further distinguish between purview weaknesses related to the ERC's scope (e.g., how big data projects may evade ERC review) and functional weaknesses, related to the ERC's way of operating. Based on this analysis, we propose reforms aimed at improving the oversight capacity of ERCs in the era of big data science.

CONCLUSIONS

We believe the oversight mechanism could benefit from these reforms because they will help to overcome data-intensive research challenges and consequently benefit research at large.

Bioethics as Object of Study: Dilemmas of Immanence in Research Ethics Review

This paper explores a dilemma that confronts empirical researchers who are interested in taking the field of bioethics itself as an object of study. Drawing inspiration and data from a recent Institutional Review Board (IRB) process, I discuss my current research, which explores the phenomenon of pediatric biomedical refusal - situations in which young people and their families resist or refuse forms of biomedical treatment for a range of cultural, religious, and political reasons. Standards of informed consent, "best interests", and child protection are central problematics in my research. They are also non-negotiable principles for the ethical conduct of research with human subjects. This presents what I am calling a "dilemma of immanence," in which my research becomes structured and governed by the very same bioethics principles that I seek to interrogate. While many social scientists wrestle with IRB regulations, I argue that this specific dilemma may be particular to empirical bioethics research - particular because our research questions and objectives coincide with the IRB's own mandate.

Perspectives of key stakeholders on essential virtues for good scientific practice in research areas

In contrast to the principle-based approach to ethics and research integrity (ERI) training, which stresses the importance of following moral rules, the virtue-based approach focuses on developing good character traits. This study has aimed to explore what virtues mean in scientific practice and their suitable place in ERI training, using a qualitative approach. Two face-to-face focus group discussions were conducted with 21 participants. Heterogeneous purposive sampling was used to reach participants from different countries, organization types (academia, research, publishing, private sector), scientific disciplines and stages of their scientific careers. Data generated during the focus group discussions were analyzed using a reflexive thematic analysis approach, and three main themes were developed. The first theme addressed the relativity of virtue meanings because the participants differed in their definitions and understandings of the concept of virtue. The second theme referred to the acquisition of virtues through social interactions because participants saw virtues mostly as social constructs acquired through socialization and education. The third theme addressed the differences in the importance of particular virtues in research. Participants felt that particular virtues were more important than others because some of them are necessary for responsible research, and some are not.

Working Through Ethics Review of Big Data Research Projects: An Investigation into the Experiences of Swiss and American Researchers

The employment of Big Data as an increasingly used research method has introduced novel challenges to ethical research practices and to ethics committees (ECs) globally. The aim of this study is to explore the experiences of scholars with ECs in the ethical evaluation of Big Data projects. Thirty-five interviews were performed with Swiss and American researchers involved in Big Data research in psychology and sociology. The interviews were analyzed using thematic coding. Our respondents reported lack of support from ECs, absence of appropriate expertise among members of the boards, and lack of harmonized evaluation criteria between committees. To implement ECs practices we argue for updating the expertise of board members and the institution of a consultancy model between researchers and ECs.

Compliance with National Ethics Requirements for Human-Subject Research in Non-biomedical Sciences in Brazil: A Changing Culture?

Ethics regulation for human-subject research (HSR) has been established for about 20 years in Brazil. However, compliance with this regulation is controversial for non-biomedical sciences, particularly for human and social sciences (HSS), the source of a recent debate at the National Commission for Research Ethics. We hypothesized that for these fields, formal requirements for compliance with HSR regulation in graduate programs, responsible for the greatest share of Brazilian science, would be small in number. We analyzed institutional documents (collected from June 2014 to May 2015) from 171 graduate programs at six prestigious Brazilian universities in São Paulo and Rio de Janeiro, the states that fund most of the science conducted in Brazil. Among these programs, 149 were in HSS. The results suggest that non-compliance with standard regulation seems to be the rule in most of these programs. The data may reflect not only a resistance from scientists in these fields to comply with standard regulations for ethics in HSR but also a disciplinary tradition that seems prevalent when it comes to research ethics in HSR. However, recent encounters between Brazilian biomedical and non-biomedical scientists for debates over ethics in HSR point to a changing culture in the approach to research ethics in the country.

Situational ethics in a feminist ethnography on commercial surrogacy in Russia: Negotiating access and authority when recruiting participants through institutional gatekeepers

In this article, I discuss methodological and ethical dilemmas when recruiting participants with the help of medical and institutional gatekeepers during my ethnographic fieldwork on commercial surrogacy in St Petersburg, Russia. Based on four case studies, I argue for the use of situational ethics. Solid up-front ethics that are approved by institutional advisory boards are important to ensure that the researcher has done their best to identify potential ethical issues prior to data collection and offer deontological safeguards. However, as empirical researchers, we are familiar with the unanticipated that is bound to happen once we commence data collection. In such cases, when the proposed and approved ethical conduct is no longer suited and researchers must make new ethical choices, situational ethics that take the immediate context into consideration are crucial. I further argue that situational ethics must not only be an extension of procedural ethics when the latter are no longer suited but an alternative to procedural ethics in order to make the research empowering, reciprocal and transformative of existing disadvantaging power relations. With this article, I contribute to the growing literature that argues in favour of situational ethics.

Ethics Regulation in Social Computing Research: Examining the Role of Institutional Review Boards

The parallel rise of pervasive data collection platforms and computational methods for collecting, analyzing, and drawing inferences from large quantities of user data has advanced social computing research, investigating digital traces to understand mediated behaviors of individuals, groups, and societies. At the same time, methods employed to access these data have raised questions about ethical research practices. This article provides insights into U.S. institutional review boards' (IRBs) attitudes and practices regulating social computing research. Through descriptive and inferential analysis of survey data from staff at 59 IRBs at research universities, we examine how IRBs evaluate the growing variety of studies using pervasive digital data. Findings unpack the difficulties IRB staff face evaluating increasingly technical research proposals while highlighting the belief in their ability to surmount these difficulties. They also indicate a lack of consensus among IRB staff about what should be reviewed and a willingness to work closely with researchers.

Revisions to the Common Rule: A proposal in search of evidence

Proposed changes to the Common Rule are proffered to save almost 7,000 reviews annually and consequently vast amounts of investigator and IRB-member time. However, the proposed changes have been subject to criticism. While some have lauded the changes as being imperfect, but nevertheless as improvements, others have contended that ‘neither the scientific community nor the public can be confident that improved practices will emerge from the regulatory changes mandated by the NPRM.’

In the present article, I discuss an important aspect that has been overlooked: the question of whether benefits will emerge is demonstrably empirical, yet data upon which to draw conclusions are conspicuous by their absence.

This is thrown into sharp relief when we consider the current environment in which health research is increasingly focused on providing evidence of need or benefit, where there is greater emphasis on evidence-based practice, and when we have the nascent field of implementation science.

Are we ethical? Approaches to ethics in management and organisation research

We are currently witnessing two concurrent trajectories in the field of research ethics, namely the increasingly explicit and formalised requirements of research governance and the ongoing debate around the implicit nature of ethics, which cannot be assured by these methods, and related—for some—the role that reflexivity can play in research ethics. This article seeks to address two questions. First, given the focus of these discussions is often theoretical rather than on practice, how do our colleagues engage with research ethics and what is their ethical position? Second, given reflexivity is typically focused on knowledge construction, to what extent does it influence (if at all) their ethics throughout the research process? Interviews were undertaken with senior colleagues who have established modes of research practice and ethical approaches. Drawing on understandings of reflexivity and ethics, this article explores an ethical subjectivity that was typically reflective and sometimes reflexive and was usually related to personal rather than procedural ethics. It demonstrates contrasting ethical concerns of society, participant and researcher community, and how some researchers saw their ethical obligation as focused on producing meaningful research at the expense of more traditional concerns for the research participant.

Informed Consent-Uninformed Participants: Shortcomings of Online Social Science Consent Forms and Recommendations for Improvement

As informed consent forms continue to lengthen, are these lengthening forms helping to create better informed participants? The aim of this research was to determine whether the length of consent forms affected reading frequency and comprehension, and to provide recommendations on how to improve consent forms in the social sciences so they are more likely to be read. A quasi-experiment was conducted using actual consent forms at two liberal arts schools, one requiring a long form (463 words, n = 73) and one requiring a shorter form (236 words, n = 57). Participants exposed to the shorter form reported fully reading, or at least skimming the form more frequently than those exposed to the longer form. Those exposed to the shorter form also comprehended more of the form's information. The majority of participants indicated consent forms need to be shortened if researchers want future participants to be more likely to read these forms' contents. Additional recommendations are discussed.

Development and oversight of ethical health promotion quality assurance and evaluation activities involving human participants

ISSUE ADDRESSED

This paper considers the role of ethics and ethics review processes in the development of health promotion quality assurance and evaluation activities involving human participants.

CONTENT

The Australian National Health and Medical Research Council (NHMRC) National Statement on Ethical Conduct in Human Research and associated documents provide the framework for the ethical conduct and independent review of research (including quality assurance and evaluation) involving humans in Australia. Identifying the level of risk to which participants may be exposed by participation in quality assurance and evaluation activities is essential for health promotion workers undertaking such activities. Organisations can establish processes other than review by a Human Research Ethics Committee for negligible and low risk research activities. Health promotion quality assurance and evaluation activities often involve negligible and low risk to participants. Seven triggers that indicate the need for ethics review of quality assurance and evaluation activities and a procedural checklist for developing ethical quality assurance and evaluation activities are provided.

CONCLUSION

Health promotion workers should be familiar with the NHMRC's National Statement on Ethical Conduct in Human Research. When ethical considerations underpin the planning and conduct of all quality assurance and evaluation from the very beginning, the activity is the better for it, independent 'ethics approval' can mostly be secured without much trouble and workers' frustration levels are reduced. So what? Health promotion quality assurance and evaluation activities must be ethically justified. Health promotion workers should be familiar with the NHMRC's National Statement on Ethical Conduct in Human Research and should use it when developing health promotion quality assurance and evaluation activities.

Providing ethical guidance for collaborative research in developing countries

Experience has shown that the application of ethical guidelines developed for research in developed countries to research in developing countries can be, and often is, impractical and raises a number of contentious issues. Various attempts have been made to provide guidelines more appropriate to the developing world context; however, to date these efforts have been dominated by the fields of bioscience, medical research and nutrition. There is very little advice available for those seeking to undertake collaborative social science or natural science research in developing countries and what is there tends to be held within disparate sources. Charting the development of a set of ethics documentation for future use by the Ecosystem Services for Poverty Alleviation (ESPA) programme research community, this paper outlines past and present attitudes towards ethics procedures amongst this community and suggests ways in which ethics procedures might be made more relevant and user-friendly to researchers working in this area.

A Scoping Review of Empirical Research Relating to Quality and Effectiveness of Research Ethics Review

Background

To date there is no established consensus of assessment criteria for evaluating research ethics review.

Methods

We conducted a scoping review of empirical research assessing ethics review processes in order to identify common elements assessed, research foci, and research gaps to aid in the development of assessment criteria. Electronic searches of Ovid Medline, PsychInfo, and the Cochrane DSR, ACP Journal Club, DARE, CCTR, CMR, HTA, and NHSEED, were conducted. After de-duplication, 4234 titles and abstracts were reviewed. Altogether 4036 articles were excluded following screening of titles, abstracts and full text. A total of 198 articles included for final data extraction.

Results

Few studies originated from outside North America and Europe. No study reported using an underlying theory or framework of quality/effectiveness to guide study design or analyses. We did not identify any studies that had involved a controlled trial - randomised or otherwise – of ethics review procedures or processes. Studies varied substantially with respect to outcomes assessed, although tended to focus on structure and timeliness of ethics review.

Discussion

Our findings indicate a lack of consensus on appropriate assessment criteria, exemplified by the varied study outcomes identified, but also a fragmented body of research. To date research has been largely quantitative, with little attention given to stakeholder experiences, and is largely cross sectional. A lack of longitudinal research to date precludes analyses of change or assessment of quality improvement in ethics review.

Is research ethics regulation really killing people?

It has been argued that research ethics regulation is leading to loss of life by delaying life-saving research. For example, Whitney and Schneider argue that the delays to the ISIS-2 trial cost 6538 lives. This suggests that there are grounds for rejecting research ethics regulation. However, the methods adopted by critics are flawed because: they conflate regulatory delays with those due to genuine normative requirements that would be present even if the regulatory framework was not; and looking at the impact of regulation on a per-project basis is the wrong metric, because it neglects all the unsuccessful research and because delaying specific projects does not reduce the overall research done by researchers. Research ethics regulation does not lead to substantial losses of life, but we have strong obligations to make it as efficient as possible.

Untangling research and practice: What Facebook’s “emotional contagion” study teaches us

Published in 2014, the Facebook “emotional contagion” study prompted widespread discussions about the ethics of manipulating social media content. By and large, researchers focused on the lack of corporate institutional review boards and informed consent procedures, missing the crux of what upset people about both the study and Facebook’s underlying practices. This essay examines the reactions that unfolded, arguing the public’s growing discomfort with “big data” fueled the anger. To address these concerns, we need to start imagining a socio-technical approach to ethics that does not differentiate between corporate and research practices.

Ethical dilemmas in research in relation to ethical review: An empirical study

The aim of the present article is to contribute empirically derived knowledge about Swedish researchers’ experience of ethical problems, conflicts and dilemmas in their research practice in relation to the ethical vetting legislation and procedure. The study has been carried out using the critical incident technique, with researchers from various disciplines providing examples from their own research practice of problems relating to research ethics. The analysis of the researchers’ responses indicates three phenomena, partly in line with similar studies in other countries: (i) the law of ethical vetting puts limits on the relevant research ethical questions; (ii) it is not possible to anticipate all questions of research ethics; and (iii) there are consequences to the fact that the boards for ethical vetting ignore problems that fall outside the law.

Can significant differences in regulating medical and non-medical research be justified?

It is now typical for human subjects research to be regulated by review by an independent research ethics committee in most jurisdictions. However it is common for countries to opt to only compulsorily regulate medical research while leaving some or all non-medical research either unregulated or only regulated on a voluntary basis. In this paper I will argue, using regulation in the UK as an example, that it is difficult to justify this sharp distinction in practices. While I won't come to any definitive conclusions in this paper as to whether research ought to be regulated compulsorily I will suggest that we would be better to regulate all research, albeit perhaps with a lighter touch than the present UK system if we want to prevent some highly risky research avoiding appropriate regulation. I will examine several arguments to defend making such a distinction; that medical professionals have special moral duties, that medical research has a higher magnitude/frequency of risks and that regulating non-medical research constitutes the inappropriate imposition of the medical model onto non-medical research. Having critiqued these objections I will then discuss the advantages of harmonizing the regulation of research and conclude that there is not a good reason to treat medical and non-medical research as fundamentally different in kind.

The case for ethics review in the social sciences: Drawing from practice at Queen Mary University of London

This article responds directly to an article published in Research Ethics in 2011 where Schrag argued against ethics review for social science and humanities research. He argued that review committees offer solutions in search of a problem, impose silly restrictions and apply inappropriate principles. He suggests that review committees typically lack appropriate expertise and argued that the process harms the innocent. This article refutes these claims and offers a case study of the ethical review process at Queen Mary University of London (QMUL) to offer counter claims. The discussion highlights the way in which the QMUL process is sensitized to the challenges posed by social science and humanities research and is a process that, rather than focusing upon avoiding harm, emphasizes notions of care to both participants and researchers.

Medical dominance within research ethics committees

Qualitative research is reported which explores the perceptions of members of the U.K.'s independent Phase I ethics committees (IECs) about key issues identified following a literature review. Audio-recorded interviews were conducted with ten expert and ten lay members from all IECs except the one to which the lead author was attached. Transcripts were thematically analyzed following a broadly hermeneutical approach. The findings-dealing with such matters as recruitment strategies and length of service; attitudes towards member categories, published ethics guidelines, and the adequacy of insurance; levels of training and views on achieving a recognised level of competence-have an intrinsic interest, but it is when the findings are considered collectively using Freidson's theory of professional dominance that they reveal the influence the medical profession can have in shaping ethics review.

Response to Schrag: What are ethics committees for anyway? A defence of social science research ethics review

Zachary Schrag would like to put the burden of proof for continuation of research ethics review in the Social Sciences on those who advocate for research ethics committees (RECs), and asks that we take the concerns that he raises seriously. I separate his concerns into a principled issue and a number of pragmatic issues. The principled issue concerns the justification for having research ethics committees; the pragmatic issues concern questions such as the effectiveness of review and the expertise of the committee members. I argue that RECs can be justified by their role in improving ethical practice and in reducing wrongs done to research participants. I propose a model of review for doing this, which I think would also address the pragmatic issues raised. I then offer an account of where the UK ethics review system is now and suggest three steps which could improve social science ethics review in the UK and move it in a perhaps more desirable direction.

Social science and ethics review: A question of practice not principle

In his article ‘The case against ethics review in the social sciences’, Schrag asserts that the social sciences should not be subject to ethical review. He recounts a number of examples where ethical review has seemingly failed. He further suggests some alternative models for dealing with ethical review in the social sciences. Finally, he concludes, and we concur, that there is a lack of empirical evidence as to the benefit of research ethics review.

Ethical imperialism or ethical mindfulness? Rethinking ethical review for social sciences

This article is a response to the challenge with which Zachary Schrag concluded his article, ‘The case against ethics review in social sciences’ − that ‘the burden of proof for its continuation rests on its defenders’ (Schrag, 2011). This article acknowledges that there is substance in the charges he lays against some reviews of social sciences and that these are of sufficient quantity and seriousness to justify his challenge. Instead of favouring abandonment of ethical review of social sciences, the author of this article draws upon his experience as Research Ethics Officer for Social Sciences and Law in a research intensive UK university to identify the sources of some of the problems and suggest potential remedies. These start with reviewing the warrant for ethical review as the basis for understanding reviewer’s role concerning the core ethical issues of rigour, respect and responsibility in the proposed research. This response concludes by considering the implications of a warrant for enhancing trust between scientists and the public as the context in which ethical review is only one component in a number of ethical strategies designed to promote ethical mindfulness as integral to social science research.

Rethinking local Institutional Review Board (IRB) review at state health departments: implications for a consolidated, independent public health IRB

A number of unique problems plague human research protection efforts at United States (U.S.) State and Territorial Departments of Health (DOHs) problems which might be ameliorated through a consolidated national or regional, independent, not-for-profit Institutional Review Board (IRB).