Background
The Department of Health and Human Services recently called for public comment on human subjects research protections.
Objective
(1) To assess variability in reviews across Institutional Review Boards (IRBs) for a multisite minimal risk trial of financial incentives for evidence-based hypertension care. (2) To quantify the impact of review determinations on site participation, budget, and timeline.
Design
A natural experiment occurring from multiple IRBs reviewing the same protocol for a multicenter trial (May 2005–October 2007).
Participants
25 Veterans Affairs Medical Centers (VAMCs).
Measurements
Number of submissions, time to approval, and costs were evaluated. We compared patient complexity, academic affiliation, size, and location (urban/rural) between participating and non-participating VAMCs.
Results
Of 25 eligible VAMCs, 6 did not meet requirements for IRB review, and 2 declined participation. Of 17 applications, 14 were approved. This process required 115 submissions, lasted 27 months, and cost close to $170,000 in staff salaries. One IRB’s concern about incentivizing a particular medication recommended by national guidelines prompted a change in our design to broaden our inclusion criteria beyond uncomplicated hypertension. The change required amending the protocol at 14 sites to preserve internal validity. The IRBs that approved the protocol classified it as “minimal risk”. The 12 sites that ultimately participated in the trial were more likely to be urban, academically affiliated, and care for more complex patients, limiting the external validity of the trial’s findings.
Limitations
Because data came from a single multisite trial in the VA, which uses a two-stage review process, generalizability is limited.
Conclusions
Complying with IRB requirements for this minimal risk study required substantial resources and threatened the study’s internal and external validity. The current review of regulatory requirements may address some of the problems.
Primary Funding Sources
Veterans Affairs Health Services Research & Development and National Institutes of Health, National Heart, Lung, and Blood Institute