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SACHRP Recommendations

SACHRP Recommendations

SACHRP advisory documents were the result of considerable Committee effort, deliberation, and consensus building. Once the Committee reached consensus on an issue, its recommendations were posted online and transmitted by the Chair to the Secretary of Health and Human Services, the Assistant Secretary for Health, and the Director of OHRP for their consideration. The content of these documents was advisory and did not represent the official views or policies of OHRP or the Department of Health and Human Services. Following SACHRP’s termination on March 31, 2025, PRIM&R has undertaken the responsibility of archiving these publicly available materials to ensure continued access for the research oversight community. By maintaining this collection, PRIM&R seeks to preserve the Committee’s valuable contributions and support professionals who rely on SACHRP’s work to inform ethical and regulatory decision-making in human subjects research.

2024 SACHRP Recommendations

October 22, 2024 - Letter to the HHS Secretary SACHRP Recommendation on Assessment Considerations on Uninformative Research

July 25, 2024 - Letter to the HHS Secretary SACHRP Recommendations for the Ethical Review and Inclusion of LGBTQI+ Participants in Human Subjects Research

March 21, 2024 - Letter to the HHS Secretary SACHRP Recommendation on Interpretation of the Best Interests Standard for the Retention of Subjects in Human Subjects Research that Has Been Suspended or Terminated

2023 SACHRP Recommendations

October 25, 2023 - Letter to the HHS Secretary SACHRP Recommendation on GAO-23-104721, INSTITUTIONAL REVIEW BOARDS: Actions Needed to Improve Federal Oversight and Examine Effectiveness

July 31, 2023 - Letter to the HHS Secretary SACHRP Recommendations on OHRP Draft Guidance “Frequently Asked Questions: Limited Institutional Review Board Review and Related Exemptions”

SACHRP Recommendations on “Decentralized Clinical Trials for Drugs, Biological Products, and Devices - Guidance for Industry, Investigators, and Other Stakeholders”

April 4, 2023 Letter to the HHS Secretary SACHRP Recommendations on Draft Guidance “Ethical Considerations for Clinical Investigations of Medical Products Involving Children Guidance for Industry, Sponsors, and IRBs”

2022 SACHRP Recommendations

October 21, 2022 Letter to the HHS Secretary IRB Considerations on the Use of Artificial Intelligence in Human Subjects Research Recommendations on 87 FR 58733: Protection of Human Subjects and Institutional Review Boards

Recommendations on 87 FR 58752: Institutional Review Boards; Cooperative Research

Use of Social Media by Research Subjects: Ethical and Regulatory Considerations for the Protection of Human Research Subjects

July 25, 2022 Letter to the HHS Secretary A New Interpretation of the “Engaged in Research” Standard Considerations for IRB Review of Research Involving Artificial Intelligence DRAFT Supplemental Information to the NIH Policy for Data Management and Sharing: Protecting Privacy When Sharing Human Research Participant Data Interpretation of the Definition of “Support” in the HHS Regulations Recommendations on the Draft Guidance for Use of Single Institutional Review Board for Cooperative Research

March 17, 2022 Letter to the HHS Secretary NIH Genomic Data Sharing Policy: NIH Request for Public Comments The Protection of Non-Subjects from Research Harm

2021 SACHRP Recommendations

July 22, 2021 - Letter to the HHS Secretary Consideration of the Principle of Justice 45 CFR part 46

March 29, 2021 - Letter to the HHS Secretary Attachment A - IRB Authority to Restrict Use of Data Collected and Developed in Research Attachment B - New Challenges in Interactions among Sponsors, Clinical Trial Sites, and Study Subjects

2020 SACHRP Recommendations

October 26, 2020 - Letter to the HHS Secretary Attachment A -Public Health Authority and Surveillance Activities

August 12, 2020 - Letter to the HHS Secretary Attachment A - NIH Data Sharing Policy Attachment B - Deceased Donor Intervention Research 45 CFR part 46

April 7, 2020 - Letter to the HHS Secretary Attachment A - New Information Provided to Previously Enrolled Research Subjects Attachment A1 - Reconsent Appendix 1 Attachment A2 - Reconsent Appendix 2 Attachment B - Clarifying Requirements in Digital Health Technologies Research

2019 SACHRP Recommendations

November 20, 2019 - Letter to the HHS Secretary

Attachment A - Charging Subjects for Clinical Trial Participation

September 30, 2019 Letter to the HHS Secretary

Attachment A - Addressing Ethical Concerns Offers of Payment to Research Participants

2018 SACHRP Recommendations

November 13, 2018 Letter to the HHS Secretary

Attachment A - Response Off. Inspector Gen. Report, July 7, 2017

Attachment B - Interpretation Revised Common Rule Exemptions

Attachment C -New "Key Information" Informed Consent Requirements

Attachment D - Parental Permission in Research involving Children

Attachment E - Transition Provisions and Informed Consent Req.

Attachment A - Modif. Prev. Approved Expedited List No. 12

Attachment B -Prev.Approved Rec. Implem.EU GDPR (SACHRP Mar.2018)

April 11, 2018 Letter to the HHS Secretary

Attachment A - FAQs Relating to Recommendations on Broad Consent

Attachment B - European Union's General Data Protection Regulations

Attachment C - Updated FAQs on Informed Consent for Use of Biospecimens and Data

Attachment D - Granting Exceptions or Single IRB Review for Multi-Site Research

2017 SACHRP Recommendations

December 12, 2017 Letter to the HHS Secretary

Attachment A - Recommendations on the Expedited Review List

Attachment B - Recommendations on the Interpretation and Application of §_.104(d)(4) the “HIPAA Exemption"

August 2, 2017 Letter to the HHS Secretary

Attachment A - Recommendations on Compliance Dates and Transition Provisions

Attachment B - Recommendations on Benign Behavioral Intervention

Attachment C - Recommendations for Broad Consent Guidance

Attachment D - Recommendations for a Broad Consent Template

Attachment E - Recommendations on FDA draft Real-World Evidence guidance

Attachment F - Recommendations on Reporting Incidental Findings

2016 SACHRP Recommendations

November 2, 2016 SACHRP Letter to the HHS Secretary

Attachment A: Initial Considerations for Single IRB Review: Points to Consider

Attachment B: Recommendations on Regulatory Issues in Cluster Randomized Studies

Attachment C: SACHRP Recommendations on Benchmarking

Attachment D: SACHRP Recommendations on Revisions to “NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules,” Appendix M

Attachment E: Recommendations on OHRP/FDA draft guidance “Institutional Review Board (IRB) Written Procedures: Guidance for Institutions and IRBs"

July 21, 2016 SACHRP Letter to the HHS Secretary

Attachment A: Minimal Risk Informed Consent Models

Attachment B: Return of Individual Research Results

January 5, 2016 SACHRP Letter to the HHS Secretary

Attachment A: Recommendations NPRM

2015 SACHRP Recommendations

November 3, 2015 SACHRP Letter to the HHS Secretary

September 28, 2015 SACHRP Letter to the HHS Secretary

Attachment A: Recommended Guidance on Minimal Risk Research and Informed Consent

Attachment B: Recommendations Regarding Application of the Common Rule to Clinical Data Registries under the Medicare Access and CHIP Reauthorization Act of 2015

Attachment C: Return of Individual Results and Special Consideration of Issues Arising from Amendments of HIPAA and CLIA

April 24, 2015 SACHRP Letter to the HHS Secretary

Attachment A: Human Subjects Research Implications of “Big Data” Studies

Attachment B: Commentary on FDA Draft Guidance, “General Clinical Pharmacology Considerations for Pediatric Studies for Drugs and Biological Products,” released December 9, 2014, docket number FDA-2013-D-1275-0002

Attachment C: SACHRP Comments on FDA draft guidance “Use of Electronic Informed Consent in Clinical Investigations: Questions and Answers”

Attachment D: Recommendations Regarding Return of General Research Results

Attachment E: Recommendations Regarding Research Uses of Newborn Dried Bloodspots and the Newborn Screening Saves Lives Reauthorization Act of 2014

Attachment F: Recommendations Regarding the Draft NIH Policy on the Use of a Single Institutional Review Board for Multi-site Research

February 11, 2015 SACHRP Letter to the HHS Secretary Attachment A: SACHRP Commentary on the FDA Draft Guidance Entitled, "Informed Consent Information Sheet; Guidance for IRBs, Clinical Investigators and Sponsors," released July 15, 2014, docket number FDA-2006-D-0031

2014 SACHRP Recommendations

July 3, 2014 SACHRP Letter to the HHS Secretary

Attachment A: Recommendations on Assurances and Engagement

Attachment B: Recommendations on Certificates of Confidentiality

Attachment C: Recommendations on Regulatory Issues in Cluster Studies

2013 SACHRP Recommendations

December 4, 2013 SACHRP Letter to the HHS Secretary

Attachment A: SACHRP comment regarding the June 4, 2013 FDA Request for Comment relating to the availability of masked and de-identified non-summary safety and efficacy data

May 20, 2013 SACHRP Letter to the HHS Secretary

Attachment A: Recommendation on Changes to Expedited Review Applicability and Categories

Attachment B: Considerations and Recommendations concerning Internet Research and Human Subjects Research Regulations, with Revisions

January 10, 2013 SACHRP Letter to the HHS Secretary

Attachment A: Consideration of Local Context with Respect to Increasing Use of Single IRB Review

Attachment B: Comments on OHRP and FDA Draft Guidance Documents Regarding IRB Transfers

Attachment C: Investigator Responsibilities

Attachment D: Informed Consent and Waiver of Consent

2012 SACHRP Recommendations

March 30, 2012 SACHRP Letter to the HHS Secretary

Attachment A: Recommendation on Applicability of FDA Regulations for IRBs

Attachment B: Recommendation on Single Patient Treatment Use

Attachment C: Recommendation on Protocol Deviations

Attachment D: Recommendation Regarding Oversight of Research Misconduct and Regulatory Noncompliance

2011 SACHRP Recommendations

October 13, 2011 SACHRP Letter to the HHS Secretary: SACHRP ANPRM Comments - Final Attachment - ANPRM Biospecimen Minority Report Final

October 13, 2011 SACHRP Letter to the HHS Secretary: Recommendations from SAS & SOH

Attachment A: Approved by SACHRP July 20, 2011 - Guidance on Applying the Regulatory Requirements for Research Consent Forms: What Should and Should Not be Included?

Attachment B: Approved by SACHRP July 20, 2011 - SACHRP Recommendation regarding definition of a minor change in research under 45 CFR 46 and 21 CFR 56

Attachment C: Approved by SACHRP July 20, 2011- SACHRP Recommendation regarding application of 45 CFR 46 and 21 CFR 56 to early processes in research, such as identifying potential subjects, contacting subjects and recruiting subjects

Attachment D: FAQ's Terms and Recommendations on Informed Consent and Research Use of Biospecimens

August 5, 2011 SACHRP Letter to the HHS Secretary (Including recommendations and FAQ's on the topic of parental permission, child assent, and documentation of informed consent) August 5, 2011 SACHRP Letter to the HHS Secretary (Including comments regarding request for Comments on Human Subjects Protections in Scientific Studies) August 5, 2011 SACHRP Letter to the HHS Secretary (Including recommendations on HIPAA/HITECH Notice of Proposed Rulemaking) January 24, 2011 SACHRP Letter to the HHS Secretary: Recommendations Involving Informed Consent and Biospecimens, IRB Membership and Definition of Non-scientist

Attachment A: FAQs, Terms and Recommend. on Informed Consent

Attachment B: Recommendation on IRB Membership and Definition of Non-scientist under 45 CFR 46 and 21 CFR 56

2010 SACHRP Recommendations

November 23, 2010 SACHRP Letter to HHS Secretary on HITECH Proposed Rule

Attachment A: SACHRP Models of Compound Authorization

March 24, 2010 SACHRP Letter to HHS Secretary: Recommendations regarding IRB accountability, establishing SACHRP Subcommittee on Harmonization, Financial Conflicts of Interest, IRB member training

2009 SACHRP Recommendations

July 15, 2009 SACHRP letter to HHS Secretary

Attachment: Recommendations Regarding Research Involving Individuals with Impaired Decision-making

February 4, 2009 SACHRP referencing OHRP resources, and socio-behavioral research in subpart B

2008 SACHRP Recommendations

September 18, 2008 SACHRP letter to HHS Secretary: Recommendations regarding regulatory exemptions, institutional responsibilities, tribal authority, research in disaster situations, review of the human subjects protection system

Attachment: Institutional official responsibilities - draft example of guidance to be developed

January 31, 2008 SACHRP letter to HHS Secretary: Recommendations related to waiver of informed consent and interpretation of “minimal risk”

Appendix: Understanding Minimal Risk

2007 SACHRP Recommendations

June 15, 2007 SACHRP letter to HHS Secretary: Recommendations related to the training of individuals involved in the review, oversight, or conduct of human subjects research

Response letter from the Secretary

March 14, 2007 SACHRP letter to HHS Secretary: Recommendations regarding continuing review and expedited review of research by IRBs

Response letter from the Secretary August 8, 2007 Response letter from Secretary

2006 SACHRP Recommendations

November 9, 2006 SACHRP letter to HHS Secretary on Children's Research

Appendix A: Recommendations relative to research involving children

2005 SACHRP Recommendations

July 28, 2005 SACHRP Chair Letter to HHS Secretary Regarding Recommendations

Appendix A: Who is a “prisoner” under Subpart C, Research Protections for the “Subsequently Incarcerated,” identification of prisoner representative, prisoner representative on IRBs in multi-site studies

Appendix B: Recommendations regarding risk in research involving children

2004 SACHRP Recommendations

September 27, 2004 SACHRP chair letter to HHS Secretary on HIPAA - Health Insurance Portability and Accountability Act

Appendix A: Research disclosures should be exempted from the accounting

Appendix B: Reconsider the de-identification standard, reduce the number of data categories, and focus on safeguards in recording and publishing data

Appendix C: Clarify that the February 2004 Guidance addresses only what is permissible under the HIPAA Privacy Rule not a "best practices" standard for recruitment methods

Appendix D: Application of the Privacy Rule to research databases and repositories needs further refining to align it with existing Common Rule requirements

Appendix E: HIPAA's compound authorization requirements elevate form over substance, confuse subjects, and diminish the informed nature of their consent and authorization

Appendix F: Administrative burden of IRB waiver of the authorization requirement for research not required to receive IRB review is unnecessary

Appendix G: HIPAA's transition provisions exempting research where informed consent was obtained are not helpful

Appendix H: Clarify in guidance that IRB alteration of HIPAA's authorization requirement may be sought and granted for international research

Appendix I: Clarify scope of the public health reporting exception

Response from HHS Secretary to September 27, 2004 letter

Summary Table of Recommendations on the HIPAA Privacy Rule

July 8, 2004 SACHRP Letter to HHS Secretary on Children's Research

Appendix A: Algorithm for Subpart D Analysis (45 CFR 46 and 21 CFR 50)

Appendix B: Non-FAC Open Panel Model Guidelines

Appendix C: OHRP Procedures for a 407 Panel Process for Multi-Site Research Response from HHS Secretary to July 8, 2004 letter


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