June 14, 2023: IMPACt-LBP and INSPIRE Have Updated Study Snapshots, Ethics and Regulatory Documentation

Updated study snapshots and ethics and regulatory documentation are now available for the IMPACt-LBP and INSPIRE trials, both NIH Pragmatic Trials Collaboratory Trials.

Logo for the IMPACt-LBP NIH Collaboratory TrialIMPACt-LBP transitioned from the planning phase to the implementation phase in August. As part of the transition, the study team reviewed and updated the minutes of their initial consultation with the Ethics and Regulatory Core. The study is a cluster randomized trial evaluating the effect of first-contact patient referral to physical therapists and doctors of chiropractic for the treatment of low back pain. IMPACt-LBP is supported within the NIH Collaboratory under an award from the National Center for Complementary and Integrative Health.

Logo for the INSPIRE NIH Collaboratory TrialINSPIRE joined the NIH Collaboratory at the beginning of its implementation phase. The study team held its initial consultation with the Ethics Regulatory Core to review their approach their approach to consent, data privacy, and the applicability of recent FDA guidance regarding clinical decision support software functions. INSPIRE consists of 2 cluster randomized trials that are using personalized clinical decision support to improve judicious antibiotic prescribing for non–critically ill patients hospitalized with abdominal infections or skin and soft tissue infections. The project is supported within the NIH Collaboratory under an award from the National Institute of Allergy and Infectious Diseases.

May 11, 2023: Article Outlines Key Stakeholder Insights Related to Participant Data Sharing in Pragmatic Trials

Headshot of Dr. Stepanie Morain

A new article from the NIH Pragmatic Trials Collaboratory outlines stakeholder insights and ethical considerations related to sharing deidentified, participant-level data in pragmatic clinical trials. While there are numerous arguments for and against data sharing in the context of pragmatic trials, the report aims to address the gap in documented stakeholder perspectives.

The article was published this month in Learning Health Systems.

The authors, including members of the NIH Collaboratory’s Ethics and Regulatory Core, recruited stakeholders who represented a range of experiences. They then conducted 40 semistructured interviews focused on ethical considerations. The team identified 5 overarching themes after analyzing the interviews: (1) challenges in sharing data collected under a waiver or alteration of consent; (2) conflicting views regarding patient-subject preferences for data sharing; (3) identification of respect-promoting practices beyond consent; (4) concerns about elevated risks or burdens from sharing data; and (5) diverse views about the likely benefits resulting from sharing data.

A key insight was that a “one size fits all” model for promoting broader sharing of data from pragmatic trials is not feasible, and policies must be sensitive to the unique challenges that pragmatic trials present, such as variation among trials.

“Our data indicate unresolved tensions in how to fulfill this expectation for [pragmatic clinical trials],” the authors wrote. “Future work could inform efforts to tailor data-sharing policy and practice to reflect these and other challenges, including sharing experiences from trials that have successfully navigated these tensions.”

Lead author Stephanie Morain and co-authors Juli Bollinger, Kevin Weinfurt, and Jeremy Sugarman are members of the NIH Collaboratory’s Ethics and Regulatory Core. This work was supported within the NIH Pragmatic Trials Collaboratory by a supplemental grant award from the National Center for Complementary and Integrative Health.

Read the full report.

March 23, 2023: AJOB Calls for Peer Commentaries on Ethics in Pragmatic Trials

American Journal of Bioethics cover imageThe American Journal of Bioethics (AJOB) this week issued a call for peer commentaries for a forthcoming special issue on pragmatic clinical trials. Both of the target articles for the special issue are from the NIH Pragmatic Trials Collaboratory’s Ethics & Regulatory Core.

Unlike AJOB‘s typical Open Peer Commentaries, commentaries for the special issue may be written either in response to the 2 target articles or on the topic of pragmatic trials in general. Proposals of approximately 1 paragraph are due Friday, April 7, and should be submitted via the AJOB editorial website.

After evaluating the proposals, the journal’s editorial office will contact authors to inform them of whether their proposal has been selected to be submitted as a full Open Peer Commentary. Invited commentaries will be due Wednesday, April 26. Authors are limited to a single Open Peer Commentary.

Target articles:

  • “Think Pragmatically: Investigators’ Obligations to Patient-Subjects When Research is Embedded in Care” by Stephanie Morain and Emily Largent: Growing interest in embedded research approaches—where research is incorporated into clinical care—has spurred numerous studies to generate knowledge relevant to the real-world needs of patients and other stakeholders. However, it also has presented ethical challenges. An emerging challenge is how to understand the nature and extent of investigators’ obligations to patient-subjects. Prior scholarship on investigator duties has generally been grounded upon the premise that research and clinical care are distinct activities, bearing distinct duties. Yet this premise—and its corresponding implications—are challenged when research and clinical care are deliberately integrated. After presenting three case studies from recent pragmatic clinical trials, we identify six differences between explanatory trials and embedded research that limit the application of existing scholarship for ascertaining investigator duties. We suggest that these limitations indicate a need to account for the implications of usual care and to move beyond a narrow focus on the investigator-subject dyad, one that better reflects the team- and institution-based nature of contemporary health systems.
  • “Do Clinicians Have a Duty to Participate in Pragmatic Clinical Trials?” by Andrew Garland, Stephanie Morain, and Jeremy Sugarman: Clinicians have good moral and professional reasons to contribute to pragmatic clinical trials (PCTs). We argue that clinicians have a defeasible duty to participate in this research that takes place in usual care settings and does not involve substantive deviation from their ordinary care practices. However, a variety of countervailing reasons may excuse clinicians from this duty in particular cases. Yet because there is a moral default in favor of participating, clinicians who wish to opt out of this research must justify their refusal. Reasons to refuse include that the trial is badly designed in some way, that the trial activities will violate the clinician’s conscience, or that the trial will impose excessive burdens on the clinician.

Open Peer Commentaries are typically between 500 and 1500 words and contain no more than 10 references. A guide to writing an Open Peer Commentary is available under the Resources section “Instructions and Forms” on the AJOB editorial website.

February 8, 2023: Goals of Informing and Consenting, This Friday in the Ethics and Regulatory Grand Rounds Series

Headshots of Pearl O'Rourke, Dave Wendler, Miguel Vazquez, and Michael HoThis Friday’s PCT Grand Rounds will feature the next installment of our special series, Ethical & Regulatory Dimensions of Pragmatic Clinical Trials. Pearl O’Rourke, Dave Wendler, Miguel Vazquez, and Michael Ho will present “Informing and Consenting: What Are the Goals?”

The Grand Rounds session will be held on Friday, February 10, 2023, at 1:00 pm eastern.

O’Rourke is the director of human research affairs at Partners HealthCare Systems in Boston and an associate professor of pediatrics at Harvard. She serves as cochair of the NIH Collaboratory’s Ethics and Regulatory Core. Wendler is the head of the Section on Research Ethics in the NIH Clinical Center and a member of the Ethics and Regulatory Core. Vazquez is a professor of internal medicine at UT Southwestern Medical Center and the principal investigator of the ICD-Pieces NIH Collaboratory Trial. Ho is a professor medicine at the University of Colorado and the principal investigator of the Nudge NIH Collaboratory Trial.

Join the online meeting.

This special Grand Rounds series features moderated webinar discussions with panels of experts. The sessions focus on a range of topics, including the ethics of data sharing; ethical and regulatory considerations in the design and conduct of pragmatic trials; pragmatic research involving patients with dementia; and the use of waivers and alterations of consent.

Read the full program.

February 7, 2023: FDA Issues Draft Guidance for Use of Real-World Data in Externally Controlled Trials

The US Food and Drug Administration last week issued draft guidance for the use of “externally controlled clinical trials” to provide evidence of the safety and effectiveness of drugs and biologics. An externally controlled trial uses patient-level data from a source outside the clinical trial—such as a registry, electronic health records, or administrative claims data—to provide a historical or concurrent control group for the study.

Reviewers are asked to submit written comments on the draft guidance by May 2, 2023. Read the draft guidance.

Externally controlled trials can be useful when it would not be feasible or ethical to use an internal control in the study, such as in studies of populations with rare diseases. The FDA issued the draft guidance as part of a series of guidance documents under its Real-World Evidence Program to satisfy a mandate under the 21st Century Cures Act.

February 6, 2023: Postdoctoral Fellowship Available in Ethics and Regulatory Aspects of Pragmatic Trials

Johns Hopkins Berman Institute of Bioethics logoThe Johns Hopkins Berman Institute of Bioethics is accepting applications for its 2023-2024 Postdoctoral Fellowship in the Ethics and Regulatory Aspects of Pragmatic Clinical Trials.

From the announcement:

The Johns Hopkins Berman Institute of Bioethics invites applications for a Postdoctoral Fellowship in the Ethics and Regulatory Aspects of Pragmatic Clinical Trials. This position includes pursuing independent research, working alongside faculty members involved with the ethics and regulatory aspects of large-scale pragmatic clinical trials and participating in the Hecht-Levi Postdoctoral Fellowship in Bioethics.

The postdoctoral fellow is expected to pursue one or more projects addressing the ethics and regulatory aspects of pragmatic clinical trials in collaboration with Berman Institute faculty members. The Fellow will actively engage with the Ethics and Regulatory Cores of the [NIH Pragmatic Trials Collaboratory] and the Pragmatic and Implementation Studies for the Management of Pain to Reduce Opioid Prescribing (PRISM) Resource Coordinating Center.

As a member of the Hecht-Levi cohort of Bioethics Postdoctoral Fellows at the Berman Institute, the Fellow will have access to Berman Institute faculty and resources, including weekly seminars, presentations, discussions with leading academics and policy makers, professional development training, outreach efforts, and teaching opportunities commensurate with experience and background.

Read the full information about the fellowship. Applications will be considered on a rolling basis through April 30, 2023.

January 11, 2023: Ethics and Regulatory Grand Rounds Series Addresses Vulnerable Populations in Pragmatic Trials This Friday

Headshot of Dr. Emily LargentThis Friday’s PCT Grand Rounds will feature the next installment of our special series, Ethical & Regulatory Dimensions of Pragmatic Clinical Trials. Emily Largent will present “Ethical Considerations When Vulnerable Populations are Subjects in Pragmatic Trials.”

The Grand Rounds session will be held on Friday, January 13, 2023, at 1:00 pm eastern.

Dr. Largent is the Emanuel and Robert Hart Assistant Professor of Medical Ethics and Health Policy at the University of Pennsylvania. Her work explores ethical and regulatory aspects of human subjects research as well the social, legal, and ethical considerations that arise when research findings are translated into care.

Join the online meeting.

This special Grand Rounds series features moderated webinar discussions with panels of experts. The sessions focus on a range of topics, including the ethics of data sharing; ethical and regulatory considerations in the design and conduct of pragmatic trials; pragmatic research involving patients with dementia; and the use of waivers and alterations of consent.

Read the full program.

November 9, 2022: Ethics and Regulatory Grand Rounds Series Continues This Friday

Headshots of Stephanie Morain and Kayte Spector-BagdadyThis Friday’s PCT Grand Rounds will feature the next installment of our special series, Ethical & Regulatory Dimensions of Pragmatic Clinical Trials. Stephanie Morain and Kayte Spector-Bagdady will present “Data Sharing and Pragmatic Clinical Trials: Law and Ethics Amidst a Changing Policy Landscape.”

The Grand Rounds session will be held on Friday, November 11, 2022, at 1:00 pm eastern.

Morain is a core faculty member in the Berman Institute of Bioethics and an assistant professor of health policy and management in the Bloomberg School of Public Health, both at Johns Hopkins University. Spector-Bagdady is interim codirector of the Center for Bioethics and Social Sciences in Medicine and an assistant professor of obstetrics and gynecology at the University of Michigan Medical School. Both Morain and Spector-Bagdady are members of the NIH Collaboratory’s Ethics and Regulatory Core.

Join the online meeting.

This special Grand Rounds series features moderated webinar discussions with panels of experts. The sessions focus on a range of topics, including the ethics of data sharing; ethical and regulatory considerations in the design and conduct of pragmatic trials; pragmatic research involving patients with dementia; and the use of waivers and alterations of consent.

Read the full program.

October 19, 2022: Living Textbook Adds New Collection of Ethics and Regulatory Content

Living Textbook Ethics Collection menu buttonThe NIH Pragmatic Trials Collaboratory announced the addition of a new collection in the Living Textbook of Pragmatic Clinical Trials focused on ethical and regulatory aspects of pragmatic trials.

“The Living Textbook is a dynamic, evolving collection of knowledge gained from 10 years of conducting pragmatic clinical trials within the NIH Collaboratory,” said Dr. Kevin Weinfurt, co–principal investigator of the NIH Collaboratory Coordinating Center and editor-in-chief of the Living Textbook. “Our new offering of content focuses on ethics and regulatory issues and will further expand researchers’ ability and capacity to conduct these innovative studies,” he said.

The collection launches with 4 new chapters contributed by members of the NIH Collaboratory’s Ethics and Regulatory Core:

  • Privacy Considerations: Real-world data sources like electronic health records, insurance claims, and patient-reported outcomes are generated for purposes other than research. This chapter examines the privacy considerations for use of real-world data in pragmatic trials from patient, clinician, and healthcare system perspectives by reviewing current regulatory frameworks and highlighting experiences from studies that used real-word data for research.
  • Identifying Those Engaged in Research: Clinical research routinely involves 2 distinct roles: researchers and research participants. But pragmatic trials, as well as other clinical research, can be more complex and may require consideration of additional roles. This chapter describes, in addition to the standard roles of researchers and research participants, the roles of service providers and those affected by the research. Appropriate mechanisms of oversight for each of these groups is summarized.
  • Consent, Waiver of Consent, and Notification: Informed consent, which is one means of upholding the fundamental ethical principle of respect for persons, is codified in human subjects protection regulations. However, the regulations acknowledge that it may be ethically and practically inappropriate to obtain informed consent for some research. This is particularly relevant for pragmatic trials. This chapter reviews regulatory requirements for informed consent, discusses waivers and alterations of consent, and examines mechanisms for notification, with a focus on special considerations for pragmatic trials.
  • Collateral Findings: Collateral findings in pragmatic trials are findings that emerge during the course of the trial that are unrelated to the primary research question but may have implications for the individual patients, clinicians, or healthcare systems from whom or within which research data are collected. This chapter examines the ethical considerations related to the identification and management of collateral findings by describing these findings and how they differ from findings that emerge in other contexts.

Additional content that is in development for the Ethics & Regulatory collection will provide more information about these important aspects of pragmatic research.

Navigate the new collection by using the “Ethics & Regulatory” drop-down menu on any page of the Living Textbook at rethinkingclinicaltrials.org. The drop-down menu appears alongside the menus for the existing collections of “Design,” “Data, Tools & Conduct,” and “Dissemination.”

October 12, 2022: Ethics and Regulatory Grand Rounds Series Continues This Friday

Headshots of Joe Ali, Tanya Matthews, and Leslie CroffordThis Friday’s PCT Grand Rounds will feature the next installment of our special Grand Rounds series, Ethical & Regulatory Dimensions of Pragmatic Clinical Trials. Joe Ali, Tanya Matthews, and Leslie Crofford will present “Responding (or Not) to Signals of Potential Clinical Significance in Pragmatic Clinical Trials.”

The Grand Rounds session will be held on Friday, October 14, 2022, at 1:00 pm eastern.

Ali is an assistant professor of international health at Johns Hopkins University, Matthews is director of human research protections at Kaiser Permanente Washington, and Crofford is professor and chair of medicine at Vanderbilt University. Crofford is also a co-principal investigator for FM-TIPS, an NIH Collaboratory Trial.

Join the online meeting.

This special Grand Rounds series will include an additional 4 moderated webinar discussions with panels of experts. The sessions will focus on a range of topics, including the ethics of data sharing; ethical and regulatory considerations in the design and conduct of pragmatic trials; pragmatic research involving patients with dementia; and the use of waivers and alterations of consent. Read the full program.