October 16, 2025: New Article Surveys Landscape of Empirical Ethics Research Related to Pragmatic Clinical Trials

Headshots of Dr. Kayla Mehl, Dr. Stephanie Morain, and Dr. Jeremy Sugarman
Left to right: Kayla R. Mehl, Stephanie R. Morain, and Jeremy Sugarman

A new article from the NIH Pragmatic Trials Collaboratory’s Ethics and Regulatory Core offers a comprehensive scoping review of published empirical ethics research related to pragmatic clinical trials. These trials, which are designed to assess evidence-based interventions in real-world settings, present a variety of unique ethical and regulatory challenges.

The article was published online ahead of print in Learning Health Systems.

The review analyzed 82 published studies of ethics issues that have been explored in the context of pragmatic clinical trials. The authors, led by Kayla Mehl at Johns Hopkins University, identified 22 distinct ethical themes, with the 5 most prevalent being consent and disclosure, risk assessment, trust and transparency, operational burdens and implementation barriers, and the role of engagement.

  • Consent and disclosure: Traditional written informed consent is often impractical in pragmatic trials, prompting the exploration of alternative approaches such as opt-out or general notification.
  • Risk assessment: Pragmatic trials present challenges in risk assessment, particularly regarding how “minimal risk” is defined and communicated, which complicates regulatory determinations and participant protections.
  • Trust and transparency: Trust-building practices, such as results sharing and transparent data use disclosures, are essential for fostering participant confidence.
  • Burdens, barriers, and costs: Institutions, investigators, and research teams face a variety of operational and logistical burdens in pragmatic trials, especially when integrating interventions into routine care and navigating ethics concerns around data governance and data sharing.
  • Engagement: Engagement practices in pragmatic trials have been limited and inconsistent, highlighting “a persistent gap between the ideal of inclusive, sustained collaboration and the realities of constrained resources, power dynamics, and unclear stakeholder roles.”

Read the full article.

The authors point out that most empirical ethics research related to pragmatic trials has been concentrated in the United States and other Western countries and is heavily reliant on surveys and hypothetical scenarios. This limits the generalizability and real-world applicability of current findings. The authors advocate for future research that is geographically inclusive and that employs innovative methodologies, including nested empirical studies within ongoing pragmatic trials, to provide richer, context-sensitive insights.

Mehl completed a postdoctoral fellowship in the ethics and regulatory aspects of pragmatic clinical trials at the Berman Institute for Bioethics at Johns Hopkins University. Coauthor Stephanie Morain is a core faculty member at the Berman Institute and an associate professor of health policy and management at the Johns Hopkins Bloomberg School of Public Health. Coauthor Jeremy Sugarman is the Harvey M. Meyerhoff Professor of Bioethics and Medicine, professor of medicine, and professor of health policy and management at Johns Hopkins and the deputy director for medicine of the Berman Institute.

Morain and Sugarman are cochairs of the NIH Collaboratory’s Ethics and Regulatory Core.

August 17, 2023: American Journal of Bioethics Publishes Special Issue on Pragmatic Clinical Trials

A graphic that includes the cover image from the August 2023 issue of the American Journal of Bioethics. The text in the graphic reads as follows: "American Journal of Bioethics Special issue on pragmatic trials, featuring target articles from the NIH Pragmatic Trials Collaboratory."When research and clinical care are deliberately integrated in an embedded pragmatic clinical trial, the nature and extent of investigators’ obligations to patient-subjects are blurred, as is the clinician’s duty to participate is such research. To address these questions, the American Journal of Bioethics (AJOB) recently published commentaries on 2 target articles in a special issue on pragmatic clinical trials. Both of the target articles for the special issue are from the NIH Pragmatic Trials Collaboratory’s Ethics and Regulatory Core.

Target Article #1

Think Pragmatically: Investigators’ Obligations to Patient-Subjects When Research Is Embedded in Care by Stephanie Morain and Emily Largent

  • The authors challenge the notion that the current ethical model can simply be extended to pragmatic research. Instead, the authors suggest a shift to a model that better reflects the team- and institution-based nature of both clinical care and embedded research.

Target Article #2

Do Clinicians Have a Duty to Participate in Pragmatic Clinical Trials? by Andrew Garland, Stephanie Morain, and Jeremy Sugarman

  • The authors argue that clinicians have a duty to participate in pragmatic research in usual care but suggest acceptable reasons to refuse, such as a badly designed trial, trial activities that violate the clinician’s conscience, or that the trial will impose excessive burdens on the clinician.

Some of the responses to the target articles are highlighted below.

Blurred Boundaries: Toward an Expanded Ethics of Research and Clinical Care
Megan C. Hailey and Nate Olson

  • The authors applaud the articles and offer a range of different research contexts where similar issues apply, including rare disease and genomics research.

Progressing From “Whether to” to “How to” Conduct Pragmatic Trials
Jonathan Casey, Todd Rice, and Matthew Smelner

  • The authors state that clinicians are confronted daily with clinical decisions where the best treatment is unknown and suggest that pragmatic trials are best situated to address the problem.

    “We believe that the US healthcare system has a basic choice to make: allow arbitrary variation in clinical care and continue to systematically expose patients to suboptimal or harmful therapies indefinitely or structure that variation through pragmatic trials to generate knowledge, reduce variation, and improve outcomes over time.”

Ethical Pragmatic Clinical Trials Require the Virtue of Cultivated Uneasiness
Joel Pacyna and Jon Tilburt

  • The authors suggest that softening the default requirement of documenting individual consent removes a primary tool that researchers rely on to ensure the ethical nature of their research. Cultivated uneasiness about waiving consent is warranted and will push researchers to fully examine their decisions and subsequent consequences.

Distinguishing Clinical and Research Risks in Pragmatic Clinical Trials: The Need for Further Stakeholder Engagement
Benjamin S. Wilfond, Sinem Toraman Turk, Stephanie A. Kraft, Elliott M. Weiss, Philip I. Tarr, David Schnadower, and Stephen B. Freedman

  • The authors present a case study involving complex interventions to support the target articles’ supposition that ethical frameworks for pragmatic clinical trials need to account for shortcomings in clinical care.

More-Than-Partial Entrustment in Pragmatic Clinical Trials
Henry S. Richardson

  • The author strongly supports the obligations of the investigators to report significant, actionable incidental findings about individuals.

End-to-End Integration of Pragmatic Trials Into Health Care Settings
Sarah M. Greene

  • The author agrees that pragmatic trials will provide invaluable evidence, but argues that trialists must take care not to interrupt the flow of clinical practice.

For more, see the 15 other commentaries in the special issue of AJOB and the Living Textbook chapter on Consent, Waiver of Consent, and Notification.

July 6, 2022: Article Offers Framework for Meeting Ethical Obligation of Respect for Persons in Pragmatic Trials

Cover the the Hastings Center ReportRespect for persons is a central obligation for the ethical conduct of research with human subjects. Traditionally, clinical trials have primarily relied on informed consent practices to fulfill this ethical obligation.

A new article in the Hastings Center Report proposes 8 dimensions for how researchers can meet the ethical obligation of respect for persons in pragmatic clinical trials. The authors, including members of the NIH Pragmatic Trials Collaboratory’s Ethics and Regulatory Core, developed the framework in recognition of the challenge many pragmatic trials face with traditional informed consent practices when embedding research into clinical care.

“What respect requires in the context of [pragmatic trials] will vary based on the nature of the [pragmatic trial] in question. In some circumstances, alterations of consent may be more ethically appropriate than traditional regulatory consent practices,” the authors wrote.

The dimensions of demonstrating respect for persons—including promoting transparency, minimizing burden, and protecting privacy and confidentiality, among others—serve as context-dependent goals that researchers and oversight committees can use in considering the ethical design, conduct, and oversight of pragmatic trials.

Lead author Stephanie Morain and coauthors Benjamin Wilfond, Andrew Garland, and Jeremy Sugarman are members of the NIH Collaboratory’s Ethics and Regulatory Core.

Read the full article.

June 23, 2022: Ethics and Regulatory Core Aims for Better Design and Improved Implementation

In an interview at the NIH Pragmatic Trials Collaboratory's annual Steering Committee meeting and 10th anniversary celebration, we asked Drs. Jeremy Sugarman and Pearl O'Rourke to discuss the role of the Ethics and Regulatory Core in helping the NIH Collaboratory Trial teams plan and implement their pragmatic trials, and the contributions the Core has made to the literature on ethics and regulatory challenges in pragmatic clinical research.

Headshot of Dr. Jeremy SugarmanBased on your experience working with the NIH Collaboratory Trials, what are some of the common challenges of the Core?

A common challenge the NIH Collaboratory Trial investigators face is determining their study’s level of risk, specifically whether the research is determined to be “minimal risk.” This issue is important, because it influences the permissibility of using alternatives to conventional written informed consent, such as waiving consent or waiving the requirement to document consent.

A recent focus of the Ethics and Regulatory Core is the challenge some studies face with “collateral findings.” These are findings, whether discovered intentionally or unintentionally, that don’t address the trial’s research questions, but may have implications for the health of patients in the trial. For example, when collecting data from electronic health records, researchers might detect the possible use of contraindicated medications in some patients. We recently completed a multimethod investigation of the ethical and regulatory implications of collateral findings in pragmatic clinical trials.

The Core has also offered advice and guidance on several other issues, including innovative study designs such as cluster randomization and stepped-wedge designs, data and privacy issues, collaborating and communicating with healthcare system representatives and clinicians, and challenges related to conducting research at multiple sites.

Headshot of Dr. Pearl O'Rourke

What strategies have NIH Collaboratory Trials used to overcome these barriers?

The Ethics and Regulatory Core hosts an initial consultation with each NIH Collaboratory Trial in the planning phase, and then a follow-up consultation when the project transitions to the implementation phase. We also invite the study teams to consult with us to help address any ethical challenges they’re facing. Sometimes these consultations result in changes in study design, partnerships with the Core to nest empirical ethics studies within the NIH Collaboratory Trials, and other approaches.

How are the NIH Collaboratory Trials’ experiences with the Core helping the field of pragmatic research?

The Core’s work with the NIH Collaboratory Trials has created a body of knowledge and guidance that we have made available to help those engaged in pragmatic research. In addition to a series of published articles in the peer-reviewed literature, we have included some related content in the Living Textbook of Pragmatic Clinical Trials.

Can you describe the impact the Core has had on pragmatic trials over the past decade?

The Core’s consultations during the development stage of these trials has improved investigators’ understanding, appreciation, and planning for the relevant ethical and regulatory issues. The result has hopefully been better research design and improved implementation. Likewise, routine conference calls with active studies have provided opportunities for investigators to hear about the challenges encountered and the solutions developed by other study teams. Sharing these experiences has been invaluable.

The Core is available for ad hoc consultation regarding the ethical and regulatory issues facing any of the projects. Such issue-specific consultations hopefully help study teams develop appropriate solutions.

Finally, Core members have generated a substantial amount of empirical and conceptual scholarship related to the ethical and regulatory issues encountered in the NIH Collaboratory. This work is helping to expand understanding of pragmatic clinical research for the broader research community.

What do you think the Core can contribute over the next decade?

The Core’s ongoing consultations during all phases of the NIH Collaboratory Trials will promote improvements to research protocols and offer real-time check-ins for unanticipated challenges. Our regular conference calls, contributions to the Living Textbook, and scholarly publications will continue to provide an important resource for investigators as well as IRBs.

May 11, 2022: MOTIFS Investigation of Collateral Findings in Pragmatic Trials Will Be Featured in PCT Grand Rounds

Head shots of Dr. Jeremy Sugarman, Dr. Stephanie Morain, Juli Bollinger, and Dr. Kevin WeinfurtIn this Friday’s PCT Grand Rounds, Dr. Jeremy Sugarman, Dr. Stephanie Morain, and Juli Bollinger of Johns Hopkins University and Dr. Kevin Weinfurt of Duke University will present “Ethics and Collateral Findings in Pragmatic Clinical Trials: Implications of a Multi-Method Exploration.” The Grand Rounds session will be held on Friday, May 13, at 1:00 pm eastern.

The team will present lessons from MOTIFS, a recently completed multi-method investigation of the ethical and regulatory implications of “collateral findings” in pragmatic clinical trials.

Join the online meeting.