Home    /    Newsletters    /    New Policy Implementation Guidance

New Policy Implementation Guidance


September 15, 2020


Dear Research Community


Over the past 18 months, we have rewritten the HRPP policies to be compliant with the revised common rule and consistent with the reorganization of OHSRP and the NIH IRBs.  As these policies are all inter-related, with few exceptions we were not able to implement them as they were developed and cleared.  Now that they are complete, we are rolling them out in groups between now and years end.  We understand that releasing so many new policies rapidly is a little overwhelming.  Hopefully, as you become familiar with the new policies, you will see that in many cases there is not a lot of change in the actual policy requirements, and for those that there is change, it is for the better.


To guide you in the implementation of these new policies, please review the following:

For example, the new policy requires that the protocol and consent describe the compensation plan, even if the plan is that there will be no compensation.  Some protocols that are not compensating subjects are silent on this.  At this time, you do not need to amend your protocol to add a new section stating there is no compensation. With your next planned amendment you can change this.