ACN - 101321555 Australasian Human Research Ethics Consultancy Services Pty Ltd (AHRECS)
Search
Generic filters
Exact text matches only
Search into
Filter by Categories
Research integrity
Filter by Categories
Human Research Ethics

Resource Library

Research Ethics MonthlyAbout Us

Resourcing practice

Australasian Human Research Ethics Consultancy Services Pty Ltd (AHRECS)

A users perspective on the ethics application process in Australia-room for improvement0

 

  1. Suat Chin Ng. MBBS, BMedSc, FRACS. Department of Surgery, Eastern Health, Melbourne, Australia.
  2. Wei Ming Ong MBBS Department of Surgery, Eastern Health, Melbourne, Australia.
  3. Shane Belvedere MBBS Department of Surgery, Melbourne Health, Melbourne, Australia
  4. Creski Gilong. MBBS Department of Surgery, Austin Health, Melbourne, Australia.
  5. Dr Nikolajs Zeps. BSc, PhD Research and Development, Epworth HealthCare, Melbourne, Australia. Eastern Clinical School, Monash University, Melbourne, Australia
  6. Philip Smart MBBS, D.Med.Sci, FRACS. Gastrointestinal Clinical Institute, Epworth HealthCare, Australia  Department of Surgery, Austin Health, Melbourne, Australia.

Compliance with ethical standards is fundamental to conducting human research. While there is a need for a thorough review process to prevent unethical research, the administrative workload required can often be significant. Indeed, researchers largely regard the ethics process as an obstacle that needs to be overcome, rather than a key part of the research process itself. In a recent blog on the AHRECS website entitled “Research Ethics Review as a Box-Ticking Exercise”, A/prof Angela Romano identified a significant problem with our current approach to ethical review as being one that promotes a compliance mentality rather than one that actively encourages appropriate and useful ethical reflection throughout the lifecycle of a research project.

Health and Medical Research is aimed at providing new knowledge to improve the health and wellbeing of the community and the fruits of this work will hopefully translate into tangible benefits for everyone. Significant concerns have been expressed by others that the current processes employed to regulate this work in fulfilment of ethical and legal requirements can itself be unethical. For instance, in a recent Blog by Prof Julian Savulescu he comments that whilst no-one is suggesting that research should not be subject to appropriate regulation and ethical review, given the potential to unnecessarily delay important research, all review processes should be as efficient and proportionate to the risk as is possible. Whilst we cannot immediately fix the lamentable lack of investment in undergraduate and post-graduate training in and practical application of ethics, the processes for review of projects could, in our view, be vastly improved with some fairly low-cost interventions.

What are researchers supposed to do to obtain ethical approval?

We reviewed the webpages of 78 Human Research Ethics Committees (HREC) associated with both public and private health services that we identified from the NHMRC list of registered HRECs. This list is only current to 1st March 2018 and we noted that several of the listed HRECs have in fact closed leaving just 71 that could be assessed. We also excluded from our review websites of small clinics which appear to serve only their own needs, eg IVF clinics.

Our review aimed to assess the ease with which researchers could find the webpages of the HREC, or the office of research and/or governance responsible for research oversight, and the level of information provided in terms of 1) instructions relating to how to make a submission itself, and 2) instructions about ethical considerations that may assist researchers to make a sound submission along the lines of A/Prof Romano’s wishes. We scored these objectively using a binary score of 1 if they had a readily accessible website and 0 if they did not. We scored the information related to the submission process in the same way, that is it was either present or not. We decided to include whether or not there was a clear process for considering low risk research in an expedited way consistent with the National Statement as this provided an insight into whether or not the institution regarded such research in a proportionate manner. We further checked on some of the linked documents and policies provided by the HREC, such as guidance on reporting of Serious Adverse Events (SAEs), to check for consistency and whether they were up to date with current guidelines.

We were surprised to find that 8 of 71 hospital based HRECs did not have a website that we could find. In some instances, the information about the HREC was provided via a central state-based portal where elements of the submission process and key local contact details were provided for each of the HRECs. We checked all of the links present in these websites and found that many were broken and in over half of all cases the links to the relevant policies, procedures, and key guidance documents were significantly out of date.

In contrast, we did find several websites that provided excellent resources such as those provided by the St Vincent’s HREC based in Melbourne and the Bellberry private HREC, which are exemplary in the level of useful information and easily accessible guidance they provide to researchers. We observed that of all of the HREC websites reviewed, 30 of the top 37 HRECs which all had accessible websites with useful information about submission were certified HRECs. Only 6 of the bottom 31, with what we considered to be inadequate levels of guidance information, were certified. This raises an interesting question as to whether the need to become certified led them to invest significantly in all aspects of the administrative process, including the development of useful websites.

Table 1: Key findings overall

CriteriaNo of HRECs scoring 1 (total 71)
Easily accessible information about key functions62 (87%)
Clear instructions about submission process62 (87%)
Additional information to guide applicants about ensuring their project met ethical requirements27 (38%)
Clear and proportionate pathway for low risk research43 (61%)
Up to date policies and guidance documents31 (44%)

.
Our findings suggest that many health services that run HRECs could significantly improve the researcher experience by simply upgrading their websites to guide researchers more clearly about what is expected of them. As Angela Romano highlighted, the process should not be a box checking exercise and we suggest that if there was clear guidance about what was substantive ethical considerations that needed to be met rather than simply how to fill in the relevant forms we might achieve this, or at least take a step in the right direction.

Whilst we cannot provide any analytical evidence of a correlation it would not be surprising if the improved guidance provided by some HRECs meant that the time to approval was shorter due to a reduction in non-compliant submissions and perhaps even the quality of submission in terms of covering the substantive ethical concerns likely to arise. It is fair to argue that researchers themselves should take the time and effort to ensure that they find out what is expected of them but we suggest that it would be a highly cost efficient exercise to start by making the websites themselves more useful and geared toward this end.

Would you like to find out the score for your institution’s web site/or have an assessment conducted? If you are a https://www.ahrecs.vip subscriber this can be done for free.  Send an email to enquiry@ahrecs.com to discuss.

We did note in reviewing all of the websites that they were all designed differently and put information in different places and in different formats. We would also like to suggest that there would be some value in establishing a national standard for the presentation of core information regarding ethical submission and that there really is no reason that we can see for such wide variation in the way documents are provided. Efforts to harmonise content are evident in groups of hospitals such as Ramsay Healthcare, and we did note that several institutions now utilise the services of a central HREC, either their own for a group of hospitals or of other (certified) HRECs as part of the National Mutual Acceptance (NMA) scheme. We did not observe a great deal of harmonisation of content though outside of mandatory state-specific forms.
.

Australia is committed to fostering health and medical research to improve the lives of patients as demonstrated by the State, Federal and charitable sector financial commitments that run to several billion dollars. Enhancing and harmonising website content would seem one way in which a small amount of effort would go a very long way to boosting our capability of doing ethically sound research.
.

References:
National Statement on Ethical Conduct in Human Research 2007 (Updated 2018). The National Health and Medical Research Council, the Australian Research Council and Universities Australia. Commonwealth of Australia, Canberra.

Romano, A. (22 June 2019) Research Ethics Review as a Box-Ticking Exercise Research Ethics Monthly. Retrieved from: https://ahrecs.com/human-research-ethics/research-ethics-review-as-a-box-ticking-exercise

This post may be cited as:
Ng, S. C., Ong, W. M., Belvedere. S., Gilong, C., Zeps, N. & Smart, P. (4 February 2020) A users perspective on the ethics application process in Australia-Room for improvement. Research Ethics Monthly. Retrieved from: https://ahrecs.com/human-research-ethics/a-users-perspective-on-the-ethics-application-process-in-australia-room-for-improvement

Clergy service to HRECs: the useful paradox within secular governance of research involving human participants0

 

Aviva Kipen, Union for Progressive Judaism and Progressive Judaism Victoria.

In 2015, I earned a Doctor of Ministry Studies degree from the University of Divinity in Melbourne. The thesis, investigating how 13 Christian and Jewish clergy experienced HREC service in their pastoral care roles, arose from my own human research ethics committee and Victorian Biotechnologies Ethics Advisory Committee service and extensive interfaith work. I had been mentored into my service to the Monash University HREC by the Rev’d Dr Judy Redman, the then Victorian Uniting Church Outreach Ministries Coordinator. I found myself in the company of Anglican clergy and had succeeded Catholics – nuns and priests – Buddhist monks and also male rabbis who had served before me. Joining Judy, the serving female minister, made the gender issue less remarkable than it might otherwise have been, even in the late 1990s. The faith interchanges on succession raised my immediate curiosity that would later lead to the research question and the project on which this piece draws.

The then National Guidelines were clear: we clergy appointees were not there to push our own denominational barrows. Still, I became curious about what was really going on in the minds of others who served HRECs interchangeably from a range of faiths and traditions regardless of often-irreconcilable theologies in the ‘pastoral chairs’. My interfaith work meant I was confident that, in the event of content matters being beyond my own repertoire, I would have an extensive network from which to seek expert guidance if asked to do so. But HREC appointment provides an opportunity to serve far beyond the specifics of faith content occasionally referenced in research applications.

I became aware that the recruitment of ‘the pastor’ in other committees was not always simple. I had been spotted at a meeting about chaplaincy in women’s prisons! How had others been identified and invited to join committees? What constituted their self-understanding of the ministry service being gifted to the committees they served? Would my interviews disclose any kind of ‘evangelism by stealth’?  Did faiths or denominations target access to committees assessing large amounts politically/theologically/ethically sensitive, kinds of research?

I discovered no documents showing the means by which the Catholic Church became an early adopter of the opportunity to be represented, but clearly there were Catholic clergy leading the discussion in the early years. My research showed great diversity within the voices of the Christian ministers. Even within denominations, including between current serving Catholics, there was diversity of expression on ground-breaking issues. It became clear that the one participant who asserted his role as being to represent the Catholic position, was the exceptional Catholic voice. Other Catholics applied the provisions of the current National Statement informed by their own faith understanding, but with broad appreciation for other communities’ concerns.

Many clergy enjoyed the intellectual effort of meeting preparation and assessing applications, perhaps indicating a somewhat obsessive character trait. The rigor of disciplined meetings, the collegiality with co-assessors and committee colleagues was experienced by many as a valued counterweight to congregational demands. When appointed, some experienced a bit of resistance and some took a gentle ribbing. But as they became known and trusted on their merits and performance, tenures were frequently extended. There was some inference that if individuals had theologies unable to embrace the content or methodologies required in assessing projects, it would be unlikely that they would find their way onto committees. A few references to short tenures alluded to non-renewal of clergy who were not a good fit.

The diversity of appointments reflects the neighbourhoods/communities served by HRECs and is appropriately representative of our national diversity. One participant was from a highly conservative evangelical denomination. The interview triggered deeply thoughtful reaction about personal identity relative to the HREC work. I would later find out that the reflection resulted in some major theological grappling as a consequence of the conversation. Regardless of denomination, interviewees found themselves intrigued by the attention my investigation was bringing to HREC clergy/pastoral work, which had almost invariably been out of the faiths’ hierarchical spotlights. Most remained entirely grateful for the freedom to do the HREC work without such attention.

One pastor described choosing not to participate in a committee discussion because he was aware his personal knowledge was not sufficient. It was a frank admission. The example begs the question of how applications need to enable comprehension and how lay and other non-disciplinary experts are enabled in their roles. Others found solutions to specific matters of dogma by offering wordings that would provide enough cues to the faith’s adherents to ensure they were going to be able to make informed choices without imperilling projects. What emerged was that clergy were clear about their denominational obligations and the tension between them and the needs of others in the general community.

Given that the task of assessing applications and contributing to meetings is identical for all HREC members, how do clergy understand themselves alongside their colleagues (who may be harbouring strong religious views but are not required to disclose them and which need not be presumed) as contributors to the wellbeing of the research landscape? Several clergy described pastoral care for committee colleagues and secretariat staff, by virtue of regular contact with them. This was implicit and automatic pastoral work. Care for researchers and participants whom the HREC members will never meet, is also natural pastoral work and a clear driver for clergy in their appointments.

Serving HRECs also provides clergy with a window to unfolding knowledge, a forward-looking perspective, regular use of critical faculties not always appreciated in congregational work, intelligent company, confidential settings in which they can be full participants without any oversight from their hierarchies resulting in contributions that don’t need to follow predictable, dogmatic lines, and a chance to serve beyond the faith or denomination. Australia has encoded high standards for itself in the research domain. Participants in my research were clear that high ethical research standards fit congruently into their understanding of their ministry work and several specialise in HREC work as their ministry interest. Many of these have high-level academic qualifications and years of expertise, which are offered repeatedly to the Australian community through HREC service.

Rabbi Dr Aviva Kipen has held Monash University HREC appointments and served on the Victorian Bio-Ethics Advisory Committee. She returned to serve a second term on the Australian Health Ethics Committee of NHMRC in 2019 and has begun the current triennium for the Victorian DHHS HREC. All comments reflect material in the thesis Kipen, A. (2015) Serving God and The Commonwealth of Australia: The Ministry Experiences of Clergy in Victorian Human Research Ethics Committees. Melbourne: University of Divinity.

This post may be cited as:
Kipen, A. (3 November 2019) Clergy service to HRECs: the useful paradox within secular governance of research involving human participants. Retrieved from: https://ahrecs.com/human-research-ethics/clergy-service-to-hrecs-the-useful-paradox-within-secular-governance-of-research-involving-human-participants

Keywords
Clergy, religion, denomination, ministry, faith

Should we Reframe Research Ethics as a Professional Ethics?0

 

Dr Nathan Emmerich
Research Fellow in Bioethics at ANUMS

Despite the fact that one of the urtexts of bioethics—Beauchamp and Childress’ principles of biomedical ethics—offers a set of concepts that purport to apply to both research and medical practice it is nevertheless the case that we standardly contrast research ethics with professional ethics. The operating presumption seems to be that a proper grasp of professional ethics requires an understanding of the unique role professional’s play, whereas the same cannot be said of research ethics. Here the presumption is that researchers are not unique but interchangeable. Furthermore, their individuality is inimical to good, and therefore ethical, research.

Whilst both healthcare professionals and researchers should be objective, the professional enters into a singular relationship with their patients. The position of the researcher can, however, be occupied by any relevantly qualified individual and their function is to report their scientific observations. Thus, underlying this contrast is an epistemological point. The perceived importance of the relationship between doctors and patients means that whilst the ethics of the preeminent profession, medicine, are predicated on professionalism they are equally predicated on something that is distinctively (inter)personal. In contrast, the notion that there might be an (inter)personal dimension to the relationship between researchers and research participants is inimical to the requirement for objectivity, at least for a certain value of objectivity.

COMMENTARY
Nik Zeps, AHRECS

.
In this thought-provoking blog, Nathan Emmerich challenges the notion that there is any distinction between research ethics and professional ethics when it comes to social science research. That is, the very nature of the enterprise requires that the researcher be deeply engaged in ethical discourse throughout the conduct of the study and not simply at a point in time to satisfy the regulatory requirements of ethics committees to obtain their approval. Whilst the argument is reserved for the social sciences, and there is some hesitancy to extend it beyond this, it is clear that the arguments made are true for all research, including biomedical. There is a reluctance to challenge notions about the divide between research and clinical practice that have been with us for over 50 years, but perhaps it is time to have a proper discussion about whether this is or is not applicable any longer. Patient centered research with an emphasis on co-design with consumers upends the notion that this type of research maintains a separation between researchers and research participants. Social science research provides an immediate opportunity for rethinking how we behave ethically, but biomedical research should follow hot on the heels.

Therein, of course, lies the rub. According to Stark, the differentiation between research ethics and professional ethics can be traced to the National Institute of Health, Bethesda, Maryland, USA, circa 1950. Given the existing competition between the codes of professional ethics promulgated by medicine’s sub-specialties, the nascent idea of a research ethics was conceived pragmatically and in aprofessional terms. When it came to biomedical research, and the epistemology of the natural sciences, this was not an issue. However, consistent with Schrag’s critique of the subsequent development of research ethics as neglecting concerns expressed by social scientists, this is more problematic when it comes to the social sciences, particularly at the more interpretive end of the spectrum.
.

In qualitative social science the unique perspective, position or standpoint of the researcher is essential to understanding socio-cultural reality and, therefore, to the process of conducting research. Furthermore, it is not something that can be eliminated by the use of (replicable) quantitative measures. This does not mean qualitative research cannot be objective. Rather, it means that the notion of objectivity differs between the natural and social sciences. Doing qualitative social science does not mean embracing subjectivity. Rather, it requires qualitative researchers to embrace epistemological reflexivity and to aim at objectivity as a value, virtue, or standpoint of social research.
.

When this is coupled with the fact that such research often seeks to give expression to the ‘lived experience’ of research participants, one can see how a concern for the (inter)personal must return to center stage in discussions of social scientific research ethics. One way of doing so would be to rethink the ethics of social scientific research as a form of professional ethics. Thus, rather than simply ‘frontloading’ ethical decision-making as a part of the design of proposed research, which can then be subject to peer review or evaluation by committee, we can more clearly acknowledge that engaging with the ethical dimension of research requires ongoing attention. The range of ethical issues researchers might encounter, both in the field and as a function of their role, are such that we cannot hope to fully address them preemptively. In this context, and consistent with the contemporary concern for the integrity of both research and researchers, we might draw on the idea of researchers as professionals and, in so doing, embrace the view that they ought to be guided by a set of internal professional norms or ethics.
.

Of course, this is not exactly a solution to the ethical issues social scientists might encounter in the course of research. It does, however, invite further engagement with such questions. Indeed, one can say more than this. Rather than thinking of the ethics of research as something to be addressed and codified by external commentators, such as bioethicists, the idea that research might benefit from a professional ethics invites researchers themselves to lead the discussion. No doubt questions remain, not least on what might constitute a profession or professional group in this context. Nevertheless, this proposal suggests that both professional groups and professional researchers should play a privileged role in creating, interpreting and putting into practice the substantive commitments of their own professional ethics. Furthermore, it is for them to set forth, justify and communicate the stance they adopt to other stakeholders.
.

This suggestion stands in relatively stark contrast to conceptions of research ethics, where external standards and evaluations are seen as having priority. To me, the difference is akin to the one we find when comparing research ethics committees and clinical ethics committees. The former tends to be rather one-sided; it assesses and offers judgment on research proposals or documents. The latter engages with professional actors and, through a process of mutual dialogue and discussion, facilitates and contributes to the individual’s own ethical formations. Which approach is more likely to promote the ethics and integrity of research, particularly social scientific research, seems self-evident.
.

Dr Nathan Emmerich is a Research Fellow in Bioethics at ANUMS. The ideas presented in this post stem from a book chapter entitled ‘A Professional Ethics for Researchers?’ (online first) recently published in Iphofen (Ed) Handbook of Research Ethics and Scientific Integrity (Springer) as well as an earlier publication ‘Reframing Research Ethics.

References:

Beauchamp, T.L., and J.F. Childress. 2009 [1979]. Principles of Biomedical Ethics. 6th Edition. Oxford, UK: Oxford University Press.

Emmerich, N. 2016 ‘Reframing Research Ethics: Towards a Professional Ethics for the Social Sciences’. Sociological Research Online 21(4):7 http://www.socresonline.org.uk/21/4/7.html

Emmerich, N. 2019. ‘A Professional Ethics for Researchers?’ In Iphofen, R. (Ed) Handbook of Research Ethics and Scientific Integrity. Springer. Online First: https://doi.org/10.1007/978-3-319-76040-7_34-1

Iphofen, R. (Ed) Forthcoming 2020. Handbook of Research Ethics and Scientific Integrity. Springer, https://link.springer.com/referencework/10.1007/978-3-319-76040-7

Stark, L. 2011. Behind Closed Doors: IRBs and the Making of Ethical Research. University of Chicago Press. https://www.press.uchicago.edu/ucp/books/book/chicago/B/bo12182576.html

Schrag, Z.M. 2010. Ethical Imperialism: Institutional Review Boards and the Social Sciences, 1965–2009. The Johns Hopkins University Press. https://jhupbooks.press.jhu.edu/title/ethical-imperialism

This post may be cited as:
Emmerich, N. (1 October 2019) Should we Reframe Research Ethics as a Professional Ethics? Research Ethics Monthly. Retrieved from: https://ahrecs.com/human-research-ethics/should-we-reframe-research-ethics-as-a-professional-ethics

Smarter proportional research ethics review0

 

Rushing toward a faster review decision should not mean relaxing standards or playing chicken with stricter central control

Gary Allen, Mark Israel and Colin Thomson

Too often, there is a danger that ‘expedited ethical review’ (a term not used in the National Statement since 1999) might equate to an approach that abridges the review process to the point where it’s little more than a friendly exchange between peers or a nod to seniority. We won’t call out the well-reported cases where it is hard to fathom how they were granted ethics approval. Such cases should make us uncomfortable, because they are invitations to replace institutional self-regulation with something hasher and unsympathetic.

Don’t get us wrong, we’ve spoken often and enthusiastically about the value of well-designed proportional review arrangements. We have assisted many clients, large and small, to design and implement such arrangements and believe that they form part of a well-conceived review system.

A proportional review arrangement can deliver a review outcome much faster than consideration by a human research ethics committee, but instead of a ‘Claytons’ or mock-review, it should have the following features:

  1. While there can, and should, be a mechanism to do an automated quick self-assessment of whether a proposed project qualifies for ethics review other than by a research ethics committee, the process should:
    1. not rely on questions along the lines of “Is this a low risk research project?”
    2. draw on, reference and link to guidance material.
    3. when using trigger questions, ensure they are nuanced, with probing sub-questions.
    4. include confirmation of a quick assessment by an experienced ethics officer or chairperson.
    5. retain an applicant’s responses, both as a record of what they said about the project, and for future evaluation of whether the arrangement is correctly assessing new projects and guiding applications along the correct review pathway.
  2. The process should preferably be online, easily (re)configurable, easily auditable, with information entered by applicants and ‘triaged’ by an ethics officer.
  3. A quality online system will populate committee papers and reports, will issue reminders and will populate with known information.
  4. While many projects may be reviewed outside of the human research ethics committee, the reviews should be conducted by experienced persons, who participate in annual professional development and who can draw upon internal and external policy and resource material.

In Australia, an institution’s proportional review arrangements might include the following pathways:

  1. Prior review– Research that has already been reviewed by another HREC, appropriately delegated review body, or an international body equivalent to an Australian research ethics review body.
  2. Scope checker– A test to confirm whether a proposed project is in fact human research.
  3. Exemption test– A test to determine whether the proposed research is a type an institution could exempt from ethics review as per the National Statement.
  4. HREC review required test– A test to confirm whether the research project is of a type the National Statement specifies must be reviewed by a HREC.
  5. Institutional exemption test– Many institutionsexempt some categories of human research from research ethics review (e.g. universities often exempt course evaluations and practical activities for a teaching-learning purpose).
  6. Negligible risk research– Subject to qualifying criteria an institution might establish a negligible risk review pathway in which applications are considered administratively.
  7. Low-risk, and minimal ethical issue research– Subject to qualifying criteria, proposed projects that are low risk and have minimal ethical sensitivity could be reviewed by the chair of the research ethics committee.
  8. Low-risk, some ethical issue research– Again subject to qualifying criteria, proposed projects that are low risk but have some ethical sensitivity could be reviewed by a small panel of the research ethics committee (including external member of the committee).
  9. HREC review – Only human research (see 2), that has not previously been reviewed (see 1) that is not exempt (see 3 and 4) and has not been classified as negligible risk (see 6) or low risk (see 7 and 8) needs to be reviewed by HREC.

An arrangement with the features listed above would allow for review that is proportional, timely, efficient and justifiable. Reviews that are merely expedited or fast places us all at risk. The increasing examples of “how could that have been approved?” makes it feel as though some institutions are gambling that a desire to meet researchers’ calls for quick, if superficial, review won’t be exposed by unethical practice. Perhaps they are correct, but every new reported review misstep makes us more nervous. Realistically, establishing a nationally administered reliable, robust and agile proportional review process requires substantial investment of time and other resources so is unlikely to happen.  But, what poor review processes could do is invite far more detailed direction on how institutions can design, conduct and monitor processes outside of a HREC. In our experience, there are greater and longer-lasting benefits that can accrue from an institution having a high quality approach to proportional review.

The above is a summary of the discussion we typically include in blueprint documents about establishing a robust proportional review arrangement. We have included some further notes on this topic on our https://www.ahrecs.vip and Patreon pages.

Please contact us at proportional@ahrecs.com if you would like to discuss how we might assist your institution.

This post may be cited as:
Allen, G., Israel, M. & Thomson, C. (26 August 2019) Smarter proportional research ethics review.  Research Ethics Monthly. Retrieved from: https://ahrecs.com/human-research-ethics/smarter-proportional-research-ethics-review

0