1 00:00:04,538 --> 00:00:07,188 I was wondering if there has been any talk of 2 00:00:07,188 --> 00:00:07,541 using 3 00:00:07,541 --> 00:00:10,777 AI somehow in IRBs especially 4 00:00:10,777 --> 00:00:13,814 to maybe expedite things, or I don't. 5 00:00:13,814 --> 00:00:16,984 I don't know if there's anything I could do, but they're there. 6 00:00:16,984 --> 00:00:18,819 So the short answer is yes. 7 00:00:18,819 --> 00:00:23,969 There's a lot of chatter, for lack of a better word of use 8 00:00:23,969 --> 00:00:24,324 ING 9 00:00:24,625 --> 00:00:27,327 AI to do a variety of things. 10 00:00:27,327 --> 00:00:30,430 I actually heard the tail end of a talk the other day. 11 00:00:30,797 --> 00:00:33,967 So you will learn next week 12 00:00:33,967 --> 00:00:36,970 that there is a new requirement 13 00:00:37,571 --> 00:00:39,912 as it relates to the informed consent 14 00:00:39,912 --> 00:00:42,442 form, that at the very top of the form, 15 00:00:42,442 --> 00:00:46,656 there is key information that is the most important 16 00:00:46,656 --> 00:00:47,648 information 17 00:00:47,648 --> 00:00:50,651 that the potential participant should know. 18 00:00:51,051 --> 00:00:55,594 And so a group at the University of Michigan has basically 19 00:00:55,594 --> 00:00:56,690 created a way 20 00:00:57,090 --> 00:01:00,227 with queries to chat GPT four or 5 21 00:01:00,227 --> 00:01:03,630 or 6 to say, here's the consent form, 22 00:01:04,298 --> 00:01:07,568 please pull out the key information 23 00:01:07,568 --> 00:01:11,405 and put it in a readable, you know, eighth grade language. 24 00:01:11,838 --> 00:01:15,509 And, they sort of attested that for a while. 25 00:01:15,509 --> 00:01:17,911 They haven't adopted it as a service 26 00:01:17,911 --> 00:01:19,446 for all investigators. 27 00:01:19,446 --> 00:01:22,672 But, that's one way that investigators 28 00:01:22,672 --> 00:01:26,153 are using it to comply with regulations. 29 00:01:27,120 --> 00:01:28,255 There has also been 30 00:01:28,255 --> 00:01:32,259 some chatter about, could you use AI to do that 31 00:01:32,259 --> 00:01:34,963 administrative review, for example, 32 00:01:34,963 --> 00:01:36,663 here is the protocol. 33 00:01:36,663 --> 00:01:40,567 Make sure that it has all these seven components 34 00:01:40,567 --> 00:01:42,834 and that there's something that makes sense 35 00:01:42,834 --> 00:01:43,203 below. 36 00:01:43,203 --> 00:01:45,605 So there are a lot of ideas. 37 00:01:45,605 --> 00:01:48,442 There isn't yet any chatter 38 00:01:48,442 --> 00:01:52,379 about replacing the IRB with AI, but who knows? 39 00:01:54,114 --> 00:01:56,383 Hey, Daniel. Hey, 40 00:01:56,383 --> 00:01:57,751 this is super interesting. 41 00:01:57,751 --> 00:02:00,754 My question is about, you mentioned that 42 00:02:01,221 --> 00:02:04,925 IRBs, vary in terms of practice and policy, 43 00:02:05,625 --> 00:02:08,628 historically beholden to federal regulations. 44 00:02:08,628 --> 00:02:10,831 But I'm curious, 45 00:02:10,831 --> 00:02:14,067 how much do they vary from institution to institution? 46 00:02:14,067 --> 00:02:16,219 Do they look like, vastly different 47 00:02:16,219 --> 00:02:18,372 or is it generally pretty similar? 48 00:02:18,572 --> 00:02:19,606 Great question. 49 00:02:19,606 --> 00:02:23,443 And the the short answer, it's a bit of a bell curve, right. 50 00:02:23,644 --> 00:02:26,646 So a really good example is 51 00:02:26,913 --> 00:02:29,883 when you're doing pediatric research, 52 00:02:30,450 --> 00:02:33,887 the IRB must categorize research 53 00:02:33,887 --> 00:02:36,890 as no more than minimal risk, 54 00:02:37,591 --> 00:02:40,327 more than minimal risk with, 55 00:02:40,327 --> 00:02:43,463 a, prospect of direct benefit 56 00:02:43,463 --> 00:02:46,833 and more than minimal risk and potential benefit 57 00:02:46,833 --> 00:02:50,003 to the group of children represented by the population. 58 00:02:50,003 --> 00:02:50,670 You're enrolling. 59 00:02:51,605 --> 00:02:54,231 So that definition of minimal risk 60 00:02:54,231 --> 00:02:55,776 is really important 61 00:02:56,009 --> 00:02:58,984 as it relates to what category of research 62 00:02:58,984 --> 00:02:59,479 it is. 63 00:03:01,181 --> 00:03:02,682 If there's a lot 64 00:03:02,682 --> 00:03:05,294 if there's a lot of risk, right, there has to be some direct 65 00:03:05,294 --> 00:03:05,686 benefit. 66 00:03:06,353 --> 00:03:08,618 And in the third category, you know, 67 00:03:08,618 --> 00:03:10,757 you have to be able to say, well, 68 00:03:10,757 --> 00:03:14,396 what how much risk is too much to expose, 69 00:03:14,396 --> 00:03:14,928 etc.. 70 00:03:15,562 --> 00:03:18,932 So, Sima Sha, who was a fellow 71 00:03:18,932 --> 00:03:21,119 here at the Department of Bioethics 72 00:03:21,119 --> 00:03:22,869 many years ago, did a study 73 00:03:22,869 --> 00:03:27,674 where she asked IRBs for pediatric research. 74 00:03:28,008 --> 00:03:30,710 How do you define minimal risk? 75 00:03:30,710 --> 00:03:34,047 And here's a list of potential things. 76 00:03:34,247 --> 00:03:36,430 Which would you call minimal risk 77 00:03:36,430 --> 00:03:37,951 and not so blood draw? 78 00:03:39,152 --> 00:03:42,856 You know, up to like, a lumbar puncture or, 79 00:03:43,924 --> 00:03:46,159 take an amount of blood, right. 80 00:03:46,159 --> 00:03:47,527 She sort of said so. 81 00:03:47,527 --> 00:03:50,063 Bottom line is there was a lot of variation, 82 00:03:50,063 --> 00:03:52,499 but it was about a it was a bell curve, right? 83 00:03:52,499 --> 00:03:56,336 Some IRBs would say none of that is minimal risk, 84 00:03:56,336 --> 00:04:00,176 even a simple blood draw where at the other end, lumbar 85 00:04:00,176 --> 00:04:00,874 puncture? 86 00:04:00,874 --> 00:04:02,843 No, not more than. 87 00:04:02,843 --> 00:04:04,511 Again, that's a little extreme, but 88 00:04:05,612 --> 00:04:06,746 you get the idea. 89 00:04:06,746 --> 00:04:09,583 So it's within a bell curve. 90 00:04:09,583 --> 00:04:13,487 And we as ethics types might worry about either end. 91 00:04:13,487 --> 00:04:13,887 Right. 92 00:04:13,887 --> 00:04:16,603 So we might worry about exposing kids 93 00:04:16,603 --> 00:04:17,924 to too much risk, 94 00:04:18,291 --> 00:04:20,829 or we might worry about valuable research 95 00:04:20,829 --> 00:04:22,129 that isn't happening 96 00:04:22,129 --> 00:04:23,697 because they're so strict. 97 00:04:23,697 --> 00:04:26,433 And that's generally true when you look 98 00:04:26,433 --> 00:04:31,004 at the literature about it's not very wide, 99 00:04:31,004 --> 00:04:35,566 but there is some literature about how IRBs have, you know, 100 00:04:35,566 --> 00:04:35,876 did 101 00:04:35,876 --> 00:04:39,455 some said that is it's exempt, others said it was expedited, 102 00:04:39,455 --> 00:04:39,813 etc.. 103 00:04:39,813 --> 00:04:42,816 So it's almost always a bell curve, 104 00:04:43,083 --> 00:04:46,052 and very little on either end 105 00:04:46,686 --> 00:04:47,220 and or one. 106 00:04:47,220 --> 00:04:48,922 Go ahead. Hi. 107 00:04:48,922 --> 00:04:51,925 I just have a question about quality control. 108 00:04:52,259 --> 00:04:55,968 So, I imagine that, like, look, there are a number of local 109 00:04:55,968 --> 00:04:56,596 libraries 110 00:04:56,596 --> 00:04:58,331 and they all have a bunch of different people. 111 00:04:58,331 --> 00:04:59,566 Who sit on these committees. 112 00:04:59,566 --> 00:05:02,563 So is there a procedure for these arabes 113 00:05:02,563 --> 00:05:03,537 to sit like, 114 00:05:03,537 --> 00:05:06,504 step back and look at all the cases that they've, you 115 00:05:06,504 --> 00:05:06,840 know. 116 00:05:07,741 --> 00:05:09,976 Presided over and looked at in the past, you. 117 00:05:09,976 --> 00:05:12,812 Know, a number of months and then, make some sort. 118 00:05:12,812 --> 00:05:14,347 Of determination about whether their. 119 00:05:14,347 --> 00:05:16,683 Decisions have been generally consistent. 120 00:05:16,683 --> 00:05:17,450 Yeah. 121 00:05:17,450 --> 00:05:20,554 So this is a topic that is very close to my heart. 122 00:05:20,554 --> 00:05:23,557 I spend a lot of my time these days thinking about 123 00:05:23,924 --> 00:05:26,565 how can we evaluate the quality of IRB 124 00:05:26,565 --> 00:05:28,094 review and oversight. 125 00:05:28,562 --> 00:05:33,600 The short answer is there are some tools that are 126 00:05:33,600 --> 00:05:34,834 inadequate. 127 00:05:34,834 --> 00:05:38,458 I would say that an IAB could step back 128 00:05:38,458 --> 00:05:39,573 and review. 129 00:05:39,573 --> 00:05:41,474 They could look at how did we, 130 00:05:42,776 --> 00:05:43,143 you know, 131 00:05:43,143 --> 00:05:46,782 decide let's look at all our pediatric research and see 132 00:05:46,782 --> 00:05:47,047 how 133 00:05:47,047 --> 00:05:49,533 we decided whether or not we always said 134 00:05:49,533 --> 00:05:51,585 a blood draw was a minimal risk. 135 00:05:51,585 --> 00:05:53,453 So one could do that. 136 00:05:53,453 --> 00:05:55,887 But IRBs are really busy, don't have 137 00:05:55,887 --> 00:05:58,658 enough staff, don't have enough funding. 138 00:05:58,658 --> 00:06:01,403 So it for some, it's a bit of a luxury 139 00:06:01,403 --> 00:06:03,930 to be able to take that step back. 140 00:06:04,431 --> 00:06:07,434 But there are 141 00:06:08,068 --> 00:06:12,505 there are a couple of ways in which institutions improve 142 00:06:12,505 --> 00:06:14,357 the likelihood that the people around 143 00:06:14,357 --> 00:06:15,809 the table are well situated. 144 00:06:15,809 --> 00:06:19,045 So they're all trained in a particular way. 145 00:06:19,045 --> 00:06:21,314 They have in-service training. 146 00:06:21,314 --> 00:06:23,531 I'm sure that if a chair had a concern, 147 00:06:23,531 --> 00:06:24,951 like you were on the IRB 148 00:06:24,951 --> 00:06:26,774 and you fell asleep and you were never 149 00:06:26,774 --> 00:06:28,021 bringing your reviews in, 150 00:06:28,788 --> 00:06:30,914 they'd probably have a chat with you and 151 00:06:30,914 --> 00:06:33,093 ask you like the at the extremes, right? 152 00:06:33,093 --> 00:06:35,391 There's ways that the sort of local 153 00:06:35,391 --> 00:06:37,163 quality can be maintained. 154 00:06:37,163 --> 00:06:39,849 And but there are ways that you could step 155 00:06:39,849 --> 00:06:40,233 back. 156 00:06:40,934 --> 00:06:44,671 Some institutions do ad hoc audits. 157 00:06:45,138 --> 00:06:46,306 Not for cause. 158 00:06:46,306 --> 00:06:46,606 Right. 159 00:06:46,606 --> 00:06:49,309 We're not worried about a particular person's 160 00:06:49,309 --> 00:06:49,909 protocol. 161 00:06:50,143 --> 00:06:51,611 You can't review everything. 162 00:06:51,611 --> 00:06:54,263 So you say, I'm going to randomly select 163 00:06:54,263 --> 00:06:56,583 ten projects and take a deep dive. 164 00:06:56,850 --> 00:06:59,331 And so those audits can then inform 165 00:06:59,331 --> 00:07:01,955 wow, everybody's forgetting to do X. 166 00:07:01,955 --> 00:07:04,381 So we've got to reorient the investigators 167 00:07:04,381 --> 00:07:05,825 and the IRB to make sure 168 00:07:05,825 --> 00:07:06,626 this is present. 169 00:07:08,828 --> 00:07:09,629 Go ahead. 170 00:07:09,629 --> 00:07:12,632 Hi, Holly. Sally Fowler. Hi there. 171 00:07:12,632 --> 00:07:14,691 I kind of more practical question 172 00:07:14,691 --> 00:07:15,502 on something 173 00:07:15,502 --> 00:07:17,289 you just put up, and it's about irb 174 00:07:17,289 --> 00:07:18,872 used in a responsible parties. 175 00:07:18,872 --> 00:07:23,273 And you wrote that, IRBs have to do the continuing 176 00:07:23,273 --> 00:07:23,977 review. 177 00:07:23,977 --> 00:07:27,128 Yes. On studies that receive full committee 178 00:07:27,128 --> 00:07:28,081 review. Yep. 179 00:07:28,081 --> 00:07:31,648 So expedited reviews which, you know, are minimal 180 00:07:31,648 --> 00:07:32,085 risk. 181 00:07:32,085 --> 00:07:33,653 Yeah. 182 00:07:33,653 --> 00:07:36,050 Are you saying because this would be kind of 183 00:07:36,050 --> 00:07:36,323 good 184 00:07:36,323 --> 00:07:38,537 if you are that they don't need continuing 185 00:07:38,537 --> 00:07:38,958 review. 186 00:07:38,958 --> 00:07:41,306 And I know your your caveats going to be 187 00:07:41,306 --> 00:07:42,362 go to your local. 188 00:07:42,362 --> 00:07:43,563 Yeah I heard that. 189 00:07:43,563 --> 00:07:44,864 So it's a great question. 190 00:07:44,864 --> 00:07:47,727 So one thing none of us mentioned today 191 00:07:47,727 --> 00:07:50,370 is that the common rule was revised 192 00:07:50,370 --> 00:07:54,074 in 2018 after a very long, protracted 193 00:07:54,074 --> 00:07:54,974 process. 194 00:07:55,442 --> 00:07:58,615 One of the things that's different 195 00:07:58,615 --> 00:08:01,881 from before 2018 is that only full 196 00:08:01,881 --> 00:08:05,262 committee reviewed protocols are required 197 00:08:05,262 --> 00:08:07,654 to provide an annual review. 198 00:08:08,188 --> 00:08:11,391 So if it's expedited, you don't have to. 199 00:08:11,391 --> 00:08:14,761 Now, some IRBs could say 200 00:08:15,028 --> 00:08:18,198 we want to do more than what the regulations require, 201 00:08:18,198 --> 00:08:21,768 and we want to review all expedited research, 202 00:08:21,768 --> 00:08:25,069 but they're no longer required by federal regulations to do 203 00:08:25,069 --> 00:08:25,405 that. 204 00:08:25,605 --> 00:08:27,829 So when they approve whichever IRB 205 00:08:27,829 --> 00:08:30,510 you're in, when they approve your study, 206 00:08:31,478 --> 00:08:32,245 they will tell. 207 00:08:32,245 --> 00:08:33,313 You exactly they. 208 00:08:33,313 --> 00:08:34,948 Want a continuing review every year. 209 00:08:34,948 --> 00:08:37,183 We're going to want to know exactly. 210 00:08:37,183 --> 00:08:40,320 Exactly. And it's not required. 211 00:08:40,320 --> 00:08:44,090 And some IRBs will, do an even shorter period. 212 00:08:44,090 --> 00:08:46,059 So here at the Clinical Center, 213 00:08:46,059 --> 00:08:47,861 I think I'm going to mention this 214 00:08:47,861 --> 00:08:49,662 in another, in another, lecture. 215 00:08:50,096 --> 00:08:53,733 The vast majority of research that happens here is phase 216 00:08:53,733 --> 00:08:56,668 one research very early, first in human 217 00:08:56,668 --> 00:08:57,270 trials. 218 00:08:57,704 --> 00:09:00,030 And when that type of trial is going on, 219 00:09:00,030 --> 00:09:02,008 the IRB might say, you know what, 220 00:09:02,208 --> 00:09:04,210 we're a little worried about that 221 00:09:04,210 --> 00:09:06,212 or we really want to have close, 222 00:09:06,780 --> 00:09:09,176 we want to be very careful about the risks 223 00:09:09,176 --> 00:09:10,717 that people are exposed to 224 00:09:10,717 --> 00:09:13,349 and want to make sure that everything is moving 225 00:09:13,349 --> 00:09:13,853 forward. 226 00:09:13,853 --> 00:09:16,322 We want to review you in six months. 227 00:09:16,322 --> 00:09:19,142 So the IRB always has the option to ask 228 00:09:19,142 --> 00:09:21,961 for something earlier if they want to.