April 11, 2018 Letter to the HHS Secretary

The Honorable Alex Azar
Secretary of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C.  20201

Dear Mr. Azar:
On behalf of the Secretary’s Advisory Committee on Human Research Protections (SACHRP), I respectfully submit for your consideration recommendations relevant to the Department of Health and Human Services (HHS) human subjects protection regulations at 45 CFR part 46.  These recommendations were presented to SACHRP by the co-chairs of SACHRP’s two subcommittees, the Subcommittee on Harmonization and the Subpart A Subcommittee, and were approved on March 14, 2018.
SACHRP’s charge to the Subcommittee on Harmonization (SOH) is to identify and prioritize areas in which regulations or guidelines for human subjects research adopted by various agencies or offices within HHS would benefit from harmonization, consistency, clarity, simplification and/or coordination.  The Subcommittee develops recommendations for consideration and possible adoption by SACHRP to harmonize and simplify these guidelines and regulations.  The goal of this subcommittee effort is to reduce unnecessary burdens on research efforts, thus resulting in better allocation of research resources and promoting the safety and welfare of human subjects.
SACHRP’s charge to the Subpart A Subcommittee (SAS) is to review and assess all provisions of subpart A of 45 CFR part 46 (HHS’ codification of the Federal Policy for the Protection of Human Subjects, also known as the Common Rule) and relevant Office for Human Research Protections (OHRP) guidance documents, and based on this review and ongoing assessment, to develop recommendations for consideration by SACHRP in three categories: 
(1) recommendations on interpretation of subpart A provisions; (2) recommendations for development of new, or modification of existing, OHRP guidance; and (3) recommendations for possible revision of subpart A.
The goals of this review and assessment of subpart A of 45 CFR part 46 are threefold: (1) to enhance the protection of human subjects; (2) to reduce, where possible, regulatory burdens that do not contribute to the protection of subjects in a meaningful way; and (3) to promote scientifically and ethically valid research.
During the March SACHRP meeting, this committee approved the following sets of recommendations for consideration:
1. FAQs, Recommendations, and Glossary: Informed Consent and Research Use of Biospecimens and Associated Data
2. Implementation of the European Union’s General Data Protection Regulation and its Impact on Human Subjects Research
3. FAQs and Recommendations Relating to Broad Consent 
4. Points to Consider: Granting Exceptions to Requirements for Single Institutional Review Board Review for Multi-Site Research
On behalf of SACHRP, I would like to thank you for your consideration of these recommendations. The committee, the Subpart A Subcommittee and the Subcommittee on Harmonization have been actively working in pursuit of their charges, and remain dedicated to continuing this work to enhance human subjects protections for the benefit of all Americans.
Stephen Rosenfeld, M.D.
Chair, Secretary’s Advisory Committee
on Human Research Protections
cc:   Jerry Menikoff, M.D., J.D., Executive Secretary, SACHRP
        Julia Gorey, J.D., Executive Director, SACHRP
Meeting Members:
Sandra H. Berry, M.A.
Senior Behavioral Scientist
Chair, Human Subjects Protection Committee
RAND Corporation
Santa Monica, California
Diana T. Chingos, M.S., M.F.A.
Patient Advocate in Research
Los Angeles, California
Holly Fernandez-Lynch, J.D.,
M. Bioethics
Harvard Law School
Cambridge, Massachusetts
Jonathan Green, M.D.
Washington University
School of Medicine
St. Louis, Missouri
Nancy M.P. King, J.D.
Wake Forest University
Winston-Salem, North Carolina
Reed E. Pyeritz, M.D., Ph.D.
University of Pennsylvania
Philadelphia, Pennsylvania
Stephen Rosenfeld, M.D., M.B.A.
Quorum Review IRB
Seattle, Washington
Leslie Wolf, J.D., M.P.H.
Director of the Center of Law, Health and Society
Georgia State University
Atlanta, Georgia
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