| Overview
If an organization conducts research, then
it should adhere to research guidelines
and practices, as well as ethics, when clients
are involved in research activities.
Accreditation Requirement(s)
- All organizations involved in human
research activities should follow standard
research protocols, guidelines, and ethics.
Implementation Tips
Some Implementation Tips provided, in part, by Robert Johnson at: www.accreditationnow.com.
- This standard does not apply to the
outcomes management system in place at
the organization, which is usually based
on data collection and client/family/stakeholder
satisfaction. The research standard
is only applicable if clients are
part of a research study that is part
of an experimental design. For instance,
to determine the efficacy of a particular
medication, some clients could receive
the medication; others (part of the control
group) may not receive the medication.
- It is extremely important for organizations
to have research policy and procedures
in place that protect the rights of persons
served and, in addition, protect the organization
and its staff members from liability.
Over the past two decades, national and
international regulations concerning human
research have been strengthened considerably.
- Behavioral healthcare organizations
have traditionally been somewhat less
stringent with regard to research regulations,
as research practices have tended to be
less invasive when compared to medical
human research. However, with the increased
focus on rights of persons served, risk
management, and corporate compliance,
it is recommended that all behavioral
health organizations have research policies
that are comprehensive and fully cover
all aspects of research conducted within
the organization.
- The Federal Government adopted a very
comprehensive human research policy in
1991 (45 CFR 46.116), and all government
agencies, with the exception of the Food
and Drug Administration, adhere to the
policy. That policy can be accessed at
www.hhs.gov/ohrp.
- In addition, the Privacy Rule (45 CFR
160 and 164), which was created by the
Health Insurance Portability and Accountability
Act of 1996 (HIPAA), has specific guidelines
regarding consent and authorization to
conduct research with persons served.
That policy can be accessed at www.aspe.hhs.gov.
- The sample policy provided follows
the general outline of 45 CFR 46.116,
includes guidelines from 45 CFR 160 and
164, and also includes additional components
that are specific to behavioral healthcare
organizations.
- Informed consent is a key component
of any research project and is not merely
a form. It is a process in which information
must be presented in a manner that allows
persons to voluntarily decide if they
want to participate in research. This
is an education process that should be
provided in "lay language" and
constructed as a teaching tool in addition
to providing legal protection.
- Informed consents for research should,
at a minimum, contain the following:
- A statement of the study involved
- An explanation of the purposes of
the research
- The expected duration of the subject's
participation
- A description of the procedures
to be followed
- Identification of any procedures
that are experimental
- A description of any reasonably
foreseeable risks or discomforts to
the subject
- A description of any benefits to
the subject or to others
- A statement that participation is
voluntary and refusal to participate
will involve no loss of rights
- An explanation of whom to contact
for answers to pertinent questions
about the research
- Informed consent for research requires
a written form to document the process
of informing the research participants
of the required information and documenting
their acceptance through a legal signature.
However, all of the elements as described
above do not have to be written on the
document and may be presented orally.
When an oral method is used, however,
there must be a witness to the process.
- It is recommended that an Institutional
Review Board (IRB), as described in the
policy, exist in all behavioral healthcare
organizations that conduct research or
allow outside researchers to access their
system to conduct research. Many organizations
do not conduct internal research but allow
outside entities, through affiliations
with universities and colleges, to conduct
research within their systems. It is equally
important that the organization protect
itself by requiring the IRB to review
and approve research conducted by an outside
entity, rather than assuming that the
outside organization's research approval
system is meeting the organization's legal
needs.
- In certain circumstances it is permissible
to pay research participants with the
most common form of payment to assist
persons to defray the cost of participation.
Be extremely careful in this area. If
a token payment is being made to assist
in participation, ensure that it is applied
equally and that the amount or method
of payment is not coercive in any manner.
- The schedule and number of meetings
of your IRB should be dependant on the
amount of research being conducted in
your organization. For example, if your
organization does not conduct internal
research, your committee may want to meet
on an as needed basis. Determine what
your needs are and add this element to
your policy.
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