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  • Open Comment Period: August 17 - September 8, 2017


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Comments Sep 7, 2017 7:23 pm

I checked the Belmont Report again, and found that there were several ways that the currently proposed policy fails to meet the ethical obligations that we are required to meet in conducting research.  I have highlighted the relevant parts below:

  1. Beneficence.-- Persons are treated in an ethical manner not only by respecting their decisions and protecting them from harm, but also by making efforts to secure their well-being. Such treatment falls under the principle of beneficence. . . . In this document, beneficence is understood in a stronger sense, as an obligation. Two general rules have been formulated as complementary expressions of beneficent actions in this sense: (1)do not harm and (2) maximize possible benefits and minimize possible harms. . . . .

The obligations of beneficence affect both individual investigators and society at large, because they extend both to particular research projects and to the entire enterprise of research. In the case of particular projects, investigators and members of their institutions are obliged to give forethought to the maximization of benefits and the reduction of risk that might occur from the research investigation.

  1. Justice.-- Who ought to receive the benefits of research and bear its burdens? This is a question of justice, in the sense of "fairness in distribution" or "what is deserved." An injustice occurs when some benefit to which a person is entitled is denied without good reason or when some burden is imposed unduly. Another way of conceiving the principle of justice is that equals ought to be treated equally. . . . .

I particularly note that not only PIs, but also the institution is "obliged" to to consider minimization of risk, and maximization of benefit, and also that it is unjust when some burden is presented unequally.

A second issue is that of Justice -- that we would be imposing a different burden on individuals who were and were not citizens.  

I appreciate that the IRS would like to know about possible taxable income, but I'm guessing that there are not that many people who make a lot of money from participating in research (and thus, a relatively low amount of money that the IRS would get from this procedure).

In contrast, complying with this procedure would violate U.S. ethical standards for research that have been in place for over 40 years, and make it even more difficult to conduct the research that would address significant issues that we face.

Are we really choosing to do something that MIGHT get the IRS a little money, over the option of being ethical, beneficent, and just?   Can't we use the Belmont principles to explain why we cannot comply with their request? eharri20@uic.eduSep 7, 2017 6:28 pm

I am a research assistant at UIC. I am strongly in support of the change to allow one advance per approved IRB protocol. Currently, we are required to put multiple studies under one advance which is a complicated, difficult and error-prone system. The change allowing one advance per protocol will save me a great deal of time and frustration. Thank you for making this change and I hope to see it implemented soon. Sep 6, 2017 5:39 pm

Thanks for the opportunity to comment. The requirement for identification is not a possibility for many kinds of studies that pay participants.  Research ethics as well as official IRB Board requirements for confidentiality do not allow release of identities for many types of participants, in order to protect people from harm.  Please adjust the policy to acknowledge this consideration. Anna C. Roosevelt, Anthropology, UIC Sep 6, 2017 10:20 am

There are 2 major issues with this policy.

1. Open a Program Advance to Pay Human Subjects in Cash or Cash Equivalents: The policy statement says "A program advance custodian may have only one outstanding program advance per Institutional Review Board protocol." Nowhere in this statement does it inform business office staff or researchers that an exception must be obtained in order to have a program advance for each IRB protocol, and nor does it explain how to/where to request the exception.

2. Reconciliation of a Program Advance: The policy statement says "A program advance must be reconciled at least every 90 days from the advance start-date or last reconciliation date to meet fiscal and calendar year tax reporting requirements; however, OBFS recommends monthly reconciliation." Nowhere in this statement, or anywhere in the entire policy including the definitions section that contains the definition of a reconciliation, does it explain what constitutes an acceptable reconciliation or acceptable documentation that a reconciliation has been done. By acceptable, I mean a reconciliation that would be accepted by the University of Illinois Audit Office. For example, researchers are being required to directly tie back/reconcile the actual data collected from surveys to the payments that were made to the human subject participants who completed the surveys. Signed receipt of payment forms/consent forms from the participants alone are not sufficient documentation to complete a reconciliation. This policy does not provide any details for researchers on what documentation needs to be collected and how to complete a reconciliation of the documentation to the data that was collected. Aug 29, 2017 2:43 pm

The proposed changes still do not address some concerns of some faculty regarding privacy/confidentiality of our research participants as well as how these align or not with UIC's misson and strategic planning.   I encourage more discussion of this (perhaps a townhall?) before it is finalized as it directly impacts the work we do as a public research university. Aug 28, 2017 6:28 pm

This policy lacks the instructions on documentation requirements of the PI/Researcher that both internal and external auditors expect business offices to verify and reconcile at the time of advance closure and/or an advance refurbish.

Although the policy allows for a PI to have multiple advances in their name for different projects, it appears no one has communicated this to payables, as they are still rejecting cash advance requests. 

University Payables needs training and a professional understanding of Human Subject research.  The lack of this understanding has caused many delays in advances and inefficiencies in human subject processing.

PIs do not ask participants if they are US Citizens when sending a survey or conducting a focus group.  Will this be required of them in the future to assess if they are a foreign national or a nonresident alien.  Lack of included instruction for the PI will result in us not obtaining the correct payment information/documentation.

Should the policy contain the methods of human subject payments (Cash, Check, MTurks, Gift cards, amazon e-codes) and the procedures and policies of each.

This policy states an advance cannot exceed $10,000, however payables changed my advance to $9000 due to IRS rules and regulations.

Should the policy be more specific in regards to if the custodian failed to safeguard the advance or allowed it to be improperly used, the custodian must repay the money FROM PERSONAL FUNDS.  This suggests they can use ICR or unrestricted funds if they have such funds. 

Procedures specifically for Mturks or Amazon e-codes would be good, an internal auditor recently advised us to go into TEM and pull the documentation and to have it in the statement document files.  This is not something we knew to do.  We should be using the internal audits for a guide of how to do things and what documentation to have where for checks and balances to Human Subject payments.

The policy should include information regarding the need to close or replenish an advance on or before June 30th and on or before December 31st and the reasons why. 

On the map, it suggests that we obtain the full/legal name of HS and keep signature verification receipt of payment.  How do we know if it is their legal name, do the directions that PIs do not have instruct them to ID someone, or ask for a legal name?  Should there be additional information on what a signature consists of?  Again, the internal auditor dismissed 3 cash receipts because the participant did not sign in cursive.  Is this a requirement, and can we tell a human subject participant that their signature is unacceptable? Aug 28, 2017 2:13 pm

1. The document should specify whether human subjects can be paid through the use of electronic money transfers such as PayPal transfers. 

2. The document should specify (with examples) what qualifies as a receipt for human subjects payments. Do the receipts need to show only the total paid, or must the receipts show the payments to each individual subject? The policy should recognize that human subjects are now being recruited through online work platforms such as Mechanical Turk and small payments may be made to tens of thousands of subjects in a single experiment. In addition, the policy should specify what information must the subject provide (or be provided about the subject) in the receipt? Aug 26, 2017 1:21 pm

The proposed changes still do not get to the core of the issue concerning payment of research subjects based on immigration/residency/citizenship status, as the proposed solution is essentially a "don't ask, don't tell" policy. As a faculty member, I am concerned that the mere mention of immigration/residency/citizenship status when recruiting research subjects would distance and alienate exactly those vulnerable communities our university is most committed to. I think the proposed changes regarding resident/non-resident status contradict the values of beneficence, privacy, and confidentiality that are required when performing research with human subjects, contradict UIC’s strategic priorities and overall mission and generate an additional bureaucratic burden on research faculty and staff. Aug 25, 2017 12:35 pm
  • Increases threshold for collection of tax identification numbers for human subject payments from $100 to $200 per calendar year.
  • Incorporates and updates the language currently in Section 18.10 to address IRS tax reporting requirements for payments to non-resident aliens.
  • Establishes an “if known” standard to requesting tax identification information for non-resident aliens.

These revisions attempt to get at the issues, but they really DO NOT!

The proposed changes DIRECTLY contradict the Belmont Report principle of beneficence AND go against IRB concerns about ensuring privacy and confidentiality when performing research with human subjects.

The proposed changes DIRECTLY contradict one of UIC’s strategic priorities, i.e., Chicago and Community Involvement. From my research with Latinos I KNOW that simply bringing up immigration/residency/citizenship status when recruiting participants WILL distance and alienate exactly those vulnerable communities our university is most committed to!

The proposed changes add yet another layer of bureaucracy in the payment/reporting process, and it unnecessarily creates additional burden to my research faculty and staff (and that of other investigators). Aug 25, 2017 11:49 am

The section in 18.10 on payments to nonresident aliens now reads: "Payments to human subjects that are known to be nonresident aliens, or payments to human subjects the University has a reason to know the individual is a nonresident alien, must meet IRS tax reporting requirements." The phrase "has a reason to know" is ambiguous, and creates an impossible dilemma for researchers. What is a "reason to know," and what would constitute evidence that such a reason exists? A requirement to ask about residency status would require researchers to violate the fundamental principles of privacy, confidentiality and beneficence in consenting subjects. The "reason to know" language simply makes this problematic requirement unclear, rather than removing it. Aug 25, 2017 8:21 am

I am deeply concerned by the proposed adjustments to the policy regulating research at UIC because, rather than guaranteeing the proper access to human subjects, avoids the issue through a "don't ask, don't tell" policy that was a complete failure in the military and anywhere else it has been tried.  As an immigrant and a person that works with vulnerable populations, I am fully aware that any checks on immigrant status or even the supicion that their identity can be compromised biases research completely: not only can people choose not to participate or provide false information to protect themselves. Furthermore, in my opinion this measure actually violates the freedom of speach constitutional right.  I believe these matters should be completely removed from research as they should when it comes to persons seeking the services of the university. Aug 18, 2017 11:50 am

Complex research projects may require a program advance to pay human subjects for longer than 18 months. I recommend addressing how to manage these type of requests from research faculty.  In terms of closing or replenishing a program advance,  clarify what is the information that is needed/required on the receipt for a participant compensated in a confidential study.  We had been asked to get signtures on receipts and more recently informed to provide a study ID number.