COVID-19 and Human Subjects Research Activities - Updated March 16, 2022
This webpage was substantively updated on March 16, 2022 to provide guidance to the Brown University research community and align with updated University policies as they apply to human subjects research activities on-campus at Brown, at field sites and venues off-campus, and at international research sites. It is the responsibility of Principal Investigators or their study teams to check this site regularly for updates and to be familiar with the University's policies.
Brown continues to prioritize public health and the safety of faculty, staff, and students, while also maintaining our ethical obligation to protect individuals who volunteer to participate in research.
- Plans to conduct human subjects research activities that involve in-person procedures must align with all Brown policies, guidance from public health authorities and, when applicable, State of Rhode Island requirements.
Research Participants and Brown's Visitor and Guest Vaccination Policy:
- Brown's Visitor and Guest Vaccination Policy contains an FAQ specific to research participants. Human subjects research participants completing study procedures on Brown's campus are considered limited-duration visitors. These participants must abide by the COVID-19 Campus Safety Policy and any requirements specific to the facility or program they are visiting. Researchers who have questions about requirements relevant to participants should email [email protected].
Brown's MRI Research Facility (MRF):
If approved research requires use of the MRI, Brown will provide disposable surgical-type masks to research participants undergoing the MRI. Please see below for PREP Act language that must be included in consent documents when a study participant will be entering the MRI as part of a research procedure. The MRF will revisit the requirement for participants to wear a mask in the scanner in the coming weeks as they continue to monitor COVID-19 rates in Rhode Island.
- The MRF retains the authority to decide the spacing between scans and to determine appropriate masking requirements in accordance with Brown Policy.
Research participants are considered limited-duration visitors in accordance with Brown Policy and related guidance. Research participants who are fully vaccinated are no longer required to wear a mask when coming on campus for human subjects research procedures, in accordance with the COVID-19 Campus Safety Policy.
The Principal Investigator of any human subjects research study has the flexibility to require that masks be worn by all research participants and research personnel for human subjects research activities occurring on campus. Research participants should be made aware of this requirement in advance of traveling to campus.
All proposed field research must undergo review in accordance with Brown's Field Research - COVID Safety Guidelines and Procedures for Fall 2021.
- Research conducted in community settings in Rhode Island or other sites within commuting distance is permitted, provided investigators have permission of the facility to conduct research on-premises, and investigators adhere to all requirements of the facility (e.g., use of facial coverings, social distancing, and any other enhanced safety precautions).
All faculty, students, and staff must abide by Brown’s Travel Policies.
Please note that if the purpose of travel is to carry out field research, approval must be sought by the PI from the Field Research Subcommittee. Details regarding this process can be found here.
Researchers conducting international field research may conduct IRB/HRPP-approved in-person human subjects research activities if permitted in accordance with country-level and location-specific public health requirements. No exceptions to country requirements will be permitted (i.e., conducting biospecimen collection if social distancing is required).
- All researchers who plan to resume or begin in-person human subjects research activities abroad must submit an International Research Attestation Form to the HRPP with the new IRB Application or IRB Revision Request Form and receive approval prior to commencing human subjects research activities. The review and approval process may involve seeking additional information from the PI. Please note that these activities must include health and safety measures to be taken by Brown students, staff, or faculty as set forth in the attestation, including any health and safety measures (e.g., wearing a face covering) required at the international site.
A health screening must be conducted with each study participant prior to coming to campus and likely again, upon arrival, depending on how much time elapses between the pre-screening and study visit.
Research participants must be asked if they are experiencing new or worsening signs of possible COVID-19. See the CDC website for more information.
Research participants affirming any of the above symptoms must be rescheduled. In addition, research participants must be asked if they:
- Have tested positive as a result of a COVID-19 test.
- Have been in contact with anyone who has had positive COVID-19 test or someone suspected of having a case of COVID-19 and are currently under quarantine/stay-at-home orders.
If either of the above is endorsed, the research participant’s study visit must be rescheduled.
The Secretary of HHS issued a Public Readiness and Emergency Preparedness (PREP) Act Declaration for certain COVID-19 countermeasures on March 10, 2020. In August and September 2020, the FDA and HHS released expanded guidance, allowing Brown to refine the applicability of the COVID-19 countermeasures covered by the Declaration and update the required consent language.
When does the PREP Act not apply?: Brown requires that all participants wear an appropriate face covering to protect themselves and those around them when they come to campus. If a participant visits without a face covering or the face covering does not meet Brown requirements, the University will provide them with a face covering.
When does the PREP Act apply?: The PREP Act only applies to Brown research protocols which specifically provide covered countermeasures (i.e. face masks, face shields, gowns) to participants as part of an approved research procedure, instead of allowing participants to use a face mask they may have for personal use. For example, due to the safety protocols at the MRI Research Facility (MRF), participants asked to use the MRI as a research procedure, are required to wear a face mask provided by the MRF that is safe to use in the MRI.
Consent Form Language for COVID-19 Countermeasures
Human subjects protection regulations require that participants be informed if any of their legal rights are affected, and what recourse is available. To comply with this, Brown University requires that the following additional statement be included in study consent documents.
**As a note, this additional language is unique to COVID-19 countermeasures and does not replace the risks of study procedures that must be included in order for participants to make an informed decision about study participation.
"Due to the coronavirus public health emergency, the U.S. government issued a Declaration under the Public Readiness and Emergency Preparedness (PREP) Act. This Declaration may apply to this study if it involves procedures or other actions that are related to or in response to coronavirus. If it applies, this Declaration limits your right to sue the researchers, healthcare providers, study sponsors, manufacturers, distributors, and potentially others that are involved with this study. However, the U.S. government has a program that may provide compensation to you or your family if you experience serious physical injuries or death related to procedures or other actions taken in this study. To find out more about the 'Countermeasures Injury Compensation Program,' please visit https://www.hrsa.gov/cicp."
The COVID-19 pandemic affects everyone and those experiences may be situational across participant populations. If you intend to use surveys, interviews, or measures, etc. on or about the effects of COVID-19 as a research procedure, please include the following with your submission:
1) A risk assessment of the impact the questions may have on your study population. This assessment must address if the questions you ask about COVID-19 increase risk for participants beyond the other activities involved in your study. Include this brief assessment in the risk assessment section of your submission form.
2) A list of resources/referrals for participants and a description of how / when the list will be provided to participants. This list must be applicable to the study population and research topic with easily accessible contact information. Some available resources can be found on the COVID-19 Resources page.
Q: What technology options does Brown recommend for the conduct of remote procedures?
If your IRB Application or Revision Request involves platforms not already vetted by OIT, then it will take longer to start your research. As such, the HRPP/IRB strongly encourages you to use OIT-approved platforms in your research unless there is a valid scientific reason not to do so.
Brown OIT and the IRB/HRPP strongly recommend Zoom be used for all remote procedures that involve remote, face-to-face interactions with participants. This includes administering interventions via video conferencing. Zoom is an OIT-vetted platform and is secure to use for all data risk levels, including Risk Level 3 data.
For studies that wish to use a HIPAA-compliant version of Zoom, please submit a ticket to [email protected] for your request to be authorized. The HIPAA-compliant version of Zoom does not allow for any cloud-based recording. Instead, it will only allow for recording locally, meaning that you must have encryption turned on for the device you will use for recording (i.e., Brown-owned laptop) or saved directly to a Risk Level 3 compliant local server.
QUALTRICS & REDCaP
Brown OIT and the IRB/HRPP strongly recommend Qualtrics be used for remote data collection procedures. Qualtrics is an OIT-vetted platform and is secure to use for all data risk levels, including Risk Level 3 data. If a Brown investigator has a co-investigator/collaborator at an affiliated site with an instance of REDCaP, it, too may be used for data collection for all data risk levels including Risk Level 3 data.
Q. I am already at my international study location. May I resume research involving in-person interactions with research participants?
Researchers currently located abroad at their planned study location may resume in-person human subjects research activities if permitted in accordance with country-level and location-specific public health requirements. No exceptions to country requirements will be permitted (i.e., conducting biospecimen collection if social distancing is required).
All researchers who plan to resume in-person human subjects research activities abroad must submit an International Research Attestation Form to the main IRB email address and receive approval prior to commencing those activities. The review and approval process may involve seeking additional information from the PI.
Q: How do I know if the activities I am proposing are public health surveillance and not human subjects research?
The Revised Common Rule provides the following description of public health surveillance activities that are deemed not to be research (and, therefore, do not require IRB review):
"Public health surveillance activities, including the collection and testing of information or biospecimens, conducted, supported, requested, ordered, required, or authorized by a public health authority. Such activities are limited to those necessary to allow a public health authority to identify, monitor, assess, or investigate potential public health signals, onsets of disease outbreaks, or conditions of public health importance (including trends, signals, risk factors, patterns in diseases, or increases in injuries from using consumer products). Such activities include those associated with providing timely situational awareness and priority setting during the course of an event or crisis that threatens public health (including natural or man-made disasters)."
A "public health authority" means "an agency or authority of the United States, a state, a territory, a political subdivision of a state or territory, an Indian tribe, or a foreign government, or a person or entity acting under a grant of authority from or contract with such public agency, including the employees or agents of such public agency or its contractors or persons or entities to whom it has granted authority, that is responsible for public health matters as part of its official mandate." The Rhode Island Department of Health, as an example, would meet the definition of a public health authority.
If your proposed activities do not meet the above description and instead the collection of data will be used in whole or in part for research purposes, an IRB Application will be required.
Please note that if you're submitting a grant application to the NIH and believe that you will be conducting public health surveillance activities, you must follow the requirements in this NIH Notice.
Q: If I am conducting public health surveillance activities, can I still publish?
Yes. A determination that an activity is public health surveillance and not human subjects research has no bearing on your ability to publish your work.
Yes! As outlined in 42 CFR 11.64(a)(1)(ii), if a protocol is amended in such a manner that changes are communicated to human subjects in the clinical trial, the regulations require that updates to any relevant clinical trial information be submitted not later than 30 calendar days after the protocol amendment is approved by a human subjects protection review board. Additional details can be found in the clinicaltrials.gov FAQs.
It remains important to ensure that accurate and up-to-date clinical trial information is available to the public on ClinicalTrials.gov, particularly for COVID-19 related research. However, due to the potential exceptional impact of this public health emergency on research-related staff availability, NIH acknowledges that delayed updates and corrections may be unavoidable. Refer to the Top Questions from Responsible Parties Related to COVID-19 for information on specific questions.
NIH will allow late submission of results reporting for recipients covered by the NIH Policy on the Dissemination of NIH-Funded Clinical Trial Information that are unable to submit results reporting information on-time in ClinicalTrials.gov due to COVID-19. Recipients should notify the funding Institute of Center (IC) of the delay along with documentation of the effects of COVID-19 on the study.