In which Dr. O naively asks: WTF with IRB fees?

It seems I have been living and laboring under a rock. At some point between when I graduated not-that-long-ago with my Ph.D. and now, Human Subjects Boards or Institutional Review Boards (IRBs) started charging fees to do their jobs.

I've been all over the web this afternoon, googling "IRB fees" and "sponsored research review fees" and the like. Obviously this isn't an exhaustive search. Still, I've read a sufficient number (25+) of "here is why we decided to start charging, and here is how we are doing it" notices to come up with basic observations:

1. The trend seems to have started in the early 2000s; most addenda and notices of fees are dated after 2001.

2. Most fees are attributed to the greater number of research projects being reviewed. The fee is noted as a line addition that will be billed to the sponsor of the research directly. Often the IRB tosses in a line about how such fees have become "common," and that many other universities are doing the same thing.

3. The fee does not supplant, replace, or augment the previous university charges tacked onto grant applications. That overhead is still there, and this fee does not roll into the same pool. What we have here is the "shipping and handling" of academia.

4. Most boards, but not all, note that only those projects sponsored by private industry will require a review fee.

5. Fees vary, generally from $1000 - $2000 for initial submission. Some IRBs designate the fee as all-inclusive. Others tack on an amendment fee of around $500-750 if the project has to go back through review for any reason.

6. Some note that if the fee is not paid, the protocol will not be reviewed, or if it is reviewed then consent will be withheld until the fee is received.

I get that universities are on the bureaucratic-entrepreneurship treadmill these days. I know that phrases like "best practices" have leached over from business to academia, that "soft money" is making gains on guaranteed funding. But there is something about this IRB development that sours me even further on human subjects boards. And that is saying something. Dr. O and Human Subjects shake hands, get along in public, but we don't go for beers if you know what I mean.

Here are the issues/questions I have for the IRB boards out there who passed "we are going to charge you now" policies:

* If you haven't limited your fees to industry-sponsored research, how can researchers who get small grants justify paying up to a quarter of their award (or sometimes more!) to you, just for the joy of getting permission to do their work? Do you think that maybe granting agencies will see this and hold it against an application?

* If non-industry grants are targeted by a given board, has that university removed any requirements for getting grants from the tenure and promotion process of those scholars who are in the smaller-grant-world of the humanities and social sciences?

* Why is there no uniform fee for review? Are we going to argue that one IRB is "better" than another (the merit model)? Are we going to argue that the busier the IRB, the higher the fee (making it about demand)?

* Why if this is truly necessary is there no nationwide policy? Why do some schools have such a fee and not others? Does name recognition have anything do do with it (university as 'market brand')?

* What does charging this fee do to reduce the amount of research that comes across the desks of the Board? Isn't it the job of this body to review research, for ethical purposes?

* If volume of protocols to be reviewed does not continue to drop, what is to prevent any given university from requiring professors to pay for review of non-sponsored protocols? Lest anyone out there scoff, I would ask that we all take a moment to think on parking fees. You would think that we would not be charged money by our employers so that we might feasibly do our jobs, but there you have it. The argument supporting parking fees also centers around increasing demand on limited resources.

* We'll pretend for a moment that academic paychecks are reasonable compensation for scholars' level of education and expertise. Let's consider ethics instead. The IRB exists to enforce a code of ethics. Is it not ethically questionable in the extreme for a university board to charge a potentially sponsoring group a fee for the review of a proposal for research to be done that might benefit said group? How about if each additional revision/review requires an additional payment, will the board be a bit 'pickier'? If an investigator suggested doing such a thing, his or her friendly neighborhood IRB would scream "coercion!!!!" before the undergrad work-study admin assistant could get back with the sub order from Quiznos. I have had a protocol hung up with a call for revisions because my offer of $20 to participants was seen as potentially coercive. I ask you.

I don't like this much. Not at all.