Sunday, January 21, 2007

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.


Working said...

Yeah, I had to deal with that recently. It really stinks :(

Dr. O. said...

I feel like I have "naive" stamped on my forehead, I thought it was a joke when I first saw it on the instructions documents!

Experimentaholic said...

I already despise the IRB. I really would exterminate them all if I could. It is one thing for medical research supported by drug companies that require extensive review, but for sociology or psychology projects? I find the IRB itself an ethnically dubious agency - if they start charging me for reviewing grants I will seriously go apeshit and leave academia. I can make twice as much and work half as hard consulting and not have to wrestle with the IRB's ridiculous and petty lawyer-like requests to change the word "cognition" to "thinking" because they think the average psychology major at my university is too stupid to understand the word cognition. Argh! Friggin A!

Dr. O. said...

Hey experimentaholic! I wish I could say that my situation is rare. I'm doing recon, I attended a grants administrators seminar last week and am looking up NCURA (national association for college research administrators) to try to figure what is up. I still can't find the rationale behind charging one's own scholars to do the work that one has asked them to do -- but at least in my department, it does not include my little intramural grant. I wanted to go to a few other agencies and try for something in the realm of $10-15K but I'll have to see if I write in a line for "proposal review charge?"

Will keep you posted.

And I completely agree with you on the pettiness of some of the IRB stuff. I just sent in a proposal, and I am hoping that my abstract was "lay" enough. Some of what I am writing about doesn't get described by laypeople, and I'm hoping that simple clarity will be sufficient. It isn't jargon, IMHO, if you are using the only term for a thing, you know?

Mel said...

How odd, this is now my third time trying to post this comment. I think blogger hates me.

Anyway, this is Mel and I HATE IRB. The IRB is not efficient enough to even THINK about charging fees.

You know the project I am trying to work on? The IRB delayed me for three months, then didn't tell me I needed another group to approve me. Thanks guys.

Dr. O. said...

MEL! Welcome! I am so glad to see you here! I am sorry about the IRB thing. I am going through that with the methods class I am teaching, we may have to go through full review which means scrap the idea that they can use the data for anything other than the course paper because for sure we won't make it in time. SO frustrating!

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