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Health Researchers’ Ancillary-Care Responsibilities in Low-Resource Settings:
The Landscape of Institutional Guidance Carleigh B. Krubiner, Raafay H. Syed, and Maria W. Merritt
1 Bold font in the right-most column tracks position taken, if any. If the issuing institution takes no formal position
in the document, we use bold font only for the designation “No position,” leaving in standard font any reports of
recommendations or requirements entertained within the document in the absence of formal institutional
endorsement.
Appendix III.
Detailed Positions on AC Responsibilities by Institution and Document Institution Documentation Positions on Specific Ancillary-Care
Responsibilities1
AstraZeneca PLC “Research Ethics” webpage,
accessed 15 Jan. 2013
No position: no mention of any specific AC
responsibility
AstraZeneca Global Policy:
Bioethics, accessed online
15 Jan. 2013
No position: no mention of any specific AC
responsibility
Australian National
Health and Medical
Research Council
Challenging Ethical Issues
in Contemporary Research
on Human Beings (2006)
No position: no mention of any specific AC
responsibility
National Statement on
Ethical Conduct in Human
Research (2007)
No position: no mention of any specific AC
responsibility
CIOMS International Ethical
Guidelines for Biomedical
Research Involving Human
Subjects (2002): Guidelines
7 and 21 with commentary
Advance agreement with the “sponsor,
officials of the host country, other interested
parties, and, when appropriate, the community
from which subjects are to be drawn” is
recommended regarding all health care
services, including AC, that will be made
available during the research.
AC referral is recommended.
Direct provision of AC is recommended
(“morally praiseworthy” although not
obligatory) under Guideline 21 (and, in
addition, under Guideline 7, is explicitly
permitted as a form of compensation, so long
as medical services provided free of charge are
not so extensive as to be undue inducement.)
Democratic Rep. of
Congo: Groupe
Interproject de
Reflexion et
d’Intervention en
Ethique (GIRIE)/
Centre
Interdisciplinaire de
Bioethique pour
L’Afrique
Francophone
(CIBAF)/Kinshasa
School of Public
Workshop documented in
paper titled “Engaging with
research ethics in central
francophone Africa:
reflections on a workshop
about ancillary care,” by
Tshikala et al. (2012), and
resulting in “Statement
Issued by the Workshop on
the Ethics of Ancillary Care
in the Context of Research
Conducted in the
Democratic Republic of the
Advance planning and agreement are
recommended (p. 4-5).
AC referral and direct provision of AC are
required (a) under “the ‘duty to rescue’:
“when a research participant urgently needs
medical help, . . . the researchers should
respond as any human being would to the
suffering and helplessness of another person”
(p. 5); and (b) under specified conditions as
determined by an ancillary care committee to
be constituted as a subcommittee of a research
ethics committee, as part of the prospective
and continuing ethical review of each research
Health (KSPH) Congo” to be presented to
the National Health Ethics
Committee of the DR
Congo and to the DR
Congo Ministry of Health
protocol (p. 5 and Figure 1, p. 6).
Capacity development is recommended as a
means of meeting AC needs: “When specific
ancillary care needs can be clearly anticipated,
researchers should work with local
communities to create or bolster existing
services to meet those needs, and the service
costs should be reflected in the research
budget” (p. 5).
Dutch Ministry of
Foreign Affairs—
Directorate General
of Development
Cooperation
No publicly available
guidance No position
Eisai Co. Ltd. No publicly available
guidance No position
Eli Lilly &
Company “Principles of Medical
Research” webpage,
accessed 15 Jan. 2013
No position: no mention of any specific AC
responsibility
European
Commission Ethics for Researchers
(2007)
Ethics in research and
international collaboration
(2009)
No position: no mention of any specific AC
responsibility
No position: no mention of any specific AC
responsibility
European Group on
Ethics in Science
and New
Technologies to the
European
Commission
Opinion on the ethical
aspects of clinical research
in developing countries
(2003)
No position: no mention of any specific AC
responsibility
Gates Foundation No publicly available
guidance No position
Gilead Sciences No publicly available
guidance No position
GlaxoSmithKline No publicly available
guidance No position
Global Campaign
for Microbicides Mapping the Standards of
Care at Microbicide
Clinical Trial Sites (2008):
Executive summary with
consensus
recommendations
Advance planning and agreement are
recommended by consensus (p. 21).
AC referral is required by consensus under
the conception of “assisted referral” as a
“minimum standard” (p. 21).
Direct provision of AC in the form of “safe,
appropriate contraception” for trial participants
is required by consensus under a “special
obligation” on the part of microbicide trials “to
attend to the sexual and reproductive health
needs of trial participants” (p. 17). Similarly,
direct provision of AC in the form of
screening for cervical cancer is required by
consensus as a “minimum” service to be
offered in settings where follow-up diagnosis
and treatment are available through publicly
supported services (p. 15).
More broadly (as a GCM recommendation
developed by the authors after the workshop,
but not a consensus recommendation)
“[d]onors should make funding available,
within reason,” for possible instances of direct
provision of AC (p. 21).
Capacity development is recommended by
consensus in the form of “offering training to
public-sector providers in screening
colposcopy” (p.15) as a means of improving
participants’ access to public services.
HIV Prevention
Trials Network
(HPTN)/Family
Health
International (FHI)
Partnering for Care in HIV
Prevention Trials: A How-
To Manual (2008): pp. vii
and ix; Chapter 4
Advance planning and agreement are
required.
Executive summary states, “Ensuring the
effective care and treatment of people who are
HIV positive is a critically important
counterpart to the search for methods to
prevent the spread of the virus” (p. vii). AC
referral and direct provision of AC are thus
implicitly required where necessary to
develop a system of effective care, with the
understanding that case-by-case decision
making will be sensitive to any countervailing
considerations (p. 30-32; p. 43-44).
Capacity development sensitive to local
context is implicitly recommended as an
aspect of building relationships with nearby
resources (Step 6) in support of “better health
care for the participants” (p. 33).
Advance planning through “pre-research
community consultation and systematic
assessments” is recommended “in order for
investigators to anticipate at least some of the
ancillary care needs of study participants” (p.
37).
General agreement across the HPTN
regarding “standards for the provision of care
during all HPTN research” is also
recommended.
HPTN
HIV Prevention Trials
Network (HPTN) Ethics
Guidance for Research
(2009): Guidance Point 10
“Investigators, research sponsors, local
governments and international agencies should
strive to provide access to antiretroviral
treatment for those who seroconvert during
HPTN trials, albeit in ways that do not worsen
in-country inequalities.” AC referral and
direct provision of AC are thus implicitly
recommended.
HIV Vaccine Trials
Network (HVTN) “Participants’ Bill of Rights
and Responsibilities”
webpage (revised 2007,
accessed 15 Jan. 2013)
Language addressed to participants in all
HVTN studies asserts that they have the right
to “[r]eferral to available counseling, support,
medical, and treatment services for illnesses
you suffer during the study, including HIV.”
By logical implication, AC referral is
required in such cases.
Indian Council of
Medical Research Ethical Guidelines for
Biomedical Research on
Human Participants (2006)
Advance planning is recommended
regarding AC (p. 15-16, item 12).
AC referral and direct provision of AC are
permitted as forms of compensation so long
as such medical services are not so extensive
as to bring about undue inducement (p. 25);
compare CIOMS Guideline 7 (cited above).
Inserm No publicly available
guidance No position
Institute of
Medicine Ethical Considerations for
Research on Housing-
Related Health Hazards
Involving Children (2005):
Chapter 7 and
Recommendation 7.3
Advance planning is required, as a “role-
specific obligation” (p. 137) on the part of
researchers “to anticipate the risks and
behaviors that may be observed in the home,
including observations that are not part of the
research protocol, develop anticipatory plans
that specify how to assess and respond to risks
when they are identified, and educate their
staffs about the plan” (Recommendation 7.3).
AC referral (e.g., referral to the local housing
authority or local community services) and
direct provision of AC (e.g., an educational
discussion with the head of household) in
response to relevant risks observed in the
home (e.g., mold) are required where
necessary to fulfill the researcher’s “obligation
to do what is reasonable under the
circumstances” (p. 138), with the
understanding that “[t]he appropriate course of
action will depend on the specific situation: the
type of risk identified, who experiences the
risk, the nature of the research project, and the
availability of community resources” (p. 138).
Institut Pasteur The Ethics Charter of the
Institut Pasteur (2009),
Chapter 2: Research on
human subjects
No position: no mention of any specific AC
responsibility
International AIDS
Vaccine Initiative
(IAVI)
Clinical Guidance:
Essential Approaches for
the Conduct of IAVI
Clinical Research (2012):
Sections 8 and 9
According to these “essential processes and
practices required to conduct IAVI-sponsored
research” (Introduction), participants who
become infected with HIV while on study
“will receive referrals to a reputable HIV
treatment centre or institution of [their] choice
for a full discussion of treatment options,
including antiretroviral therapy (ART) when
medically indicated. Alternatively, research
partners may provide a comprehensive
package of HIV care, support, and treatment at
the study centre. Referral systems will be
prearranged, ideally in writing, with HIV and
AIDS treatment centres, and IAVI and its
research partners will work to facilitate
effective referrals” (Section 8). Thus, advance
planning and agreement are required, AC
referral is required, and direct provision of
AC is permitted with explicit availability of
funding (Section 8: “IAVI will provide free
ART [as per national ART protocols] for
clinical trial volunteers who seroconvert
during a trial for up to five years after
treatment is initiated, if not available from
other sources free of charge”).
In addition, IAVI-sponsored researchers
“should ensure robust referral mechanisms”
for “other health issues” (Section 9). AC
referral for conditions other than HIV is thus
recommended.
International AIDS
Vaccine Initiative
(IAVI) with
affiliated Research
Centers (RC) in
Eastern and
Southern Africa
Group discussions and
interviews conducted by
IAVI to reach consensus on
expected standards of care
at participating RCs,
documented in paper titled
“Developing standards of
care for HIV prevention
research in developing
countries—a case study of
10 research centers in
Eastern and Southern
Africa,” by Ngongo et al.
(2012)
Advance planning is recommended for
services to be provided, implicitly including
some AC services (p. 1286).
“A set of required and recommended services
to be provided on-site or by referral was
developed” (p. 1277, Abstract) and listed (p.
1287, Table 4). AC referral and direct
provision of AC are thus implicitly required
in relevant instances.
Capacity development is recommended as a
potential means of meeting some AC-type
needs when the needed referral services (e.g.,
“services sensitive to the needs of criminalized
populations”) “are not widely available”
(p.1286).
International
Conference on
Harmonization of
Technical
Requirements for
Registration of
Pharmaceuticals for
Human Use (ICH)
Guideline for Good Clinical
Practice (1996): 4.3.2
No position: It is recommended that the
investigator inform subjects when medical
care is required for “intercurrent illness(es) of
which the investigator becomes aware.” Some
“intercurrent illnesses” might involve needs
for AC. Nonetheless, the document makes no
mention of any specific responsibility for
advance planning, referral, or direct provision
of needed care.
Johnson & Johnson Our Ethical Code for the
Conduct of Research and
Development, accessed
No position: no mention of any specific AC
responsibility
online 15 Jan. 2013
Kenya, National
Council for Science
and Technology
Guidelines for Ethical
Conduct of Biomedical
Research Involving Human
Subjects in Kenya (2004):
Guideline 7
“The extent of the investigator’s responsibility,
if any, to provide medical services to the
subject” is explicitly listed as an item of
“essential” information with which the
prospective research subject “must be
provided” as part of the informed consent
process (pp. 11-12). Thus, advance planning
regarding subjects’ foreseeable needs for
medical services, which might include AC, is
required, and direct provision of AC
implicitly permitted.
Merck & Co. Inc. Public Policy Statement:
Clinical Trial Ethics (2012)
No position: AC is specifically mentioned, but
Merck will address the issue on a “situational
basis.”
Merck KGaA No publicly available
guidance No position
National Health
Research Ethics
Committee of
Nigeria
National Code of Health
Research Ethics (2007)
No position: no mention of any specific AC
responsibility
Nepal Health
Research Council National Ethical Guidelines
for Health Research in
Nepal (2011): Section C,
5.3.5
Guidance on documentation required for
ethical review states that “[a]ny compensation
to be given to the research participants should
be clearly mentioned” in the application for
ethical review, and “free health care” is given
as an example of such compensation. Advance
planning regarding AC is thus implicitly
recommended and direct provision of AC
implicitly permitted.
Novartis AG Clinical trials in developing
countries (2011)
No position: no mention of any specific AC
responsibility
Novo Nordisk A/S “Clinical trial ethics”
webpage (2012, accessed
29 January 2013)
No position: no mention of any specific AC
responsibility
“Clinical Trials in
developing countries”
webpage, accessed 14
January 2013
No position: no mention of any specific AC
responsibility
Nuffield Council The ethics of research
related to healthcare in
developing countries
(2002): paragraphs 7.33,
7.34, 7.35, 10.34, and
10.35
Advance agreement is recommended (7.35;
10.35).
Paragraphs 7.35 and 10.35 state that “where it
is feasible for researchers to diagnose and treat
an illness which arises, or to ensure that
effective treatment is available at a local level,
they have a duty to do so.” AC referral and
direct provision of AC are thus required
“where it is feasible” and with the
understanding that “[t]his is a complex issue
and decisions will need to be made on a case-
by-case basis following discussion with
clinicians, researchers and representatives of
government and health authorities within the
host country.” (In addition, at 7.33 and 10.34,
the Nuffield Council endorses and generalizes
UNAIDS [2000] Guidance Point 16; it thus
implicitly recommends AC referral and
direct provision of AC where indicated, in the
form of care for the condition being studied,
including HIV, in preventive research.)
A follow-up discussion
paper (2005) 3.18 – 3.28
No position: document contains disclaimers
stating that it “does not reconsider specific
ethical issues addressed in the 2002 report”
(1.6) and that “not all of the views reported in
the Paper were necessarily shared by all of the
delegates or the Nuffield Council” (1.8). It is
nonetheless of note that delegates discussed
specific AC responsibilities as follows:
“Delegates suggested that, in general, there
would be a clear obligation on the researchers
to provide care for the condition under study”
(3.24). For cases in which such care is not
otherwise required to ensure scientific validity
and safety, direct provision of AC would thus
be implicitly required. In the application of
this point to the provision of antiretroviral
therapy (ART) for participants who
seroconvert during HIV intervention trials
(Box 3.5), advance planning and agreement
would be recommended, AC referral would be
implicitly required, and capacity development
as a means of meeting AC needs would be
recommended.
Where a condition unrelated to that directly
under study was present in a participant,
delegates agreed that a suitable referral to the
local health services may be appropriate”
(3.25).
Pfizer, Inc. MRCT Project Report
(2010), p. 52
AC is mentioned specifically, and advance
agreement is implicitly recommended in the
form of negotiation that may include “contract
provisions.”
Direct provision is permitted with a “pre-
determined pool of funds” for AC as a possible
option.
“Compensation to Human
Research Subjects in
Clinical Studies” webpage,
accessed 15 January 2013
No position: no mention of any specific AC
responsibility
“Global Standards for No position: no mention of any specific AC
Interventional Clinical
Studies” webpage, accessed
15 January 2013
responsibility
The Globalization of
Clinical Trials (2009)
No position: no mention of any specific AC
responsibility
Statement on the
Declaration of Helsinki and
the Ethical Conduct of
Clinical Studies (2008)
No position: no mention of any specific AC
responsibility
Roche Holdings
Ltd. Roche Position on Clinical
Research (2012)
No position: no mention of any specific AC
responsibility
Roche Clinical Trials Policy
in Low and Middle Income
Developing Countries
(2008)
No position: no mention of any specific AC
responsibility
Roche Global Position on
Human Subject Research
(2004)
No position: no mention of any specific AC
responsibility
Sanofi-Aventis No publicly available
guidance No position
Singapore Bioethics
Advisory
Committee
Ethics Guidelines for
Human Biomedical
Research (2012): paragraph
2.11
Paragraph 2.11 states that justice “mandates
careful consideration of the arrangements in
place for ancillary care or follow-up in the
case of research participants located in regions
that may be resource-poor relative to the
initiating country.” Advance planning
regarding participants’ potential AC needs is
thus required, and AC referral and direct
provision of AC are implicitly permitted.
South Africa
Department of
Health
Ethics in Health Research:
Principles, Structures, and
Processes (2004)
No position: no mention of any specific AC
responsibility
Guidelines for Good
Practice in the Conduct of
Clinical Trials with Human
Participants in South Africa
(2006): 3.4
No position: It is recommended that the
“PI/investigator/ institution should inform a
participant when medical care is needed for
intercurrent illness(es) of which the
PI/investigator becomes aware.” Some
“intercurrent illnesses” might involve needs
for AC. Nonetheless, the document makes no
mention of any specific responsibility for
advance planning, referral, or direct provision
of needed care.
South African MRC Guidelines on Ethics for
Medical Research: General
Principles (2002): points
11.3.1 and 11.4.4.vi
The relevant points pertain explicitly to
“international collaborative research.” Prior
agreement “on all aspects of the research” is
required (11.3.1); thus, advance agreement
regarding AC is implicitly required.
According to point 11.4.4.vi, “Participants
should be provided with care or treatment they
would not normally obtain.” Direct provision
of AC is thus recommended.
Guidelines on Ethics for
Medical Research: HIV
Preventive Vaccine
Research (2003): point
3.4.3 and Section 16
“All the principles governing international
collaborative research identified in Book 1,
11.1-4 apply to HIV vaccine development
activities in South Africa” (3.4.3) Thus, as for
South African MRC (2002) cited above,
advance agreement regarding AC is
implicitly required, and, in general, direct
provision of AC is recommended. In
addition, “[s]ponsors and investigators must
ensure that treatment and care for HIV
infection is provided to participants who
become HIV-infected during the course of an
HIV vaccine trial” (16.1). Thus, advance
planning is required, and AC referral and
direct provision of AC are implicitly
required where indicated to ensure the
provision of HIV treatment and care. Capacity
development is recommended (16.4.8) as a
means of meeting such AC needs.
Sudan, National
Ministry of Health National Guidelines for
Ethical Conduct of
Research Involving Human
Subjects (2008): 5.2
“The extent of the investigator’s responsibility
to provide medical services to the participant”
is explicitly listed as an item of information
that “the investigator must provide” as part of
the informed consent process (pp. 36-40).
Thus, advance planning regarding subjects’
foreseeable needs for medical services, which
might include AC, is required, and direct
provision of AC implicitly permitted.
Tanzania National
Health Research
Ethics Committee
Guidelines on Ethics for
Health Research in
Tanzania (2001)
No position: no mention of any specific AC
responsibility
Tanzania National
Institute for
Medical Research
Standard Operating
Procedures for the National
Health Research Ethics
Review Committee (2007)
No position: no mention of any specific AC
responsibility
Uganda National
Council for Science
& Technology
National Guidelines for
Research Involving
Humans as Research
Participants (2007): 2.2 and
7.4.
In general, investigators are required to “refer
all research participants whose conditions may
not be managed adequately” with the human
and material resources available at the study
site (7.4). AC referral is thus implicitly
required where applicable under this
guidance.
Research “should aim at improving the
wellbeing of research participants and their
communities”; “[p]rovision of health care
beyond research related care” is listed as one
of several means by which to thus aim (p. 3).
Direct provision of AC is thus permitted.
U.K. Department
for International
Development
DFID Ethics Principles for
Research and Evaluation
(2011)
No position: no mention of any specific AC
responsibility
U.K. MRC
Policy on antiretroviral
therapy for people infected
with HIV and involved in
research in developing
countries (2003)
Advance Agreement is required (p. 7). AC referral and direct provision of AC are
implicitly permitted (p. 8).
Research involving human
participants in developing
societies (2004)
No position: no mention of any specific AC
responsibility
“Ethics and research
guidance” webpage,
accessed 15 Jan. 2013
No position: no mention of any specific AC
responsibility
UNAIDS
Ethical considerations in
HIV preventive vaccine
research (2000): Guidance
Point 16 and commentary
Document is included here
as a point of historical
interest, but is neither
counted as currently
applicable nor shown in
Table 1 because it was
revised and updated in the
form of UNAIDS/WHO
(2007a); see below.
“Sponsors need to ensure care and treatment
for participants who become HIV infected
during the course of the trial” (p. 41).
Advance planning and agreement about
such care and treatment are explicitly
recommended in the form of “consensus” that
“should emerge from an extended dialogue”
(p. 43). AC referral and direct provision of
AC are implicitly required where necessary to
ensure such care and treatment.
Advance planning and agreement are
required in the form of “consultation with the
community in order to determine what items
of care might be needed during the course of
the study” (p. 12, Appendix I, point IV).
Meeting on care within the
context of HIV/AIDS-
related research in
developing countries (2002)
No position: document contains disclaimer (p.
11) that states, “The views expressed are not
necessarily those of UNAIDS.” It is
nonetheless of note that meeting participants
recommended “that a comprehensive care
package should be implemented during any
HIV-related interventional research in
developing countries” (p. 8). AC referral and
direct provision would thus be implicitly
recommended if necessary to provide specific
AC-type components in the package where
indicated (p. 11, Appendix I, point II).
UNAIDS/ WHO Ethical considerations in
biomedical HIV prevention
trials (2007a): Guidance
points 9, 12, & 14 with
commentaries
Guidance Point 14 endorses an “obligation on
the part of sponsors and investigators to ensure
access to HIV care and treatment, including
antiretroviral treatment, for participants who
become infected” (p. 48). Advance planning
“for logistics and implementation” is required
(p. 49), and documented advance agreement
“on who will finance, deliver, and monitor
care and treatment” is also required
(“critically important”) (p. 49). AC referral
and direct provision of AC are implicitly
required where necessary to fulfill the
sponsors’ and investigators’ obligations to
ensure access to HIV care and treatment.
Capacity development is recommended as a
means of meeting participants’ AC needs for
HIV care and treatment (p. 50).
In addition, direct provision of AC is
recommended in the form of family planning
services to be provided in the context of
reproductive and sexual health counseling
(Guidance Point 9), and advance planning
and agreement are generally recommended
for any “ancillary interventions provided in the
course of the research” (Guidance Point 12)
Meeting report documented
in paper titled “Ethical
considerations related to the
provision of care and
treatment in vaccine trials,”
by Tarantola et al. (2007b)
No position: document contains a disclaimer
(p. 4874) stating, “This paper does not present
an official position of the World Health
Organization or of any of the institutions that
participated in the consultations.” It is
nonetheless of note that meeting participants
discussed specific AC responsibilities as
follows:
Advance planning and agreement would be
recommended regarding trial-specific
decisions on the issue of “access to care in the
context of vaccine trials” (p. 4867).
AC referral, direct provision of AC, and local
capacity development as a means of meeting
AC needs (p. 4869) would be permitted.
UNAIDS/ AVAC Good participatory practice:
Guidelines for biomedical
HIV prevention trials
(2011) : 3.11, 3.12
“Trial sponsors and implementers are ethically
obligated to ensure that participants who
acquire HIV during trial participation have
access to clinical evaluation, and stage-
appropriate HIV care and treatment” (3.11.B).
Thus, advance planning is implicitly
required, as is advance agreement where
necessary to secure clinical evaluation, care,
and treatment through other providers; AC
referral and direct provision of AC are
implicitly required where necessary to
provide specific AC-type components in the
care and treatment package where indicated.
In addition, advance planning and
agreement are recommended regarding
“[n]on-HIV related care” such as “provision of
female or male sexual and reproductive health
care, management of infectious diseases,
nutritional health, psychiatric care, and
psychosocial services” for trial participants
(3.12.A). AC referral and direct provision of
AC are thus implicitly recommended if
necessary for provision of the locally agreed
on non-HIV-related care package.
USAID
Procedures for Protection of
Human Subjects in
Research Supported by
USAID (current as of 29
Jan. 2013)
No position: no mention of any specific AC
responsibility
USAID Research: Policy
Framework, Principles, and
Operational Guidance
(current as of 29 Jan. 2013)
No position: no mention of any specific AC
responsibility
U.S. Department of
Defense Federal Policy for the
Protection of Human
Subjects (‘Common Rule’)
(1991)
No position: no mention of any specific AC
responsibility
U.S. Ethical
Advisory Bodies NBAC: Ethical and Policy
Issues in International
Research (2001)
No position: no mention of any specific AC
responsibility
Presidential Commission
for the Study of Bioethical
Issues: Research across
Borders: Proceedings of the
International Research
Panel (2011)
No position: The Commission acknowledges
AC as a significant but controversial issue and
deliberately takes no position on any specific
AC responsibility.
U.S. Food and Drug
Administration Federal Policy for the
Protection of Human
Subjects (‘Common Rule’)
(1991)
No position: no mention of any specific AC
responsibility
U.S. NIH Federal Policy for the
Protection of Human
Subjects (‘Common Rule’)
(1991)
No position: no mention of any specific AC
responsibility
NIH Grants Policy
Statement (2012): 16.6;
19.4
No position: In Section 16, regarding grants to
foreign institutions, international
organizations, and domestic grants with
foreign components, the document alludes
broadly to “patient care costs” as being
“provided only in exceptional circumstances”
(16.6); in Section 19, regarding allowable
costs, the document states, “Patient care costs
for individuals who are receiving accepted
treatment according to standard regimens
would not ordinarily be acceptable charges to
an NIH grant” (19.4). While “patient care
costs” might in some cases include
expenditures for AC, and the restriction on
funds is consistent with permitting AC to be
funded by other sources, the document is silent
about whether any specific AC responsibility
ever obtains.
Guidelines for Conduct of
Research Involving Human
Subjects at NIH (2004)
No position: no mention of any specific AC
responsibility
U.S. Office of
Human Research
Protections—
Department of
Health and Human
Services
Federal Policy for the
Protection of Human
Subjects (‘Common Rule’)
(1991)
No position: no mention of any specific AC
responsibility
Wellcome Trust Research involving people
living in low and middle
income countries (2010):
Section 5. Collateral
benefits
Advance planning for any AC interventions
to be offered is implicitly recommended as
part of formulating the research protocol (p.
10).
AC referral, direct provision of AC, and
local capacity development as a means of
meeting AC needs are implicitly permitted as
among several kinds of “collateral benefits”
that the Wellcome Trust “will consider
supporting” provided that certain ethically
important conditions (e.g., no “undue
influence,” no “adverse effect on the local
research environment”) are satisfied (p. 10).
WHO
Standards and Operational
Guidance for Ethics Review
of Health-Related Research
with Human Participants
(2011)
No position: no mention of any specific AC
responsibility
Ethical considerations
arising from vaccine trials
conducted in pediatric
populations with high
disease burden in
developing countries,
WHO/IVR ethics meeting
26-26 November 2002,
Accra, Ghana (document
issued Jan. 2004): Ch. 12
Advance agreement (similar to CIOMS,
above) is recommended regarding the types,
level, and standard of care, including AC, to
be provided by the study. Direct provision of
AC is thus implicitly permitted.
World Medical
Association Declaration of Helsinki
(2008)
No position: no mention of any specific AC
responsibility
Zimbabwe, Medical
Research Council Conducting Health
Research in Zimbabwe:
What researchers need to
know (2004)
No position: no mention of any specific AC
responsibility
SUMMARY:
Documents reviewed: 71
Institution sources reviewed: 57
Documents coded with “no position”: 54
Institutional sources with “no position”: 34