COSSA and Members Comment on Proposed Revisions to the Common Rule

COSSA, in conjunction with the American Educational Research Association (AERA) (a COSSA governing association) and the Inter-university Consortium for Political and Social Research, submitted comments on the Notice of Proposed Rulemaking (NPRM) for the Federal Policy for the Protection of Human Subjects or the “Common Rule” (click here for context on the NPRM). Overall, the comments are supportive of the proposed changes affecting the social and behavioral sciences and urge that “major and substantial improvements… not be delayed or deferred even if it is determined that some issues require further analysis before some rule changes can be made.” The comments also points out several sections where additional clarification would be useful.

The American Psychological Association (APA), Population Association of America (PAA) (COSSA governing associations), and the Society for the Psychological Study of Social Issues (SPSSI) (a COSSA member), also submitted comments on the NPRM, which are available on regulations.gov (docket ID HHS-OPHS-2015-0008).

Now that the window for public comment has closed, the Office of Human Research Protections will review all submitted comments and release a final rule. However, if the pace of the Common Rule revision process thus far is any indication, it will likely be several months, if not longer, before we see a final rule.

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