CITI Training and the Common Rule

I just sent the following e-mail concerning the CITI training program concerning Institutional Review Boards also known as IRBs and human subjects committees. These committees are required for colleges that seek funding from the Department of Health and Human Services. They are supposed to check for abuses of research subjects under a regulation called the "common rule". The common rule stretches the definition of threat to human subjects beyond recognition. If an economist does a survey of consumption habits, the common rule subjects the survey to review by an Institutional Review Board or human subjects committee. The committee can say, for any reason, that the research cannot be done. The grounds for abuse are obvious, especially in America's politicized universities. However, the CITI training, which is run by the University of Miami, Donna Shalala, Queen of Political Correctness, president, took upon itself to say that research findings that are offensive or harmful to the interests of a group constitute a violation of the human subjects rules. That is a lie. My e-mail to a Brooklyn College committee that is aiming to find resources to support faculty research follows:

Dear K---: I just filled out the survey but I wanted to add something. The human subjects committee has had a research document that I provided them on March 1 and has not responded. If the college wishes to support research in the social sciences area, it should consider limiting the scope of IRB review to human subjects issues that go beyond mere surveys of adults. There is no need for such review.

Moreover, I would add that the CITI training module provided by CUNY is deceptive. In particular, it suggests that it is based on the common rule and that research that could potentially find something that is not advantageous to a particular group is subject to restrictions by the common rule. In fact, such a restriction would be a violation of the First Amendment. To question this claim, I went in person to the DHHS in Maryland two years ago and interviewed the people responsible for overseeing regulation of the common rule. They indicated that the claim in the CITI training is untrue. In other words, the CITI training engages in the sort of deception and manipulation that advocates of IRBs claim needs to be stopped in generalizable research. There is no reason for CUNY to tell researchers that if some activist or other finds a research finding objectionable, the researcher violated the common rule and the IRB needs to squelch it. That is a lie in which CUNY currently engages by utilizing the CITI training program.

I would urge CUNY to discontinue the CITI training, which is unethical and deceptive in claiming that research findings can constitute a human subjects issue, and replace it with a training that is honest and truly reflects the regulatory requirements of the DHHS. Not that I agree with that either, but lying, deception and the use of the DHHS regulation to potentially suppress speech and research is inconsistent with a valid research program.