The MRCT Center submitted public comments to the National Institutes of Health (NIH)

The MRCT Center submitted public comments to the National Institutes of Health (NIH) “Request for Information on Proposed Updates and Long-Term Considerations for the NIH Genomic Data Sharing Policy,” published in the Federal Register on November 30, 2021. 

The MRCT Center appreciates the NIH’s efforts to update its policy on Genomic Data Sharing (GDS) to maintain currency with evolving technology and understanding and commented on multiple issues, including de-identification and evolving concept of “identifiability,” data linkage, data management and sharing principles for NIH-supported resources, harmonization of GDS and NIH Policy for Data Management and Sharing (DMS) plans, and the types of research covered by the GDS policy. In addition, the MRCT Center proposed that the NIH consider several additional issues in its revision including withdrawal of consent, third party risks, harmonization with other federal and international agencies, the increased likelihood of re-identification with future technology advances, sanctions for misuse of data, public education, and the effectiveness and impact of the GDS policy. Read comments

Response to European Commission’s request for feedback regarding the General Data Protection Regulation (GDPR)

April 29, 2020

In response to the European Commission’s request for feedback regarding the General Data Protection Regulation (GDPR), Mark Barnes and Barbara Bierer, MRCT Center Faculty Co-directors, and Senior Advisor David Peloquin along with Rita Lawlor, Biobank Director & Research Coordinator, ARC-Net Research Centre, University of Verona, Italy, submitted feedback.

The response highlighted pragmatic solutions and proposed a cohesive approach that the Commission could pursue either through proposing amendments to GDPR in its report to the European Parliament under GDPR Article 97 or through dialogue with the European Data Protection Board and supervisory authorities.

Read Response >

Harmonized Core Competency Framework Version 2.0 Released for Public Comment

The Joint Task Force for Clinical Trial Competency (JTF) has released the Draft Version 2.0 of the Harmonized Core Competency Framework for public comment. This is an effort of a multi-stakeholder, widely representative workgroup from across the global clinical research community.

The original Framework was revised based on suggestions from implementers and stakeholders worldwide, and the JTF invites further comments on Draft Version 2.0 of the Framework. Download the Framework  and learn more about the initiative on the JTF website.

FDA Comments – No. FDA–2013–N–0271: Availability of Masked and De-identified Non-Summary Safety and Efficacy Data – June 2013

Harvard University’s Multi-Regional Clinical Trials Center (MRCT) submitted the following comments on FDA’s proposal, 78 Fed. Reg. 33421 (June 4, 2013), to make de-identified and masked clinical and preclinical data, from marketing applications submitted to FDA, available to external experts and others, as part of the Agency’s transparency initiative.

FDA proposes to make available to the public pooled data that have been sufficiently de-identified and masked (as to the drugs involved in the trial) in order to protect confidential commercial information, for analysis by the broader community.

Declaration of Helsinki comments: Declaration of Helsinki, issued for public comment by the Counsel of the WMA in April 2013

MRCT Center at Harvard responded to the World Medical Association’s request for comments or potential revisions to the Declaration of Helsinki (DoH), which will reach its 50th anniversary in 2014.

To maintain its relevance and prominence as a guidance document for clinical research, revisions are frequently made to the DoH. Revisions for the 50th Anniversary will be published in 2014. Staff, sponsors, and academic affiliates of the MRCT Center collaborated to submit the attached comments to the World Medical Association.

Comments are available here