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Compliance Committee

the committee charged with reviewing and approving compliance matters for the Medical School and Health System


Withholding of full information of the study. Misleading or omitted information might include the purpose of the research, the role of the researcher, or what procedures in the study are actually experimental. The IRB recognizes that deception or concealment may be necessary for certain types of behavioral research. Because people act differently depending on circumstances, full knowledge by the subject might bias the results in some cases.

(See: Deception and Concealment)

Concurrent Reporting

Reporting should occur in parallel or no later than 5 calendar days to all oversight bodies or agencies. Exceptions to this rule may be requested by submitting a study-specific reporting plan for IRB approval.

Concurrent Standard Therapy

Treatment (e.g., surgery, drug) a subject is receiving while participating in a research study that is not the treatment under investigation; treatment the subject would be offered even if not enrolled in the research study. For example, in a comparison study of two anti-nausea drugs in cancer patients, the chemotherapy would be the "concurrent standard therapy" and the anti-nausea drugs would be the "investigational therapy."


Confidential means that the investigator can (or could) identify individuals who participated in a study, perhaps through a code. Although the identities may be recorded, data can be kept confidential if they are carefully coded, if face sheets and consent documents are separated from survey instruments, if computer sheets and other papers are properly disposed, if access to identifiable data is limited, if research staff are educated about the importance of protecting confidentiality, and if records are stored in secured locations. More elaborate procedures may be appropriate for research involving sensitive data that may involve a greater risk should confidentiality be breached, and investigators may want to seek Certificates of Confidentiality to protect such data from subpoena.                                  

Unless federal statutes mandate this confidentiality confidential surveys that are not anonymous are not eligible for exemption using these criteria. Confidential surveys may still be eligible for exemption if any disclosure of the human subjects' responses outside the research could not possibly place them at risk of criminal or civil liability or be damaging to their financial standing, employability, or reputation.


  • Pertains to the treatment of information that an individual has disclosed in a relationship of trust and with the expectation that it will not be divulged to others without written permission in ways that are inconsistent with the understanding of the original disclosure. (OHRP)
  • Right of privacy and of non-release of disclosed personal information. The investigator should protect subjects against invasion of privacy and loss of confidentiality. Lack of secure handling of completed personality tests, questionnaires, interview protocols or data and recorded materials augments risk and must be avoided.

Confidentiality Regarding Trial Participants

Refers to maintaining the confidentiality of trial participants including their personal identity and all personal medical information. The trial participants' consent to the use of records for data verification purposes should be obtained prior to the trial and assurance must be given that confidentiality will be maintained.

Conflict of Interest (COI)

  • A COI occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt the motivation for an act in another. A COI can only exist if a person or testimony is entrusted with some impartiality; a modicum of trust is necessary to create it. The presence of a COI is independent from the execution of impropriety. Therefore, a COI can be discovered and voluntarily defused before any corruption occurs. A conflict could be financial and it includes both actual and perceived conflicts.
  • A conflict of interest is a situation in which an employee has the opportunity to influence a University decision that could lead to financial or other personal advantage, or that involves other conflicting official obligations. A COI can also occur when the conduct of research or other sponsored activities is or has the potential to be influenced by the outside financial interests of an investigator.
  • A financial interest or other opportunity for tangible personal benefit of an individual or his/her immediate family that may exert a substantial and improper influence on the individual's professional judgment in exercising any University duty or responsibility, including the review of research.

For IRBMED members, financial and non-financial interests/opportunities are evaluated.

Consent at Age of Majority

Conditional Field for Pediatric Studies Only: Select Yes if children should be re-consented near their 18th birthday.


Date that the patient signs consent (main) (device studies)

Consortium Agreement

Group of collaborative investigators/institutions; arrangement can be formalized with specified terms and conditions.


Individuals hired to give professional advice or services for a fee as long as they are not an employee of the University. Consultants do not perform a portion of the programmatic work.

Continuation Project (Non-Competing)

Applicable to grants and cooperative agreements only. A project approved for multiple-year funding, although funds are typically committed only one year at a time. At the end of the initial budget period, progress on the project is assessed. If satisfactory, an award is made for the next budget period, subject to the availability of funds. Continuation projects do not compete with new project proposals and are not subjected to peer-review beyond the initial project approval.

Continuing Non-Compliance

Non-compliance (serious or non-serious) that has been previously reported, or a pattern of ongoing activities that indicate a lack of understanding of human subjects protection requirements that may affect research participants or the validity of the research and suggest the potential for future noncompliance without intervention. Examples of continuing non-compliance may include but are not limited to: repeated failures to provide or review progress reports resulting in lapses of IRB approval, inadequate oversight of ongoing research, or failure to respond to or resolve previous allegations or findings of noncompliance.

Continuing Review (CR)

DHHS Regulations, 45 CFR 46, require at Section 46.109(e) that "an IRB shall conduct continuing review …at intervals appropriate to the degree of risk, but not less than once per year…" Continuing review must be substantive and meaningful. Review by the convened IRB, with recorded vote, is required unless the research is otherwise appropriate for expedited review under Section 46.110. Also known as a Scheduled Continuing Review (SCR).


Disadvantageous, perhaps dangerous; a treatment that should not be used in certain individuals or conditions due to risks (e.g., a drug may be contraindicated for pregnant women and persons with high blood pressure).


A contraindication is a condition or factor that serves as a reason to withhold a certain medical treatment. Some contraindications are absolute, meaning that there are no reasonable circumstances for undertaking a course of action. For example, children and teenagers with viral infections should not be given aspirin because of the risk of Reye's syndrome; and a person with an anaphylactic food allergy should never eat the food to which they are allergic. Other contraindications are relative, meaning that the patient is at higher risk of complications, but that these risks may be outweighed by other considerations or mitigated by other measures. For example, a pregnant woman should normally avoid getting X-rays, but the risk may be outweighed by the benefit of diagnosing (and then treating) a serious condition such as tuberculosis.


In Science: Scientific control allows for comparisons of concepts. It is a part of the scientific method. Scientific control is often used in discussion of natural experiments. For instance, during drug testing, scientists will try to control two groups to keep them as identical and normal as possible, and then allow one group to try the drug. Another example might be testing plant fertilizer by giving it to only half the plants in a garden (the plants that receive no fertilizer are the control group, because they are kept normal).

In Research: Subject(s) used for comparison who are not given a treatment under study or who do not have a given condition, background, or risk factor that is the object of study. Control conditions may be concurrent (occurring more or less simultaneously with the condition under study) or historical (preceding the condition under study). When the present condition of subjects is compared with their own condition on a prior regimen or treatment, the study is considered historically controlled.

Control Group

The standard by which experimental observations are evaluated. In many clinical trials, one group of patients will be given an experimental drug or treatment, while the control group is given either a standard treatment for the illness or a placebo. See Placebo

Controlled Trials

Control is a standard against which experimental observations may be evaluated. In clinical trials, one group of participants is given an experimental drug, while another group (i.e., the control group) is given either a standard treatment for the disease or a placebo.

Convened IRB Review

Review of proposed human subject research by an IRB that meets the membership requirements specified in federal regulations regarding the number, qualifications, diversity, and affiliation of its members, at which a majority of the members are present including at least one member whose primary concerns are in nonscientific areas.

Cooperative Agreement

An award similar to a grant, but in which the sponsor's staff may be actively involved in proposal preparation, and anticipates having substantial involvement in research activities once the award has been made.

Cooperative Protocol Research Program (CPRP)

Programs involving multi-protocol, multi-site research, in which data from standardized protocols are pooled across institutions. These protocols, conducted or sponsored by DHHS, are approved and monitored by DHHS Protocol Review Committees that are recognized by OHRP as satisfactorily addressing the quality of human subject protections.

Cooperative Research Projects

Research projects covered by 45 CFR 46 that involve more than one institution. In the conduct of cooperative research projects, each institution is responsible for safeguarding the rights and welfare of human subjects and for complying with federal policy [45 CFR 46.114].

Covered Entity

covered entity (individual, organization, or agency) is a health care provider, health plan, or health care clearinghouse regulated by HIPAA. Covered entities must comply with the HIPAA Privacy Rule to protect the privacy and security of health information.

The University of Michigan is a "hybrid" covered entity because some of its units are regulated by HIPAA

A health care provider is a person or organization — such as a doctor dentist, nurse, pharmacy, dialysis center, DME provider, hospital, clinic, nursing home or ambulatory care facility — who provides clinical care, coordination, and treatment to individuals.

CPT Codes

CPT Codes or Current Procedural Terminology Codes are the billing code numbers associated with medical procedures


 Continuing Review; CRs are completed through eResearch and are required to be submitted and approved prior to expiration; see also SCR


the Clinical Research Calendar Review Analysis Office, formerly the Clinical Research Billing Unit (CRBU)


Case Report Form

Cross-Over Design

A type of clinical trial in which each subject experiences, at different times, both the experimental and control therapy. For example, half of the subjects might be randomly assigned first to the control group and then to the experimental intervention, while the other half would have the sequence reversed.


Clinical and Translational Science Award

CTSU Coordinator

Individual who manages the study protocol (i.e. consenting, IRB applications, scheduling patients, monitor visits, data entry, query resolution, etc.)

CTSU Intake Approval Date

The date the CTSU intake form was received via email.

CTSU Intake No.

Sequential number followed by the PI's last name automatically assigned at the time of intake form submission.

Custom Device

A device that necessarily deviates from devices generally available or from an applicable performance standard or pre-market approval requirement to comply with the order of an individual physician or dentist and that is: 

  • Not generally available or generally used by other physicians or dentists;
  • Not generally available in finished form for purchase or for dispensing upon prescription;
  • Not offered for commercial distribution through labeling or advertising; and
  • Intended for use by an individual patient named in the order of a physician or dentist and is to be made in a specific form for that patient, or is intended to meet the special needs of the physician or dentist in the course of professional practice.