DOD, DOJ, NIH, VA, and EPA - How Agencies Layer the Common Rule

DOD, DOJ, NIH, VA, and EPA: How Agencies Layer the Common Rule shows how a single protocol can face different requirements depending on who funds it. The base rule is the same, but each agency adds its own layer, and the CIP exam expects you to know them. This is Lesson 7 of 26 in IRB and HRPP Administration: From Coordinator to CIP, taught by Angel Reyes, MPH, MCHES, PMP, a public health doctoral candidate and research methodologist. Every lesson is built on PRIM&R's public 2025 CIP Body of Knowledge and Exam References and cites the regulation it teaches, so you can verify it yourself. 5 Key Facts from This Lesson: 1. The Department of Defense codifies the Common Rule at 32 CFR 219 and requires a research monitor for research involving greater than minimal risk. 2. The Department of Justice adopts only Subpart A at 28 CFR 46, and research in the Federal Bureau of Prisons is governed by 28 CFR 512, not 45 CFR 46 Subpart C. 3. Certificates of Confidentiality have been issued automatically for NIH-funded research that collects identifiable sensitive information since October 2017. 4. The Department of Education layers FERPA, a records rule, and PPRA, a parental consent rule for surveys on eight protected topics, on top of 34 CFR 97. 5. EPA's regulation at 40 CFR 26 prohibits research involving intentional exposure of pregnant women, nursing women, and children. Visit https://www.subthesis.com for the full course, more free research and public health courses, and practical research tools. Disclaimer: This video is for educational purposes only and is not legal, regulatory, or compliance advice. Regulations and guidance change, so confirm every requirement against the current eCFR text, OHRP and FDA guidance, and your institution's IRB policies before relying on it. CIP® is a registered certification mark of Public Responsibility in Medicine and Research (PRIM&R). This course is produced independently by Subthesis and is not affiliated with, endorsed by, or reviewed by PRIM&R or the CIP Council. The instructor is not a Certified IRB Professional. Completing this course does not confer CIP certification, satisfy CIP eligibility requirements, or count as CIP recertification continuing education.