Regulation — pharma-specific

IRB Common Rule (45 CFR 46) — continuing review of AI-driven eligibility

The Common Rule places continuing-review duty on the IRB. When AI participates in eligibility, the IRB's questions about equitable subject selection and risk-benefit balance land on the sponsor. A silent exclusion pattern is the exact input that triggers IRB continuing-review escalation.

What the regulation actually says

"In order to approve research covered by this policy the IRB shall determine that … selection of subjects is equitable … and appropriate additional safeguards have been included in the study to protect the rights and welfare of these subjects." 45 CFR §46.111(a)(3) — equitable-selection criterion
"An IRB shall conduct continuing review of research requiring review by the convened IRB at intervals appropriate to the degree of risk … not less than once per year." 45 CFR §46.109(e) — continuing-review duty

What this means in plain English

Two Common Rule criteria that AI-driven eligibility directly implicates:

  1. Equitable selection. If AI screens candidates and systematically excludes an underrepresented subgroup, the equitable-selection finding on the original protocol may no longer hold.
  2. Continuing review. The IRB's continuing review will ask "has anything changed?" A silent AI-driven exclusion pattern that emerged post-approval is exactly the change that requires disclosure.

Sponsors that discover the pattern via their own audit have a very different disclosure conversation than sponsors that discover it via IRB question.

What triggers the exposure in the sample

P3 exclude-lane rate rose from 22% to 75% silently over the audit window. That pattern reaches the equitable-selection criterion directly. An IRB continuing-review board that learns of this via sponsor disclosure hears a very different case than a board that learns of it via participant complaint or auditor inquiry — and trial-site suspension is a live consequence in the second scenario.

What the $499 Snapshot shows against this rule

See the exclusion-differential chart →

How does this help me?

IRB continuing-review is not adversarial when the sponsor brings dated independent evidence + a remediation plan. It is adversarial when the sponsor is caught behind the disclosure.

Read: IRB Common Rule -- what it saves in continuing-review conversations →

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