Ethics of Rare Disease Research

Meeting Summary

Presented on: September 8, 2025

This meeting was presented to the Bioethics Collaborative. The Bioethics Collaborative is a forum to propose, share, and discuss ethical challenges in multi-national clinical trials. Meetings convene individuals from academia, industry, patient/participant groups, ethics committees, government, and others.


Abstract: Research in rare diseases presents several ethical challenges, which have, to date, been under-explored. Decisions about whether to initiate rare disease research in the first place can be complicated by economic realities, given that the eventual market for rare disease therapies may be quite limited. How should companies and research funders generally balance economic and feasibility considerations with the needs of rare patient groups? Other challenges characterize the conduct of rare disease research. Some of these involve issues related to privacy and confidentiality. The smaller the patient population, the easier it may be to identify participants and individuals within clinical trial datasets, even when efforts are made to protect privacy. Others involve how to be fair toward rare disease patients eager to participate in research, which include determining where to run trials and provide fair access. Finally, determining the scope of post-trial obligations toward rare disease populations, and what is owed to rare disease patients who appear to benefit from therapies that lack efficacy in wider populations, can be complicated. How should sponsors and other research stakeholders think about these issues?     

How Much Risk is Too Much: Revisiting the Ethics of Control Arms

Meeting Summary

Presented on: December 8, 2025

This meeting was presented to the Bioethics Collaborative. The Bioethics Collaborative is a forum to propose, share, and discuss ethical challenges in multi-national clinical trials. Meetings convene individuals from academia, industry, patient/participant groups, ethics committees, government, and others.


Abstract: Rigorous evaluation of investigational therapies often requires the presence of a control group that will not receive the therapy under evaluation. In active-controlled studies, people in the control arm receive a currently available treatment, but in some cases, they receive a placebo from which they are not likely to benefit. Furthermore, clinical research for certain conditions, such as rare neurological or genetic disorders, places increasing demands on all participants, including those in the control arm, for invasive and burdensome procedures. For example, in studies where a drug is delivered intrathecally to participants in an active arm over multiple cycles, participants in the control arm may also be asked to undergo serial lumbar puncture and placebo injections directly into the spinal canal, to maintain the blind or provide a baseline for safety and/or biomarker assessments. 

How much risk and burden is too much to ask individuals in these studies to accept— particularly those in control arms who will receive a placebo or otherwise fail to benefit? How should we think about the difference, if any, between active and placebo control arms on this issue? If intrusive elements of designs are truly indispensable to the research, should the IRB and research ethics community be willing to adjust their tolerance for risk? Are there practical mitigation strategies that can help? Do studies that include vulnerable populations, such as children and those unable to consent for themselves, demand heightened concern or a different analysis? Who decides what level of risk is acceptable? And what role, if any, should the perspectives of patient communities play in helping to set those limits? The December BC will aim to address these and related topics. 

Research Interrupted: Clinical Trial Termination and Participant Withdrawal

Meeting Summary

Presented on: March 10, 2026

This meeting was presented to the Bioethics Collaborative. The Bioethics Collaborative is a forum to propose, share, and discuss ethical challenges in multi-national clinical trials. Meetings convene individuals from academia, industry, patient/participant groups, ethics committees, government, and others.


Abstract: Withdrawal from research participation is widely acknowledged as foundational to ethical research, yet it comes with costs, including the loss of data and delays in completing valuable research. Historically, withdrawing from research has been conceived as an all-or-nothing decision, regardless of whether that decision is made by the participant or the research team. However, this assumption precludes the possibility that individuals may be willing to continue contributing to the research in other ways, even if they are not willing to participate in all aspects of a study. While access to public records (e.g., National Death Index) may allow follow-up data collection, it is rare, at the time of withdrawal, for studies to seek individuals’ permission to continue other forms of data collection, such as access to medical records or interaction with a personal care provider. Are there risks to offering more fine-grained options for monitoring and continued data collection to subjects who express a desire to withdraw? Could it be construed as unduly pressuring participants or interfering with the right to withdraw? What would the ethical parameters of such an approach be? How would these discussions need to be approached, and what would the informed consent process at enrollment need to say about it?

Transitioning from individual rights to systemic issues, it becomes evident that there are also ethical concerns surrounding trial termination generally, particularly when study closure is premature or occurs for reasons not envisaged at study launch. Currently, there is a lack of ethical guidelines, standardized protocols, and attention to or analysis of trial closure. Reasons for terminations are often inadequately documented, and procedures for closing a trial are inadequate. This raises questions about the obligations of researchers and sponsors to trial participants and the data, especially when trials are terminated for non-scientific reasons (e.g., business priorities). The recent abrupt withdrawal of NIH funding left an estimated 74,000 participants stranded and prevented those studies from producing robust knowledge and scientific benefits, which are generally needed to justify the assumption of risks for participants. Further, early closures due to seemingly preventable reasons, such as lack of participant accrual, remain common, and academic institutions routinely close protocols when an investigator leaves (or loses interest) without accountability to the research, data, or currently enrolled (or completed) participants. A framework for trial termination, emanating from use cases and experience, is needed.

Returning Summary Results to Participants: Lessons from the Research Community

Webinar

Date: October 27, 2026

On October 27, as NIH finalizes a policy requiring plain-language summaries for all NIH-supported clinical research, the MRCT Center presented a webinar on returning summary results to study participants. It builds on the Center’s ongoing work on returning both aggregate and individual results. Barbara Bierer opened with background on the topic, then introduced Sylvia Baedorf Kassis, who moderated a discussion on how researchers return summary results to the people who took part in their studies. The panel welcomed Lawrence Appel (Johns Hopkins University), who has returned results to participants for more than 30 years; Abby Gregory (ASCO), who supervises ongoing plain language summaries of the TAPUR Study; and Deborah Mascalzoni (Eurac Research and Uppsala University), whose Cooperative Health Research in South Tyrol (CHRIS) cohort of 13,500 people uses dynamic consent as a governance structure to support results return.

Read the MRCT Center’s comments on the NIH draft policy, submitted October 26 by Barbara Bierer and Sylvia Baedorf Kassis. (see below)


Related, on demand: Just in Time: Responding to the NIH Draft Policy for Sharing Summary Study Results with Participants (September 3), an MRCT Center webinar co-presented with the NIH, in which Barbara Bierer, MRCT Center Faculty Director, introduced the session, followed by Adam Berger, Director of the Division of Clinical and Healthcare Research Policy in the NIH Office of Science Policy, who summarized the NIH thinking behind the draft policy.

YouTube: Clinical Research Competencies to Support Effective Patient Partner Engagement

Return of Results Efforts

The original MRCT Center Return of Aggregate Results initiative and recent efforts are described here: https://mrctcenter.org/project/aggregate-results/

Return of Individual Results
https://mrctcenter.org/return-of-individual-results/

Proposal to FDA with Transcelerate in 2017

NIH Draft Policy on Returning Summary-Level Results to Participants

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-113.html

NIH Roadmap for engaging the public as partners in clinical research

https://www.nih.gov/about-nih/nih-director/statements/roadmap-engaging-public-partners-clinical-research

MRCT Center Clinical Research Glossary

www.mrctcenter.org/glossary

MRCT Center upcoming Health Literacy Month webinar registration:

https://mrctcenter.org/tribe-events/returning-results-to-participants-in-practice

Request for Information: Draft NIH Policy on Sharing Summary Level Study Results with Clinical Research Participants

Public Comment

Comments provided on: October 26, 2026

Comments provided to: NIH Office of Science Policy

Description: : The MRCT Center submitted a public comment to the NIH Office of Science Policy on its draft policy requiring that plain-language, summary-level study results be shared with individuals who have participated in clinical research. The MRCT Center fully endorsed the policy and its scope, and focused its comments on making it feasible, durable, and harmonized. The MRCT Center emphasized that meaningful communication of research findings should be considered a core component of the research relationship. The recommendations focus on making the policy workable across diverse study types by providing clear guidance, supporting accessibility and health literacy, aligning with other regulatory frameworks, and ensuring adequate resources for implementation. The MRCT Center offered to work with NIH to adapt its Return of Aggregate Results Guidance Document and Toolkit for the policy.

Strengthening clinical trial ethics and regulatory oversight in Africa: lessons from the TRACE initiative

Publication

Published on: September 7, 2026

Published in: Nature Medicine

Description: The TRACE Author Group, led by Kara L. Neil and Jeanine Condo and including Barbara Bierer, Willyanne DeCormier Plosky, and Sarah White of the MRCT Center, published “Strengthening clinical trial ethics and regulatory oversight in Africa: lessons from the TRACE initiative” in Nature Medicine. The authors report early results from the TRACE Project in Kenya, Nigeria, Rwanda, Tanzania, and Zimbabwe, where coordinating ethics and regulatory review into a single, parallel process drove the fastest gains in trial readiness. In Zimbabwe, a joint electronic platform linking the medicines regulator and the national ethics review function reduced approval times by at least 20%. The authors recommend that parallel review become standard practice across African clinical trial systems.

Neil, K.L., Condo, J. & on behalf of The TRACE Author Group. Strengthening clinical trial ethics and regulatory oversight in Africa: lessons from the TRACE initiative. Nat Med (2026). https://doi.org/10.1038/s41591-026-04645-7

Reproductive Privacy Risk Disclosure in US Clinical Trial Informed Consent Forms After the Dobbs Decision

Publication

Published on: October 7, 2026

Published in: JAMA Network Open

Description: “Reproductive Privacy Risk Disclosure in US Clinical Trial Informed Consent Forms After the Dobbs Decision,” published in JAMA Network Open and led by Ava Glazier, formerly of the MRCT Center, with co-authors Willyanne DeCormier Plosky and Barbara Bierer of the MRCT Center, examined whether informed consent forms tell participants about possible privacy risks that pregnancy monitoring can carry after the Dobbs decision. Of 195 US interventional trials that began after the 2022 decision and posted a consent form on ClinicalTrials.gov, more than half (59%) required pregnancy testing, yet none addressed reproductive privacy risks. The authors call for guidance on when and how to explain these risks, site-specific consent language for multisite trials, and a coordinated, nationwide effort to give all participants clear, consistent disclosure.

Glazier A, DeCormier Plosky W, Bierer BE. Reproductive Privacy Risk Disclosure in US Clinical Trial Informed Consent Forms After the Dobbs Decision. JAMA Netw Open. 2026;9(10):e2637862. doi:10.1001/jamanetworkopen.2026.37862

Exclusion of Participants for Substance Use in Clinical Trials

Publication

Published on: October 6, 2026

Published in: Clinical Pharmacology & Therapeutics

Description: “Exclusion of Participants for Substance Use in Clinical Trials,” published in Clinical Pharmacology & Therapeutics and led by Willyanne DeCormier Plosky of the MRCT Center with co-authors Benjamin C. Silverman of Mass General Brigham, David H. Strauss of Columbia University, and Barbara Bierer, analyzed ClinicalTrials.gov protocols to learn whether people who use substances are excluded from clinical trials, and why. The authors found that 43% of interventional protocols (110 of 254) excluded people who use substances, and that protocols defined substance use inconsistently, varying by level, timing, and type of substance. Most of those studies (63%) gave no rationale or none specific to substance use. The authors argue that inclusion should be as broad as the study question allows and exclusion only as narrow as participant safety and scientific validity require and call for guidance that standardizes how substance use is defined and assessed in eligibility criteria. When people who use substances and their healthcare providers determine it is appropriate to participate in clinical trials, the generalizability of safety and efficacy data for the medical products tested in the study may be improved.


doi.org/10.1002/cpt.70510

Implementing ICH E6(R3): Practical Risk-Proportionate Strategies for IRBs, Investigators, and Study Teams

Webinar

Date: September 23, 2026

Co-presented with PRIM&R (Public Responsibility in Medicine and Research)

ICH E6(R3) moves Good Clinical Practice toward quality by design and risk-proportionate oversight. This webinar looks at what that shift means for the people who review, run, and document clinical trials: IRBs, investigators, and study teams. The panel discusses what is changing, how the guideline relates to the US regulations that govern IRB review, the move from investigator supervision to investigator oversight, and how to decide which essential records a trial needs. The panel then applies these ideas to a case study: an investigator-initiated trial of an approved drug in a new indication for a rare neuromuscular condition, run at three sites under a single reviewing IRB.

Panelists

  • David Nickerson, VP, Head of Clinical Quality Management, EMD Serono, and PhRMA Topic Lead for ICH E6(R3)
  • Rebecca Stanbrook, Founder and Director, RESaltas GmbH, and EFPIA Topic Lead for ICH E6(R3)
  • Benjamin C. Silverman, MD, Senior IRB Chair, Mass General Brigham

Moderator

  • Sarah White, Executive Director, MRCT Center
YouTube: Clinical Research Competencies to Support Effective Patient Partner Engagement
The MRCT Center developed this course with the ICH E6(R3) Expert Working Group. Now available: Module 1 (Introduction and Foundational Concepts), Module 4 (Informed Consent), and Module 5 (Essential Records, new in September 2026). Module 3 (Data Governance) will be released in October, and Module 2 (Responsibilities and Oversight) will follow.
The earlier MRCT Center webinar covers the guideline’s foundational concepts: quality by design, quality management, critical to quality factors, and risk proportionality. Panelists were the ICH E6(R3) topic leads Cheryl Grandinetti (FDA), David Nickerson (PhRMA), and Rebecca Stanbrook (EFPIA).

Inclusion Beyond, And Not Limited To, Consent Discussions

Publication

Published on: September 18, 2026

Published in: American Journal of Bioethics

Description: In their commentary published in the American Journal of Bioethics (AJOB) titled “Inclusion Beyond, And Not Limited To, Consent Discussions,” Willyanne DeCormier Plosky and Barbara Bierer advocate for expanding attention to inclusion beyond the informed consent process, such as in the pre-study processes of developing eligibility criteria and study outcome measures, on-study processes such as planning for communication platforms and associated services (e.g., help desks, concomitant software or tools), and post-study processes such as return of results in accessible formats. They also contend that universal design supporting more user-friendly clinical trial components (e.g., ICFs, patient portals) may be more effectively achieved when the preferences and needs for study communication and participation processes are adapted from minoritized populations to apply to studies involving majority populations rather than using the default “reasonable person” to adapt clinical trial components to anyone other than that default “reasonable person.”


DeCormier Plosky, W., & Bierer, B. E. (2026). Inclusion Beyond, And Not Limited To, Consent Discussions. The American Journal of Bioethics, 26(10), 42–44. https://doi.org/10.1080/15265161.2026.2717109