Here is a decision tree for IRBs to use, that is primarily for AI/ML Human Subjects Research that involves medical devices. This decision tree is primarily for that and won’t do you any good if you aren’t dealing with medical devices. This tree will help you determine if an IDE is required, if the IRB can make an Non-Significant Risk Determination, and which projects can be expedited, or possibly even “exempt” from IRB review. The “Exempt” Decision Tree can be found embedded in the AI HSR Checklist.
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Published by Tamiko E.
Ms. Eto has over 17 years of experience in the field of human subjects research protections and manages IRB review and research compliance, including the facilitation of technology risk assessment and data sharing contracts, at a large healthcare institution's Division of Research. The research portfolio there comprises over 7 million members with a large profile of AI-related research projects including FDA-regulated Software as a Medical Device (SaMD). Concurrently, Ms. Eto also serves on the AI Ethics Advisory Board for the Institution of Experiential AI (EAI) at Northeastern University. Prior to her work at the Division of Research, Tamiko served as Acting Director at Stanford Research Institute’s (SRI) Office of Research Integrity and Chair of SRI IRB, where she performed scientific reviews, policy interpretations and the development of AI-related projects. She has now leveraged her experience to implement regulatory policies to health care research projects that delve into AI research. She works closely with AI researchers and institutional /regulatory bodies in addressing ethical and regulatory challenges related to AI. To facilitate researchers and IRB professionals across the US she has developed tools and checklists for IRBs to use in their review of AI research. Developing these tools, she also actively collaborates on research to be at the forefront of developing an ethical and regulatory framework for research involving human subjects. She is now currently pursuing her second Master’s Degree at Stanford University in Ethics and Policy.
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