CIHR management response to the Report of the Task Force on Ethics Reform

CIHR's Management Response to the Task Force report is grounded in six key concepts, as reflected in a refreshed Ethics Action Plan:
  • Integrated, strong leadership in ethics;
  • making ethics core;
  • management of risks including appropriate autonomy and oversight for ethics;
  • enhancement of internal awareness of ethics and capacity in ethics within CIHR;
  • ethics expertise available to advise CIHR; and
  • as part of an Ethics Action Plan, undertaking to nurture and monitor research capacity in ethics in Canada and its application within priority target areas.

The Task Force recommendations and CIHR's management response are below.

Task Force Recommendations

CIHR has summarized and grouped Task Force recommendations under themes. Numbering refers to the chronology in the original Task Force report – an extract of the report can be found on the CIHR website.

Leadership

Recommendation #1: Key recommendation from which other recommendations flow: Provide ethics leadership to CIHR. CIHR must create a position of Vice President of Ethics (VP Ethics) or a position of equivalent stature and then hire a strong individual to fill that role.

We agree that strong leadership is central to CIHR meeting its ethics mandate and ensuring integration of ethics across CIHR. As pointed out in the report, strong leadership comes from many levels of the organization: the President, VPs, Scientific Directors, and all other executive leadership in the organization are strongly committed to achieving CIHR's ethics mandate. This has now been formalized in an integrated leadership model.

Introducing a new, independent VP-level position is neither operationally feasible nor ideal. It is not ideal because it is not integrated within CIHR leadership and decision-making. A new integrated and shared structure of leadership and accountability will be created. It will include having the Chief Scientific Officer/VP Research, Knowledge Translation (CSO/VP) as Champion of Ethics at CIHR. She will become one of several new members on a refreshed Governing Council Standing Committee on Ethics (SCE) The SCE will be chaired by a member of Governing Council and will include members from Science Council, from among the Institute Advisory Board Ethics Designates as well as a few external experts in ethics.

The responses to the remaining recommendations are therefore framed within this revised structure.

Recommendation #3: The VP Ethics must have a strong mandate based upon the CIHR Act.

The CSO/VP has a critical leadership role at CIHR. She is part of the shared integrated leadership model where SC is at the core, and is supported, at the staff level, by an Associate VP, RKT; a Director, Science, Knowledge Translation and Ethics (SKTE); and an Executive Director, Secretariat on Responsible Conduct of Research, together with their teams of ethics specialists and advisors.

Recommendation #4: The VP Ethics' mandate should include knowledge generation and knowledge translation.

The mandate of the CSO/VP and of Science Council includes knowledge creation, knowledge translation and ethics placing both in a strategic position to integrate all three consistently. Funding for ethics knowledge generation and translation projects can be funded in current open funding programs and will be eligible in the new foundation and project schemes. Signature Initiatives and Strategic Initiatives will create new opportunities to significantly embed ethics & KT.

Recommendation #19: The Ethics VP and Ethics Office should partner with national and international groups on ethical issues of mutual concern.

The CSO/VP, members of Science Council and SCE, as well as the Ethics Office will engage in national and international partnerships, as relevant to the ethics mandate and the refreshed Action Plan.

Recommendation #7: The VP Ethics must have a seat on Science Council and Governing Council.

The CSO/VP, the Associate VP, RKT and the Director, SKTE all have seats on Science Council. The Chair of SCE will have a seat on Governing Council.

Recommendation #9: The VP Ethics should be the head of the Ethics Office.

The CSO/VP is responsible for the Ethics Office team and the Secretariat on Responsible Conduct of Research. Both the Director, SKTE and the Executive Director, Secretariat on Responsible Conduct of Research report through to the CSO/VP.

Making ethics core

Recommendation #2: CIHR must recognize its statutory mandate in ethics and give a clear corporate commitment to the VP Ethics.

CIHR does recognize its mandate in ethics and commits corporately to ensuring it is met. The essential role of the CSO/VP as ethics champion is reflected in her role on Science Council and as member of the refreshed SCE. A new communications strategy will be developed to highlight CIHR's leadership and progress in advancing the CIHR ethics mandate.

Autonomy and oversight

Recommendation #5: The VP Ethics must have decision-making autonomy within its mandate.

At CIHR, strategic direction is set by the Governing Council; the Executive Management Committee (comprised of the President and VPs) provide leadership and decision-making for strategic, corporate policy and management areas that support and contribute to the strategic directions set out by the Governing Council.

Science Council develops, implements and reports to Governing Council on CIHR's research, knowledge translation and ethics strategies, in accordance with the CIHR Act and the overarching strategic directions set out by Governing Council. This includes approving funding for all research, knowledge translation and ethics initiatives. Once the overarching strategy and corporate direction are set, then the CSO/VP can make decisions on areas under her purview.

Recommendation #6: The VP Ethics must report directly to Governing Council.

The Governing Council has no administrative responsibilities at CIHR, and therefore cannot have a VP reporting directly. VPs report administratively to the President who is also Chair of Governing Council. In addition, a report on strategies and actions taken by Science Council to advance the Ethics mandate will be made to Governing Council annually.

By maintaining and strengthening the role of SCE, there will be a strong oversight mechanism in place from Governing Council.

Ethics expertise

Recommendation #10: The Standing Committee on Ethics (SCE) should become a new Ethics Advisory Board for the Ethics VP.

The Governing Council, Science Council and the CSO/VP will be strategically advised by a new Ethics Advisory Board. The Governing Council member will chair this new Ethics Advisory BoardFootnote 1 that will be a Standing Committee of Governing Council. It will include members from Science Council and from among the Institute Advisory Board Ethics Designates so that Science Council formally integrates the ethics mandate. The new structure will allow for integration of scientific (Science Council) institutes (Institutes' Ethics Designates) and managerial (Ethics Office) ethics activities in the organization. The Governing Council member Chair will enable accountability to Governing Council.

Recommendation #14: The selection process for Institute Advisory Board-Ethics Designates should be clarified and made transparent.

At its February 2011 meeting, Governing Council approved the role and core competencies of the Institute Advisory Board-Ethics Designates. The process to appoint an Ethics Designate to an Institute Advisory Board is documented through our governance process.

To improve transparency, we will forthwith additionally post the role, competencies, and Institute Advisory Board appointment process on our website.

Recommendation #15: The Institute Advisory Board-Ethics Designates should receive training in order to have the requisite skills to perform their function.

There are clearly defined roles and core competencies of the Institute Advisory Board-Ethics Designates which they should meet prior to being appointed to the Institute Advisory Boards.

We will review the current skill set of Institute Advisory Board-Ethics Designates and develop an orientation/training process as recommended.

Recommendation #16: The Institute Advisory Board-Ethics Designates must have a mechanism for regular meetings with the VP Ethics and Ethics Office.

The representation of Institute Advisory Board - Ethics Designates on the Ethics Advisory Board will help ensure close communication with the CSO/VP and Ethics Office. These Ethics Designates will be helpful in developing a communications strategy with IABs from all other Institutes.

Recommendation #17: The Chair of the Institute Advisory Board-Ethics Designates should have a seat on the Ethics Advisory Board as ex officio.

The proposed new structure will ensure input of Institute Advisory Board-Ethics Designates, to the new Ethics Advisory Board as well as the CSO/VP and Ethics Office.

Recommendation #8: The VP Ethics must have sufficient support and personnel to carry out its work.

The refreshed Action Plan for ethics will be refined and finalized by the new ethics structure (referred to above as the SCE and Ethics Advisory Board) for approval by Science Council. Assessment of workload and required resources will be undertaken as part of finalizing the Action Plan.

Enhancement of internal awareness and capacity within CIHR

Recommendation #13: Ethics Office should be the point of contact for ethics at CIHR.

The Ethics team as well as the Secretariat on Responsible Conduct of Research are both points of contact for ethics at CIHR. The specific roles for the Ethics Office will evolve as the Ethics Action Plan is finalized.

Recommendation #11: The Ethics Office should have sufficient and trained personnel to support the VP Ethics, Ethics Advisory Board, Institute Advisory Board-Ethics Designates, Institutes, and other ethics initiatives (e.g. SCOC, CCAC).

We agree, as above in response to recommendations #8 and #13.

Recommendation #12: The Ethics Office should have a dedicated financial envelope.

Required support, personnel and other funds required will be considered within the annual operational planning process at CIHR driven by the Science Council approved Ethics Action Plan.

Ethics Action Plan

Recommendation #18: The CIHR Ethics Strategic Plan 2009-2014 and Logic Model for the Function of the Ethics Portfolio at CIHR should be updated, approved, and implemented.

These important documents will be provided to the revised SCE to help them develop performance indicators and targets for the implementation of the Action Plan.

Nurture and monitor research capacity in ethics in Canada

Recommendation #20: CIHR should dedicate at least 3% of its research budget to research in ethics, distributed by the Ethics Office or the Institutes.

As part of the reforms of our open suite of programs, one of the objectives is to integrate ethics research and have it well supported through our core programs.

Any further decision to earmark funding to ethics (or any other area of CIHR) will require decision by Science Council. Institutes, either through dedicated calls or through Signature Initiatives will retain the option of launching specific funding opportunities relevant to ethical areas under their purview. CIHR will better monitor the proportion of funding within investigator-initiated and priority-driven initiatives that are contributing to the achievement of CIHR's ethics mandate.

Footnotes

Footnote 1

By "Ethics Advisory Board" CIHR is referring to the expanded membership and mandate of the SCE.

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