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May 19, 2013

HHS Extends Comment Period for Advanced Notice of Proposed Rule Making Concerning the Common Rule

On July 26, 2011, the U.S. Department of Health and Human Services (HHS) issued an advance notice of proposed rulemaking (ANPRM) entitled “Human Subjects Research Protections: Enhancing Protections for Research Subjects and Reducing Burden, Delay, and Ambiguity for Investigators,” (Volume 76, Number 143, page 44512).  The comment period was to close on September 26, 2011, however, in light of numerous requests, HHS has extended it by 30 days.  Thus the comment period now ends October 26, 2011.  Due to the wide-ranging potential impact of the proposed changes on human subjects research conducted domestically, this extension gives sponsors, investigators, institutional review boards, contract research organizations and others likely to be affected by the sweeping proposed changes much needed additional time to fully review and comment on the ANPRM. 

For additional information about the ANPRM, please click here and here.

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Bernadette M. Broccolo is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Chicago office.  Bernadette has been counseling health industry organizations for 29 years.  She currently serves as chair of the Life Sciences Division of the Firm’s Health Industry Advisory practice and as co-chair of the Personalized Medicine team.

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James (Jim) S. Cohen is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Washington, D.C., office.  He is head of the Firm's Food and Drug Administration (FDA) practice.  Jim focuses his practice on the development, clinical investigation, approval, and marketing of drugs, medical devices, biologics, combination products, and other FDA regulated products. He has been recognized by Legal 500 as one of the leading lawyers in his field.

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Jennifer S. Geetter is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Washington, D.C., office.  She focuses her practice on emerging biotechnology and safety issues, advising hospital, industry, insurance and provider clients on matters relating to research, drug and device development, off-label use, personalized medicine, formulary compliance, privacy and security, electronic health records and data strategy initiatives, patient safety, conflicts of interest, scientific review and research misconduct, internal hospital...

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