Monitors research compliance with federal regulations (21 CFR, 45 CFR 46) and institutional policies. Use when ensuring research compliance, managing regulatory requirements, or conducting compliance reviews.
Research compliance encompasses the network of federal, state, and institutional regulations that govern human-subjects research in the United States. The regulatory landscape includes the Common Rule (45 CFR 46), FDA regulations (21 CFR Parts 50, 56, 312, 812), HIPAA (45 CFR Parts 160, 164), NIH policies (financial conflict of interest, data sharing, inclusion), and institutional requirements (FWA, IRB policies, conflict of interest). Non-compliance exposes institutions to federal sanctions (suspension of FWA, debarment from federal funding), participants to unacceptable risk, and investigators to personal liability. This skill provides the operational framework for monitoring, maintaining, and auditing research compliance across a clinical research program.
Checkpoint A — Intake and Scoping
Required Intake Questions
What is the scope of this compliance assessment (institutional program, specific study, specific investigator, specific regulatory domain)?
What types of research are conducted (FDA-regulated trials, federally funded non-FDA research, industry-sponsored, investigator-initiated)?
What is the institution's Federal Wide Assurance (FWA) number and status?
Is there an active Institutional Review Board (IRB) with FDA registration, or does the institution rely on an external/commercial IRB?
Are there current or recent compliance findings (FDA 483s, OHRP determination letters, NIH audit findings, sponsor audit findings)?
Ensure no billing of research costs to participant insurance
Monitor investigator compensation against fair-market-value benchmarks
Audit grant expenditures against approved budgets and allowable costs
Step 4 — Manage Regulatory Inspections
Prepare for and manage FDA, OHRP, and sponsor inspections:
Pre-Inspection Preparation
Maintain inspection-ready documentation at all times (do not rely on pre-inspection scrambles)
Conduct mock inspections annually
Ensure all regulatory binders are current and organized
Verify all essential documents are in the TMF
Identify an inspection point-of-contact and escort
During Inspection
Cooperate fully and transparently
Provide requested documents promptly
Answer questions truthfully — do not speculate; "I'll need to verify that and get back to you" is an acceptable answer
Take notes on all observations and questions
Do not volunteer information beyond what is requested
Post-Inspection Response
FDA Form 483: Respond within 15 business days with CAPA plan for each observation
OHRP determination letter: Respond per the timeline specified in the letter
Track all CAPA commitments to completion
Implement systemic changes to prevent recurrence
Document effectiveness checks for each CAPA
Step 5 — Manage Non-Compliance Events
When non-compliance is identified:
Assessment: Determine scope (isolated incident vs. systemic), severity (participant safety impact, data integrity impact), and regulatory-reporting obligations
Immediate actions: If participant safety is at risk, take immediate protective action (suspend enrollment, notify participants, provide medical care)
Reporting: Report to IRB (unanticipated problem, protocol deviation, non-compliance); report to sponsor; report to FDA (if IND safety reporting criteria met); report to OHRP (if serious or continuing non-compliance per 45 CFR 46.108(a)(4))
CAPA: Develop corrective actions (immediate fixes) and preventive actions (systemic changes); assign responsibility and timeline
Follow-up: Monitor CAPA implementation; verify effectiveness; close out with documentation
Checkpoint B — Compliance Review
All applicable regulations are identified and mapped to institutional activities
FWA is active and IRB registrations are current
COI disclosures are complete and management plans are in place
Training records are current for all research personnel
ClinicalTrials.gov registrations and results postings are current
Protocol deviation rates are monitored and trended
Informed consent compliance is audited regularly
21 CFR Part 11 compliance is documented for all electronic systems
Inspection-readiness assessment has been conducted within the past 12 months
All open CAPA plans are tracked and progressing toward completion
Quality Audit
Regulatory-framework mapping is complete and current (including recent rule changes)
No lapsed IRB approvals exist for active studies
Financial disclosures are reconciled with institutional COI records
ClinicalTrials.gov registration dates comply with the 21-day requirement
Data-retention policies meet the longest applicable requirement across all regulations
HIPAA authorization or waiver documentation is on file for every study using PHI
Research misconduct reporting procedures are documented and personnel are trained
Compliance metrics (deviation rates, audit findings, training completion) are reported to institutional leadership
All [VERIFY] flags have been resolved or escalated
Guidelines
Compliance is a floor, not a ceiling — meeting regulatory minimums is necessary but not sufficient for research excellence
Non-compliance reporting is mandatory and time-sensitive — delayed reporting compounds the violation and regulatory response
Maintain a culture of compliance: train personnel to report concerns without fear of retaliation; implement reporting mechanisms (hotline, anonymous reporting)
Proactive self-assessment (internal audits, mock inspections) is far preferable to reactive responses to external findings
ClinicalTrials.gov non-compliance now carries substantial financial penalties — treat registration and results reporting as mandatory obligations, not administrative tasks
The 2018 Common Rule revisions introduced significant changes (single-IRB mandate, broad-consent provisions, exempt-category changes) — ensure institutional policies reflect the current rule
FDA BIMO inspections are unannounced for cause-based inspections — inspection readiness must be continuous
Research misconduct (fabrication, falsification, plagiarism) has the most severe consequences — zero-tolerance policy and clear reporting procedures are essential
Mark any compliance gap that may require regulatory notification with [VERIFY] for institutional compliance officer and legal counsel review
This skill produces compliance management frameworks — compliance determinations, regulatory notifications, and inspection responses require qualified research-compliance professionals and institutional legal counsel
1---2name: managing-research-compliance3description: Monitors research compliance with federal regulations (21 CFR, 45 CFR 46) and institutional policies. Use when ensuring research compliance, managing regulatory requirements, or conducting compliance reviews.4---56# Managing Research Compliance78## Why This Skill Exists910Research compliance encompasses the network of federal, state, and institutional regulations that govern human-subjects research in the United States. The regulatory landscape includes the Common Rule (45 CFR 46), FDA regulations (21 CFR Parts 50, 56, 312, 812), HIPAA (45 CFR Parts 160, 164), NIH policies (financial conflict of interest, data sharing, inclusion), and institutional requirements (FWA, IRB policies, conflict of interest). Non-compliance exposes institutions to federal sanctions (suspension of FWA, debarment from federal funding), participants to unacceptable risk, and investigators to personal liability. This skill provides the operational framework for monitoring, maintaining, and auditing research compliance across a clinical research program.1112---1314## Checkpoint A — Intake and Scoping1516### Required Intake Questions171. What is the scope of this compliance assessment (institutional program, specific study, specific investigator, specific regulatory domain)?182. What types of research are conducted (FDA-regulated trials, federally funded non-FDA research, industry-sponsored, investigator-initiated)?193. What is the institution's Federal Wide Assurance (FWA) number and status?204. Is there an active Institutional Review Board (IRB) with FDA registration, or does the institution rely on an external/commercial IRB?215. Are there current or recent compliance findings (FDA 483s, OHRP determination letters, NIH audit findings, sponsor audit findings)?226. What institutional compliance infrastructure exists (research compliance officer, compliance committee, quality-assurance unit)?237. What electronic systems support compliance tracking (IRB management system, CTMS, COI management system)?248. Are there active investigations or corrective action plans?259. What is the institutional training program (CITI, institutional modules)?2610. What is the regulatory inspection history (FDA BIMO, OHRP compliance evaluation, NIH audit)?2728### Required Source Documents29- Institutional FWA terms and conditions30- IRB policies and procedures manual31- Institutional COI policy32- HIPAA research policies33- FDA Form 1572s for active IND studies34- FDA Form 3674 (ClinicalTrials.gov registration certification)35- NIH data-sharing agreements and policies36- Recent compliance audit reports and CAPA plans37- Institutional training requirements and completion records38- Active study regulatory binders (sample for audit)3940---4142## Step 1 — Map the Regulatory Framework4344Identify all applicable regulations for the institution's research portfolio:4546### Federal Regulations47| Regulation | Scope | Key Requirements |48|------------|-------|------------------|49| 45 CFR 46 (Common Rule) | All federally funded human-subjects research | IRB review, informed consent, vulnerable populations protections, FWA |50| 21 CFR 50 | FDA-regulated research | Informed consent requirements (overlaps with Common Rule but has FDA-specific provisions) |51| 21 CFR 56 | FDA-regulated research | IRB requirements for FDA-regulated studies |52| 21 CFR 312 | Investigational drugs | IND requirements, investigator obligations, sponsor obligations, safety reporting |53| 21 CFR 812 | Investigational devices | IDE requirements, investigator obligations, sponsor obligations |54| 21 CFR 11 | Electronic records | Electronic records and signatures (audit trails, validation, access controls) |55| 21 CFR 54 | FDA-regulated research | Financial disclosure of clinical investigators |56| 45 CFR 160/164 (HIPAA) | All research with PHI | Privacy Rule, Security Rule, research use/disclosure of PHI |57| 42 CFR 93 | PHS-funded research | Research misconduct (fabrication, falsification, plagiarism) |58| 42 CFR 50 Subpart F | PHS-funded research | Financial conflict of interest (FCOI) |59| 45 CFR 46 Subparts B-D | Specific populations | Additional protections for pregnant women, prisoners, children |6061### NIH Policies (Non-CFR but Mandatory for NIH-Funded Research)62- NIH Policy on Inclusion of Women, Minorities, and Children63- NIH Data Management and Sharing Policy (2023)64- ClinicalTrials.gov Registration and Results Reporting (FDAAA 801, 42 CFR 11)65- NIH Genomic Data Sharing Policy66- NIH Policy on Clinical Trial Registration (single-IRB mandate for multi-site trials)6768### State Regulations69- State human-subjects protections (may exceed federal requirements)70- State privacy laws (e.g., California CCPA/CPRA, state genetic-information laws)71- State laws on legally authorized representatives7273---7475## Step 2 — Audit the Institutional Compliance Infrastructure7677Assess the structural elements required for compliance:7879### Institutional Assurance (FWA)80- Verify FWA is active and covers all applicable research81- Confirm IRB(s) are registered with OHRP and FDA82- Verify the Institutional Official understands their obligations under the FWA8384### IRB Operations85- IRB composition meets regulatory requirements (at least 5 members, one non-scientist, one non-affiliated, diversity in background)86- Quorum and voting procedures comply with 45 CFR 46.10887- Review turnaround times meet institutional benchmarks88- Continuing-review cycles are current (no lapses in approval)89- IRB records are complete and retained per institutional policy9091### Conflict of Interest Management92- FCOI policy complies with 42 CFR 50 Subpart F (for PHS-funded research) and 21 CFR 54 (for FDA-regulated research)93- All investigators disclose financial interests before research begins and annually94- FCOI management plans are in place for identified conflicts95- COI training is completed within required timeframes9697### Training Program98- All research personnel complete required training before engaging in research activities99- Training includes GCP (ICH-GCP E6(R2)), human-subjects protection (CITI or equivalent), HIPAA, COI100- Training is renewed per institutional policy (typically every 2-3 years)101- Training records are centrally maintained and auditable102103---104105## Step 3 — Conduct Compliance Monitoring106107Implement ongoing monitoring across key compliance domains:108109### Protocol Compliance110- Monitor protocol deviation rates by study and site111- Classify deviations as major (affecting safety, rights, or data integrity) or minor112- Track CAPA implementation for recurring deviations113- Report major deviations to IRB, sponsor, and FDA (if applicable) per reporting requirements114115### Informed Consent Compliance116- Audit consent forms for completeness (signatures, dates, correct version, all pages)117- Verify consent process (adequate time, appropriate setting, qualified personnel)118- Confirm re-consent for protocol amendments and new safety information119- Monitor consent deviations (enrolled without consent, wrong version, expired consent)120121### ClinicalTrials.gov Compliance122- Verify registration within 21 days of first enrollment (FDAAA 801 requirement)123- Verify results posting within 12 months of primary completion date124- Monitor for data accuracy (enrollment numbers, status updates, results completeness)125- Non-compliance carries civil monetary penalties of up to $11,569 per day per 42 CFR 11126127### Data Integrity Compliance128- Audit 21 CFR Part 11 compliance for electronic systems129- Verify ALCOA+ principles in source documents and CRFs130- Monitor for research misconduct indicators (fabrication, falsification, plagiarism)131- Ensure data are retained for the required period (2 years after NDA approval per 21 CFR 312.62; or per institutional policy if longer)132133### Financial Compliance134- Verify clinical-trial invoicing matches contracted activities135- Ensure no billing of research costs to participant insurance136- Monitor investigator compensation against fair-market-value benchmarks137- Audit grant expenditures against approved budgets and allowable costs138139---140141## Step 4 — Manage Regulatory Inspections142143Prepare for and manage FDA, OHRP, and sponsor inspections:144145### Pre-Inspection Preparation1461. Maintain inspection-ready documentation at all times (do not rely on pre-inspection scrambles)1472. Conduct mock inspections annually1483. Ensure all regulatory binders are current and organized1494. Verify all essential documents are in the TMF1505. Identify an inspection point-of-contact and escort151152### During Inspection1531. Cooperate fully and transparently1542. Provide requested documents promptly1553. Answer questions truthfully — do not speculate; "I'll need to verify that and get back to you" is an acceptable answer1564. Take notes on all observations and questions1575. Do not volunteer information beyond what is requested158159### Post-Inspection Response1601. FDA Form 483: Respond within 15 business days with CAPA plan for each observation1612. OHRP determination letter: Respond per the timeline specified in the letter1623. Track all CAPA commitments to completion1634. Implement systemic changes to prevent recurrence1645. Document effectiveness checks for each CAPA165166---167168## Step 5 — Manage Non-Compliance Events169170When non-compliance is identified:1711721. **Assessment**: Determine scope (isolated incident vs. systemic), severity (participant safety impact, data integrity impact), and regulatory-reporting obligations1732. **Immediate actions**: If participant safety is at risk, take immediate protective action (suspend enrollment, notify participants, provide medical care)1743. **Reporting**: Report to IRB (unanticipated problem, protocol deviation, non-compliance); report to sponsor; report to FDA (if IND safety reporting criteria met); report to OHRP (if serious or continuing non-compliance per 45 CFR 46.108(a)(4))1754. **Investigation**: Conduct root-cause analysis; interview personnel; review documentation; determine contributing factors1765. **CAPA**: Develop corrective actions (immediate fixes) and preventive actions (systemic changes); assign responsibility and timeline1776. **Follow-up**: Monitor CAPA implementation; verify effectiveness; close out with documentation178179---180181## Checkpoint B — Compliance Review1821831. [ ] All applicable regulations are identified and mapped to institutional activities1842. [ ] FWA is active and IRB registrations are current1853. [ ] COI disclosures are complete and management plans are in place1864. [ ] Training records are current for all research personnel1875. [ ] ClinicalTrials.gov registrations and results postings are current1886. [ ] Protocol deviation rates are monitored and trended1897. [ ] Informed consent compliance is audited regularly1908. [ ] 21 CFR Part 11 compliance is documented for all electronic systems1919. [ ] Inspection-readiness assessment has been conducted within the past 12 months19210. [ ] All open CAPA plans are tracked and progressing toward completion193194---195196## Quality Audit197198- [ ] Regulatory-framework mapping is complete and current (including recent rule changes)199- [ ] No lapsed IRB approvals exist for active studies200- [ ] Financial disclosures are reconciled with institutional COI records201- [ ] ClinicalTrials.gov registration dates comply with the 21-day requirement202- [ ] Data-retention policies meet the longest applicable requirement across all regulations203- [ ] HIPAA authorization or waiver documentation is on file for every study using PHI204- [ ] Research misconduct reporting procedures are documented and personnel are trained205- [ ] Compliance metrics (deviation rates, audit findings, training completion) are reported to institutional leadership206- [ ] All [VERIFY] flags have been resolved or escalated207208---209210## Guidelines2112121. Compliance is a floor, not a ceiling — meeting regulatory minimums is necessary but not sufficient for research excellence2132. Non-compliance reporting is mandatory and time-sensitive — delayed reporting compounds the violation and regulatory response2143. Maintain a culture of compliance: train personnel to report concerns without fear of retaliation; implement reporting mechanisms (hotline, anonymous reporting)2154. Proactive self-assessment (internal audits, mock inspections) is far preferable to reactive responses to external findings2165. ClinicalTrials.gov non-compliance now carries substantial financial penalties — treat registration and results reporting as mandatory obligations, not administrative tasks2176. The 2018 Common Rule revisions introduced significant changes (single-IRB mandate, broad-consent provisions, exempt-category changes) — ensure institutional policies reflect the current rule2187. FDA BIMO inspections are unannounced for cause-based inspections — inspection readiness must be continuous2198. Research misconduct (fabrication, falsification, plagiarism) has the most severe consequences — zero-tolerance policy and clear reporting procedures are essential2209. Mark any compliance gap that may require regulatory notification with [VERIFY] for institutional compliance officer and legal counsel review22110. This skill produces compliance management frameworks — compliance determinations, regulatory notifications, and inspection responses require qualified research-compliance professionals and institutional legal counsel
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Monitors research compliance with federal regulations (21 CFR, 45 CFR 46) and institutional policies. Use when ensuring research compliance, managing regulatory requirements, or conducting compliance reviews. It is listed under Research & Search on SkillMD.
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