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Is there any work I can do on an FDA-regulated study on a contractual or sub-award basis?

Yes, the following work can be done:

  •  data analysis (whether or not the data are identifiable)
  •  discussing a study with potential subjects (but not obtaining consent)
  •  pre-screening of records for eligibility determination
  • procedures that will be performed as part of clinical practice and which would be performed exactly the same way regardless of whether the subject is in the study.