Background
Pragmatic trials comparing ‘standard of care’ treatments provide comparative effectiveness data to make practice of medicine more evidence-based. With electronic health records, recruiting and conducting such trials can be relatively inexpensive. But some worry that the traditional research ethics framework poses unnecessary obstacles and is not appropriate for evaluating such clinical trials. This concern is based on the view (which we call the ‘Standard of Care Principle’) that such research is similar to usual clinical practice and therefore does not raise significant ethical issues since everyone in the research study will receive an accepted standard of care treatment.
Methods
A case study of a pragmatic RCT (BPMedTime study) comparing morning versus nighttime dosing of antihypertensive medications. The BPMedTime study has been proposed as a paradigm example of why the Standard of Care Principle obviates the need for traditional levels of ethical scrutiny and how the current regulatory framework poses unnecessary obstacles to research. We provide an ethical analysis of the BPMedTime study drawing on empirical literature as well as normative analysis.
Results
The Standard of Care Principle is the main ethical rationale given by commentators for asserting that the BPMedTime study does not require “significant ethical debate” and by investigators for the assertion that the BPMedTime study is minimal risk and thus eligible for lessened regulatory requirements. However, the BPMedTime study raises important ethical issues, including whether it is even necessary, given the considerable RCT evidence in support of nighttime dosing, a much larger (N≈17000) confirmatory RCT already in progress, evidence for safety of nighttime dosing, and the cost-free availability of the intervention. Further, the Standard of Care Principle provides a misleading basis for analyzing the informed consent requirements, especially regarding the requirement to disclose alternative courses of treatment that “might be advantageous to the subject.”
Conclusions
The Standard of Care Principle is ethically inadequate and misleading even when it is applied to the pragmatic RCT proposed as a paradigm case for its application.