Research and biobank funders and regulators have a crucial role to play in making sure that research and biobank budgets adequately support responsible management of IFs and IRRs. They also have a crucial role to play in making sure that research oversight and biobank guidelines support sound handling of IFs and IRRs. Further work is needed to articulate ethical standards for research with human data and/or samples that is not considered “human subjects research” under the Common Rule.
