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Proposed Rule would Delay Common Rule General Compliance Date Until January 21, 2019 While Permitting Earlier Implementation of Three “Burden-Reducing” Provisions

In January 2017, the federal departments and agencies that follow the Federal Policy for the Protection of Human Subjects, which is typically referred to as the “Common Rule,” issued a Final Rule substantially revising the Common Rule. The Final Rule set the effective and general compliance dates of the Common Rule revisions as January 19, 2018, but as we reported in an earlier Alert, those dates were delayed until July 19, 2018 through an interim final rule published in January 2018 (the “January 2018 Interim Final Rule”). 83 Fed. Reg. 2,885 (Jan. 22, 2018). The January 2018 Interim Final Rule stated that the general compliance date may be subject to additional delay through further rulemaking.

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