Who Watches the Watchdogs?

Lessons from the United States for Research Ethics Oversight

When we think about protecting research participants, most of us think about ethics committees.

Researchers submit applications. Committees review them. Studies are approved, further information is requested, or they are declined.

The system appears reassuringly simple.

But recently, a story emerging from the United States has highlighted a question that few researchers, and even fewer members of the public, ever stop to ask:

“Who watches the watchdogs?”

A major investigation by STAT has revealed growing concerns about the future of the United States Office for Human Research Protections (OHRP), the federal agency responsible for overseeing the country's human research protection system. Years of under-resourcing, combined with recent staffing losses, have left the organisation struggling to maintain many of the functions that sit behind research ethics oversight. Rather than expanding alongside an increasingly complex research environment, OHRP has seen its workforce shrink dramatically, raising concerns about its ability to provide effective oversight, education, compliance monitoring, and institutional support.

This is not a story about an ethics committee making a poor decision.

It is a story about what happens when the organisations responsible for supporting, educating, monitoring, and holding ethics committees accountable begin to weaken.

And while New Zealand's research ethics system is very different from that of the United States, the questions raised by this story are surprisingly relevant here.

This blogpost is based on the following piece which we strongly encourage you to read:

Molteni, M. (2026, June 5). Tiny HHS office tasked with protecting research participants' safety is running on fumes. STAT Special Report. This investigation examines the challenges facing the United States Office for Human Research Protections (OHRP), including staffing reductions, oversight capability, education functions, and the future of research participant protections.

The author would also like to acknowledge members of The Consortium to Advance Effective Research Ethics Oversight (AEREO) for sharing and discussing this article, which prompted valuable reflection on the role of oversight within research ethics systems.

The Oversight Nobody Sees

Most researchers understand that ethics committees review research. Far fewer understand the systems that sit behind them.

Every ethics review ecosystem relies on a network of functions that are largely invisible to researchers and participants. Someone develops guidance. Someone investigates complaints. Someone monitors compliance trends. Someone identifies emerging ethical issues and provides education to the sector. Someone asks difficult questions when things appear to be working perfectly.

These activities rarely attract attention because they operate in the background. When they function well, they are almost invisible. They play a critical role in maintaining public confidence that research is being conducted ethically and responsibly.

The challenge is that these functions can be easy to take for granted.

The Lesson Emerging from the United States

One of the most striking observations from the STAT investigation was that the concern was not necessarily about an immediate collapse of research ethics protections. It was about the gradual erosion of capability:

• Training programmes disappear.

• Educational events stop being delivered.

• Compliance investigations take longer.

• Site visits become harder to conduct.

• Institutional knowledge is lost when experienced staff leave and are not replaced.

The system continues to operate, but its ability to learn, improve, and identify problems begins to weaken.

As one commentator noted in the article, the greatest risk may not be that standards suddenly disappear. The greater risk is that it becomes increasingly difficult to know whether those standards are being met.

That is a much harder problem to detect, and a much harder problem to fix.

Why This Matters Beyond the United States

It would be easy to dismiss this as a unique situation. The United States operates a vastly different research system, with different funding arrangements, regulatory structures, and oversight mechanisms to Aotearoa.

But the underlying challenge is universal.

Research ethics depends on more than individual committees. It depends on the systems that support those committees, expertise being maintained behind the scenes, guidance evolving with the environment and ongoing education.

And it depends on someone having both the authority and the capacity to step back and ask whether the system itself is working as intended.

These responsibilities exist regardless of the size of a country's research sector.

The Cost of Success

There is an irony at the heart of research ethics oversight. When it works well, almost nobody notices it.

Participants rarely see it. Researchers often encounter it only briefly. Governments may view it as a background function operating quietly behind the scenes.

But it is precisely because these systems work quietly that they are vulnerable to being overlooked.

The most successful oversight structures are often the least visible, and yet they are fundamental to maintaining public trust.

Final Thoughts

The lessons emerging from the United States are not necessarily about one agency, one government, or one country.

They are a reminder that ethical research depends on more than ethics committees alone.

It depends on the often unseen systems that support them; those people behind the scenes who provide guidance, who investigate concerns raised and who take the time to monitor trends, identify risks, and ensure accountability.

Because ethics review is only as strong as the structures that stand behind it.

And somebody, somewhere, must always be watching the watchdogs.