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Submitted by Drew on

The three R's have it: Registration, Reporting and Regulation.

Registration: Registration of a Pre-Analysis plan after data collection has been concluded is hardly good practice. In this instance the data was collected between May 2011 and January 2013, while the study was registered on June 28, 2013. Yes the AEA Registry was not there but the ClinicalTrials.gov has been in existence over a decade, and the lead author was funded by the NIH that requires this reporting

Looking at an earlier RCT prepared in June 2011, the evaluation questions including benchmarking UCTs with CCTs as well as in-kind transfers plus health insurance. However the pre-analysis plan prepared in 2013 discusses none this. Conversely the violence to female household heads, community disquiet etc etc do not find any mention in the earlier version. This not unusual. Hence the need for ex ante registration prior to data collection to allow for the viewer to see the evolution of the study design over the course of the implementation.

How did any IRB approve of an assessment undertaken by co-PI/author who is also one of the four initial founders of this start-up? Mr. Shapiro should have recused himself at the outset

Finally Give Directly is operating a money remittance provider (MRP)in Kenya it needs to follow the regulatory guidelines laid down by the Central Bank of Kenya. An important component is Know Your Customer (KYC) that requires detailed record keeping and internal controls that would be inspected by the agency tasked with oversight before being issued a license.

On the other hand if the organization is a social work agency then it would need to state what legal responsibility if any it will bear for harm caused to a recipient through its cash transfer. Their blog on the case of young woman Christine, http://www.givedirectly.org/blog_post.php?id=6234197500075333847, is a reminder of this real possibility.