- Director, Office of Human Research
- Director, Clinical Research Unit
- Professor, SKMC Department of Pharmacology & Experimental Therapeutics
For Research Activities
- Senior Associate Provost, Research Conduct & Compliance
- Professor, SKMC Department of Pathology, Anatomy & Cell Biology
About IRB Reliance
IRB Reliance (or “single IRB review”) is a legal arrangement that allows one IRB to review a study that is occurring at multiple sites or to review a single-site study that involves personnel from multiple institutions. Opportunities for single IRB review are established by entering into formal IRB reliance agreements.
Investigators that would like to initiate a multi-site study consolidated under single IRB review, where TJU will serve as IRB of record MUST attend a Zoom meeting prior to finalizing any grant submissions or submitting to the IRB. Please contact Jennifer.Polizzi@Jefferson.edu to schedule this meeting.
What is an IRB reliance agreement?
A reliance agreement is signed by two or more institutions that normally would be required to conduct their own IRB review. The reliance agreement allows for one IRB to conduct the review that fulfills federal requirements about human subjects protection. The other institutions "rely" on the reviewing IRB, thus streamlining the approval process. Even when relying on another IRB, all institutions must comply with applicable state laws and institutional policies.
Under what circumstances can a single IRB review be arranged?
- When the Jefferson IRB is being asked to serve as the reviewing IRB for a multicenter study.
- When Jefferson personnel plan to participate in research covered by another IRB.
- When Jefferson investigators plan to conduct research at non-Jefferson locations and personnel from the non-Jefferson location will be part of the study team, or
- When non-Jefferson personnel come to Jefferson to participate in our research.
Is Jefferson willing to serve as the single IRB for a multisite study?
Yes, in many cases Jefferson is able to serve as the single IRB. The IRB will evaluate the investigator’s plan to oversee the study and assist the investigator in making arrangements for review of the non-Jefferson sites.
How do I get approval to work with an outside IRB?
When requesting oversight by an outside IRB, investigators must always start with a permission from their home institution.
Why are reliance agreements necessary?
Every institution is responsible for research conducted by its own personnel, regardless of where the research occurs. When Jefferson personnel conduct human subjects research, the institution has two options:
- Review the research through the Jefferson IRB, or
- Arrange reliance on another qualified IRB
Jefferson personnel may not conduct human subjects research until approval has been obtained through one of the above options and all institutional requirements have been met.
Which IRBs can I use?
Our current IRB reliance arrangements include:
- SMART IRB (a network of 500+ academic institutions, hospitals, and institutes)
- NCI CIRB
- WIRB-Copernicus Group
- NIH Strokenet
Besides IRB review, what else do I need?
Even when an external IRB reviews and oversees a project, there are other institutional requirements that must be addressed. These include requirements for investigator training, conflict of interest review, HIPAA, data security, SKCC PRC, radiation safety, management of grants and contracts, and compliance with state laws. These additional requirements are categorized as “local context” issues that are evaluated at the time the study is proposed.
Once an external IRB has approved the study, what updates does Jefferson require?
Investigators using an external IRB remain responsible to update the IRB when key events occur. The IRB must be aware of:
- Changes to study personnel
- Annual review report
- Updates on conflict of interest disclosures
- Injury to a Jefferson subject
- Protocol deviations that could impact safety or data integrity
When should I request a single IRB review?
Please request a single review as early as possible, in the planning stages of your project.
- For new studies, the PI should pursue this step before the grant submission (if applicable) or before submitting the protocol to any IRB for review.
- When a new site or external collaborator is added to a study that is already approved at Jefferson, please contact the IRB office as soon as the site or collaborator is identified. The Jefferson IRB office can work with the other organization to see if they will rely on our review.
How do I get started with a request for a single IRB review?
All research proposals are submitted through iRIS
Am I required to rely on a single IRB for a multisite study?
In general, any institution located in the United States that is engaged in cooperative (involving more than one institution), federally funded research (where each site will conduct the same protocol) must rely upon approval by a single IRB for that portion of the research that is conducted in the United States. Please see the policy for additional information.
What if I’m preparing a grant or have a grant-based deadline?
If preparing a grant proposing that Jefferson IRB serve as the reviewing IRB, contact the IRB at least four weeks before the proposal is due, to ensure the IRB is willing to serve. Similarly, if the grant will require that Jefferson rely on an external IRB, contact the IRB In plenty of time to receive a response prior to the grant deadline.
I’ve received a continuing review approval letter and stamped consent form from the IRB of record. What do I do?
You should submit these documents to the Jefferson IRB for review. The Jefferson IRB will update its tracking system to reflect the new approval period. You are not required to complete the Continuing Review Form (OHR-9).
How do I close the study when using an external IRB?
You should first submit a closure request to the IRB of record for review and approval, according to their submission procedures. Once the IRB of record has closed the study, you should submit a copy of the closure letter to the Jefferson IRB.