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Human Subjects Division (HSD)


New UW Policy - National Science Foundation and the Timing of IRB Applications

Mar 25, 2011 at 2:15pm

Effective:   March 15, 2011

The UW Office of Sponsored Programs (OSP) has confirmed with the National Science Foundation (NSF) that institutions may decide that they will operate on a “Just-in-Time” basis for NSF grant proposals.  The UW Office of Research has decide to adopt a Just-in-Time policy for NSF grant proposals, effective immediately.  Note that the Just-in-Time policy already applies to NIH grant proposals.

What is Just-in-Time?
This means that researchers do not need to submit an IRB application at the same time they submit a grant proposal.  Instead, they submit their IRB applications as soon as the grant proposal appears likely to be funded.  The funding agencies release the funds when the researcher has received IRB approval.

What is the advantage of Just-in-Time?
Researchers will not have had to prepare IRB applications for grant proposals that are not funded.

How should researchers answer the IRB approval question on NSF grant proposals?
Select PENDING.   This has been confirmed with NSF.

How should researchers fill out the eGC1?
If the grant proposal involves human subjects, check YES on the human subjects question. Then check YES on the Just-in-Time box.

How do researchers know when to submit the IRB application?
The OSP system will automatically send an email to the researcher five months after a NSF or NIH grant proposal has been submitted. The email reminds the researcher that IRB approval will be required before grant funds can be released and that the researcher should submit an IRB application soon, or when the researcher believes that the grant proposal is likely to be funded.

What else should researchers know about this new policy?
Researchers do not receive a priority score for NSF grant proposals during the grant review process (unlike the NIH review process).  This means that there is likely to be little time between the date when a researcher learns that a NSF grant proposal is being funded and the date when NSF expects the IRB approval.  Though the IRBs do the best they can in these situations, it is the researcher’s responsibility to ensure that there is sufficient time for the IRB to review and approve an application.  The Approval in Principle mechanism cannot be used to address funding agency IRB requirements, except in rare circumstances.