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Just-in-Time Human Subjects Review


What is the Just-in-Time Review Process?

Many sponsors require human subjects approval, or at least pending approval, before accepting new grant proposals. Some sponsors , however, will accept new grant proposals with the understanding that the researcher will proceed with the human subjects review process upon receiving notification of a score in the fundable range. This is called the Just-in-Time review process. The previous method of doing this, the Letter of Intent, is no longer effective.

Which proposals can be submitted with Just-in-Time?

If the proposal is being submitted to one of the funding agencies on the List of Sponsors Currently Accepting Just-in-Time Human Subjects Review, the proposal can be submitted using the Just-in-Time procedure.

Some private, non-profit organizations will accept Just-in-Time review. It is the investigator's responsibility to provide documentation that a sponsor will accept such review. This documentation must be submitted to OSP with the grant proposal in the form of:

  • A letter from the sponsor on agency letterhead acknowledging the agency will accept Just-in-Time Human Subjects Review; or
  • A copy of the sponsor's instructions which clearly state that human subjects approval or pending approval is not required at the time of proposal submission.


How to Request Just-in-Time Human Subjects Review

If your sponsor accepts Just-in-Time Human Subjects Review, select Just-in-Time on the eGC1 Form, "Compliance Explanations," when preparing the proposal for submission to Office of Sponsored Programs.

Research Investigator's Responsibility for proposals submitted under Just-in-Time Policy

Researchers who learn that their proposal may be funded (i.e., who learn that the award was scored in the fundable range) should submit the appropriate Human Subjects Review Committee application form for review. This must be done at least 60 days before intent to approach, recruit, or enroll any subjects. An award will be restricted until final human subjects approval has been received. No portion of the proposed research can be conducted unless the proposal is funded and until after the proposal has received Human Subject Review Committee review and approval.