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Dual IRB review

National VA policy does not allow VA IRBs to have cooperative agreements with other IRBs. Therefore, any UW research that involves the VA in certain ways will require dual IRB review - that is, review by both the UW IRB and the VAPSHCS IRB. Similarly, VA research that involves the UW in certain ways will require dual IRB review. To assist in determining if this is the case, read UW Engagement in VA Research (VA-854) - 06/11/2009.

The primary IRB review is by the home institution of the principal investigator (PI) who is initiating the research. The second institution is required to review only those activities that involve the second institution, though its IRB may decide in some cases to review the entire study.

Identifying the need for dual review

UW principal investigator (PI) who is not a VA employee

If any of the following circumstances are true for the UW research, then the VA is involved in a way that requires dual review.

• A grant, contract, sub-contract, or financial cooperative agreement that supports or partially supports the research and is for activities considered to be "human subjects research" is administered through the VA or the Seattle Institute for Biomedical and Clinical Research (SIBCR).
• VA employees perform research procedures with the subjects or with identifiable subject data or specimens. It does not matter whether the VA employee has a UW faculty appointment or other UW affiliation.
• VA employees obtain the informed consent of some or all subjects.
• VA employees receive or obtain identifiable private information or identifiable biological specimens for research purposes (even if they do not directly interact or intervene with the subjects).
  Exception: If the VA employee's time spent on the research is paid for by money coming from or through the UW, then the VA is not considered to be involved in a way that requires dual review.

VA principal investigator (VA employee)

Refer to the document UW Engagement in VA Research (VA-854) - 06/11/2009 to determine whether the research involvement of the UW requires dual review. Having a UW affiliation (such as a faculty appointment) is not sufficient reason for requiring dual review.