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Single IRB

The Single IRB Mandates

The federal requirement for single IRB (sIRB) review comes from two separate mandates:

Revised Common Rule

The revised federal Common Rule contains a new requirement for single IRB review for collaborative, non-exempt human subjects research that involves multiple institutions. This applies to all federally-funded or supported research (with the exception of Department of Justice funded projects). It went into effect January 21, 2020.

NIH Policy

This is distinct from the Common Rule requirement and applies to most grants and contracts submitted to NIH on or after January 25, 2018 that involve multi-site, non-exempt human subjects research. The policy defines multi-site research as a subset of collaborative research that requires the use of a single IRB. It is important to identify when a project must comply with the NIH policy because there are specific, NIH requirements that must be present in the grant or contract applications for studies subject to this policy that do not apply to studies under the broader Common Rule requirement.

The information on these webpages is designed for studies that must comply with either of these mandates, however it may also be useful for researchers wishing to use a single IRB for multi-institutional (multi-site or collaborative) studies that are not federally-funded.

Definition of “multi-site” for NIH funded research

“Multi-site” means that the same research procedures (i.e., protocol) are being conducted at one or more domestic sites and that each site is under the control of a local participating investigator. This typically involves a lead site that receives the grant or contract directly from NIH and that then establishes a subaward or subcontract to each participating site. The research could be a clinical trial, an observational study, or a basic clinical research study.

“Same Research Protocol”

Protocols that address the same research questions, involve the same methodologies, and evaluate the same outcomes are considered to be the “same research protocol.” Additionally, sites that are accruing research participants for studies that are identical except for variations due to local context consideration would be considered to be conducting the “same research protocol.” If a study involves a separate site for study coordination or coordination of data and statistical analyses and the site is conducting the same protocol as the other participating sites, then all sites would be expected to rely on the designated single IRB.

What to Do If You Are Unsure

If you are unsure whether a project you are proposing is subject to the NIH policy, work with the NIH program officer.

Exceptions

Types of Research

The mandates do not apply to exempt human subjects research.

Types of Sites

The mandates do not apply to the following types of participating sites in multi-site research:

  • Many Veteran’s Affairs (VA) sites due to strict VA policy. For each study you must check with the VA site to understand whether or not they qualify for exception.
  • Foreign sites (though domestic sites of the same study must be reviewed by a sIRB).
  • Sites involving tribal nations.
  • Sites for which review by the proposed sIRB is prohibited by a federal, tribal, or state law, regulation, or policy.

Note that a study may involve sites that must comply with the policy and other sites that are not required to comply.

Other Exceptions

In October 2020, OHRP issued an exception for research conducted during the Coronavirus Disease (COVID-19) Public Health Emergency declared by the Secretary of HHS. Funding agencies supporting the research must approve the use of this exception. NIH has confirmed that its use of this exception will be rare.

In November 2019, OHRP issued an exception for all HHS-funded research subject to the Common Rule Single IRB requirement and that was approved by an IRB prior to January 21, 2020. This means that at least one IRB has approved any part of the study. This exception does not apply if the study must comply with the NIH multi-site policy.

NIH has established a process by which it will consider other requests for exceptions from its multi-site policy if there is a compelling justification, but it has stated that exceptions will be rarely granted. If you believe that your study should be excepted, work with the NIH program officer to identify how to request an exception.

Non-competing funding renewals of NIH-funded studies are not required to obtain sIRB review as long as an IRB has already reviewed the research, however competing renewals are subject to the NIH sIRB requirement, even if an IRB has already approved the research. This means that researchers subject to these requirements may need to transition a study already approved by multiple IRBs to a sIRB.

The Common Rule mandate allows funding agencies to make exceptions, however, at this time, there is no formal process established for requesting an exception from non-NIH funding agencies. If you believe that your study should be excepted from the Common Rule requirement, you may be able to work with the federal agency’s program officer to identify how to request an exception.

Requirements

Most multi-institutional research has a lead site which directs and coordinates the activities of participating or collaborative sites. Although some research, such as Multiple-PI or Co-PI projects, may not have a clear lead site, the investigators must still accomplish the tasks of the role. Thus, for the purposes of obtaining single IRB review, one site or PI will typically play the lead role and the others are considered to be participating sites. Each role has specific requirements and responsibilities during grant preparation, study set up, and conduct of the study.

Who should I contact if I want more information?

At NIH

General sIRB questions

Email your questions to singleIRBpolicy@mail.nih.gov

Budget, resources, personnel

The Scientific/Research Contact and/or the Financial/Grants Management Contact described in the FOA, RFA or PA to which your grant is directed

Choosing a single IRB

The Scientific/Research contact described in the FOA, RFA, or PA to which your grant is directed

At HSD

For all questions about single IRB, including requesting letters of support, choosing a single IRB, and establishing reliance agreements, contact: the Reliance Team at hsdrely@uw.edu.

Complete list of resources