SINGLE IRB & RELIANCE
Both the Office of Research Protections (OHRP) and the Food and Drug Administration (FDA) permit an IRB to rely on the review of another IRB. The two institutions enter into an agreement referred to as an IRB Reliance Agreement. These agreements are executed between a Reviewing IRB and one or more Relying Institutions and delineate the roles and responsibilities of the involved parties. The NIH, study consortia and some funding agencies have increasingly encouraged the designation of central or single IRBs (sIRB) to serve as the Reviewing IRB for all participating sites in multicenter research studies.
LSUHSC-NO IRB is willing to serve both as the Relying Institution with another IRB as the Lead or as the Lead (Reviewing) IRB with other relying institutions.
Note that exempt studies are not eligible for reliance.
LSUHSC-NO IRB as the Relying IRB (External Reliance)
- Request or requirement by the sponsor or funding agency
- Study is part of an existing network, consortium, or agency which encourages or mandates single IRB review
- Proposed external IRB has already reviewed the study or a similar study
- IRB expertise concerns (e.g., special subject population, untypical research design, sensitive topics)
- Efficiency considerations, especially for collaborative research
- Feedback or request from Institutional Official, IRB staff, IRB Board, etc.
- Conflict of interest concerns (e.g., institutional conflict of interest)
- When required by law
External Reliance Agreements
- LSUHSC-NO IRB has executed master reliance agreements with the following IRBs. Under
these agreements, all LSUHSC-NO investigators may request reliance on these IRBs for
applicable studies.
- National Cancer Institute Central IRB (NCI CIRB)
- Prevention & Early Treatment of Acute Lung Injury Network Central IRB (PETAL cIRB)
- WCG IRB (WIRB)
- Advarra IRB
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The use of commercial IRBs (WCG and Advarra) is allowed under specific conditions. The LSUHSC-NO IRB will make a determination as to whether a protocol is eligible for commercial IRB review, or if it must be submitted for local review by the LSUHSC-NO IRB.
WCG and Advarra will not review research on behalf of LSUHSC-NO IRB without prior notification from the LSUHSC-NO IRB that the study has been cleared for their oversight. A reliance agreement between the LSUHSC-NO IRB and the External (Reviewing) IRB, delineating the responsibilities of the respective institutions, must be approved before the study activities can be undertaken.
- If the Reviewing IRB intends to use either the SMART IRB or IRB Reliance Exchange communication platforms then the request for reliance must also be approved by the LSUHSC-NO IRB. LSUHSC-NO IRB will enter into reliance agreements with other institutions as the Lead IRB on a case-by-case basis.
How to Submit an External Reliance Request
- Log into Kuali.
- Under Protocol Type, select Reliance Request. Complete and submit the resulting form following instructions in the document HRP-2811: Reliance Request which is available on the Kuali Quickguides Webpage.
- The reliance decision will be communicated through the Kuali platform.
- Key considerations:
- The LSUHSC-NO IRB will serve as the Privacy Board for reliance studies. Please use
the Standard LSUHSC-NO HIPAA Authorization Form for the reliance study unless the Reviewing IRB has granted a waiver of HIPAA authorization.
Please submit a completed HIPAA form when requesting reliance.
- Use of the LSUHSC-NO consent form for reliance studies is optional. The consent document(s) approved by the Reviewing IRB may be used as long as the relevant information in the LSUHSC ICF Cover Letter Template is incorporated in the final consent document or attached to the front of the ICF approved by the Reviewing IRB when consenting participants locally. Please ensure the ICF Cover Letter is uploaded and approved by the Reviewing IRB.
- The LSUHSC-NO IRB will serve as the Privacy Board for reliance studies. Please use
the Standard LSUHSC-NO HIPAA Authorization Form for the reliance study unless the Reviewing IRB has granted a waiver of HIPAA authorization.
Please submit a completed HIPAA form when requesting reliance.
Reliance Determination
If the LSUHSC-NO IRB agrees to rely on the proposed reviewing IRB, submit the study and all relevant documents to the Reviewing IRB. Study activities may not begin locally until all of the following conditions have been met:
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- The Reviewing IRB has approved the local PI/site.
- The local PI/site approval letter, along with all locally applicable approved documents, has been uploaded in Kuali.
- LSUHSC-NO IRB has provided acknowledgment of IRB of Record approval and all applicable documents.
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If the LSUHSC-NO IRB does NOT agree to rely on the proposed reviewing IRB, it should be submitted directly to the LSUHSC-NO IRB
for review if researchers still want to undertake the study. Instructions for submitting
protocols in Kuali are available in Kuali Quickguides. Approval and maintenance of the study will follow standard LSUHSC-NO IRB policies
and procedures.
LSUHSC-NO IRB as the Reviewing IRB
When requested to serve as the Reviewing IRB for a multi-center study, the LSUHSC-NO IRB prefers to establish reliance under the SMART IRB or IREx Reliance Agreement platforms using either the SMART IRB or IRB Reliance Exchange (IREx). LSUHSC-NO and many other institutions are already signatories to the SMART IRB Reliance Agreement and its use obviates the need for establishing study-specific reliance agreements with each Relying Institution. In the case where other institutions are not signatories to SMART or IREx, an Interinstitutional Agreement (IAA) may be utilized.
Reliance Options when LSUHSC-NO is the Lead IRB
In general, the LSUHSC-NO PI will first submit their study to the LSUHSC-NO IRB in Kuali. The protocol should be submitted with the proposed risk categorization and information about the proposed relying sites included in the submission. Typically the LSUHSC-NO IRB must grant approval of the protocol before another institution will agree to cede oversight. If sites other than the original proposed relying sites are to be be included later, this can be accomplished with an amendment.
1. Submit:
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- the appropriate initial protocol (either Expedited or Full-Board) through Kuali for LSUHSC-NO IRB review and approval, making sure to answer the questions related to relying sites, or
- a modification to the approved protocol to request addition of one or more relying sites using the Amend function.
2. Once approved in Kuali, a member of the study team will need to log in submit the request for reliance and upload all approved documents.
3. After the request has been submitted, a member of the LSUHSC-NO IRB staff will
confirm all information is correct and that LSUHSC-NO is willing to act as the reviewing
IRB.
4. After the sites agree to rely, a notification will be generated in IREx or SMART
IRB.
5. Each time a change is made to the study or a renewal is approved, the research team is responsible for updating the study accordingly.
- Submit:
- the appropriate initial protocol (either Expedited or Full-Board) through Kuali for IRB review and approval, making sure to answer the questions related to relying sites, or
- a modification to the approved protocol to request addition of one or more relying
sites using the Amend function.
- Send the Single Study IAA and the Local Context Survey form to the PI at the Relying Institution for completion and processing.
- Submit the partially-executed IAA to the IRB Office for final signature by the LSUHSC-NO
IRB Institutional Official (IO). A copy of the fully-executed document will be returned
to researchers to upload in Kuali.
- The reliance determination will be communicated to researchers through the Kuali platform.
Post-Approval Requirements
- Submit all relevant requests and information (e.g., request for research modification, continuing approval, study closure, etc.) to the Reviewing IRB according to its procedures, AND
- Submit applicable information within 30 days to the LSUHSC-NO IRB following the instructions provided in Kuali Quickguides for the specific type of post-approval action.
- Reportable events should be submitted to the Reviewing IRB as well as the LSUHSC-NO IRB.