Reliance on an IRB other than the MHRI IRB & IRB Authorization Agreements
When collaborating with other institutions, sometimes a single or joint IRB review may be preferred over separate reviews at each institution. The institution will enter into an IRB authorization agreement with other institutions, a Central IRB, and/or Independent IRB with whom the institution and employees collaborate on single or multiple projects.
When collaborating with other institutions, an IRB authorization agreement must is drafted. The IRB Authorization Agreement establishes a written understanding defining the scope of responsibility of the respective institutions for the research study in which both institutions are involved in the review, approval and continuing oversight performed by the approving institutions IRB and the requirements of the HHS regulations for the protection of human subjects at 45CFR46 as well as the requirements of the federal, state and local laws. For research involving FDA regulated products, the approving institution’s IRB must be in compliance with requirements defined in 21 CFR Pats 50,56, 312 and 812.
MedStar Health will comply with the determinations of the reviewing IRB, follow reporting and conflict of interest disclosure requirements as specified in the authorization agreement, conduct monitoring, identify an appropriate contact person, ensure researchers have appropriate qualifications and provide local context information (and any updates) to the reviewing IRB.
When this institution provides IRB review for other institutions, this HRPP will follow established policies and procedures to ensure that the composition of the IRB is appropriate to review the research and will comply with applicable laws of the relying site. This includes ensuring the IRB is appropriately constituted, members are appropriately qualified, members will not participate in the review of research in which they have a conflict of interest; and that the IRB separates business functions from ethical review.
All requests for reliance on a commercial or single IRB need to be processed through the eIRB system. You can find instructions for that process here: Submitting a Study to be Reviewed by an External IRB
Please contact the ORI at [email protected] if you wish to rely on a commercial or single IRB for which an institutional profile has not yet been established.
Guidance and Forms
- General Guidance for External or Single IRB (sIRB) Review at MedStar Health
- External Team Member List Template
- External Site Questionnaire
Frequently Asked Questions
I am using an external IRB (commercial, independent, or other institution), do I need to submit my proposal through the eIRB system if I am not using the MHRI or GU IRB Committees to conduct the review?
Yes, you need to submit through the eIRB system. An outline of the process can be found here: Submitting a Study to be Reviewed by an External IRB.
What is the purpose of submitting in the new eIRB system if I am not using the MHRI or GU IRB Committees to conduct the review?
The submission of the information in the eIRB system provides a mechanism for MHRI to conduct the administrative review necessary to meet institutional responsibilities which are required regardless of IRB utilized. No IRB review is performed, however much of the same information is needed, for example, to determine if a conflict exists or if the investigative site and investigators have the required training, expertise or resources to conduct the research. The Human Subject Protections Regulations, as well as other federal regulations such as those on COI and Human Subject Protection training, outline responsibilities and requirements for Institutions as well as IRBs. You may find the following Clinical Trials Transformation Initiative Considerations documents helpful in understanding the differences between IRB and Institutional responsibilities: Considerations to Support Communication Between Institutions and Outside IRBs.
What information needs to be uploaded to the eIRB system?
Each project is different and the smart forms in the eIRB system will guide you to ensure the correct information is included. At a minimum, study-related documents such as the proposed protocol and consent (if applicable) will need to be provided.
I have a study that was previously authorized to be reviewed by an external IRB and was either not in InfoEd or was not migrated to the new eIRB system from InfoEd. Will it be migrated?
Generally no, studies that were reviewed by an external IRB and remain ongoing without modification to study personnel or an unanticipated problem to subjects or others will not be migrated to the new eIRB system. However, studies may need to be entered into the system by an investigative site at the time of modification. See below for more details.
I have a study that was previously authorized to be reviewed by an external IRB and was either not previously in an electronic IRB system at MHRI or was not migrated to the new eIRB system from InfoEd. I am now modifying or updating the study to include reportable new information, changes in study personnel or an additional site and the sponsor is requiring approval for the change from MHRI as an institution, even though the MHRI IRB is not the reviewing IRB. Do I need to submit this information to MHRI and if so what system do I use?
Yes, when adding study personnel this information needs to be submitted to the institution so that MHRI can ensure we are meeting institutional responsibilities. Since this protocol information was not previously collected in an electronic system at MHRI or was not migrated from InfoEd to the new eIRB system, there is no protocol record to "update". Instead, the project should be submitted as a new submission in the eIRB system, following the process for submitting a study for review by an external IRB. Please be sure to append a comment that the study was previously authorized to utilize an external IRB and that the submission being made now is to update protocol records with new information. A power point presentation outlining the process is available at the following link: Submitting a Study to be Reviewed by an External IRB. The ORI office will then review the request and notify you when the review is complete.