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Single IRB-of-Record (sIRB) Process

sIRB policy effective dates

Non-exempt, collaborative human subjects research (i.e., studies in addition to clinical trials) will be required to use a single IRB-of-Record for research sponsored by:

NIH - as of January 25, 2018

Other federal agencies following the Common Rule - as of January 2020

The NIH sIRB policy applies to:

  • NIH-sponsored multi-site studies, where the same protocol is used at multiple sites
  • Domestic research only

U-M IRB-of-RECORD PROCESS REFERENCES

HRPP Operations Manual, Part 5, Section IV A

Currently, non-exempt multi-site human subject studies have the option to utilize a single IRB-of-Record (sIRB) to streamline the human subject protections review process and avoid duplicate review by an institutional review board at each site. 

As federal sponsors (e.g., NIH) implement policies requiring the use of an sIRB for multi-site projects, U-M study teams may work more often with an external IRB (either an accredited commercial, "central," or other academic IRB). 

When utilizing an external IRB, an Authorization Agreement (a.ka. "reliance" or "collaborative" agreement) must be established for the project between U-M and the external IRB before the sIRB can conduct its review.  This is the legal contract negotiated and signed by U-M's HRPP Director that cedes IRB oversight authority to the external IRB.   

Blue info iconAn sIRB only handles the IRB review functions centrally.  Related local functions (e.g., ancillary committee review, verification of human subjects protections training fulfillment) remain with the individual participating institutions.  The conduct and reporting of the research remain the study team's responsibility (see Study Team Process below).  

U-M Considerations

U-M Approved External IRBs

U-M has master service agreements with two commercial IRBs:

All U-M units can utilize either of these external IRBs as the sIRB for the review of multi-site projects involving human subjects research.   

In addition, Michigan Medicine has negotiated service agreements for U-M Medical School unit use of:

Master service agreements establish the terms and conditions for the IRB review, including the fees charged (if any) for the initial review, continuing review, and the review of AEs/ORIOs.  When any of the U-M approved external IRBs are utilized as the sIRB, an individual Authorization Agreement may not be needed. 

Blue info iconFor NIH-funded multi-site human subjects research, fees (if any) for the external sIRB review should be budgeted as a direct cost on the proposal/award budget.

Will U-M act as the sIRB?

The U-M IRBs evaluate on a case-by-case basis whether they can effectively serve as the sIRB for a proposed multi-site project.  The main evaluation criteria are:

  • The risk level to the human subjects
  • The number of sites
  • The experience level of the U-M PI/study team
  • The level of administrative resources available to the PI/study team to manage/coordinate the project
  • Whether the U-M PI holds the funding grant

Warning iconBefore you begin a funding application for a multi-site study involving human subjects research contact the applicable U-M IRB to discuss the sIRB options.  To comply with the NIH sIRB policy, when a U-M Principal Investigator (PI) is the awardee of a multi-site grant, U-M plans to cede IRB oversight to an external IRB.

Study Team Process

When ceding to an external IRB (whether commercial or other institutional partner), the U-M study team:

  1. Indicates the selected external IRB in the PAF/CTRF in the eResearch Proposal Management (eRPM) system.
  2. Contacts the external IRB to determine the IRB review fees for incorporation into the proposal budget.  Commercial IRBs post their rates on their websites.  Some academic IRBs may also charge a fee.
  3. Works with the external IRB and the applicable U-M IRB to request an IRB Authorization Agreement.  
    • Warning iconNo one on the study team (or at the U-M IRB) has the authority to negotiate or sign the IRB Authorization Agreement.
  4. Completes a Requesting Review by a Non-UM IRB (a.k.a. "ceding") application in the eResearch Regulatory Management (eRRM) system.   The external IRB usually will have an application process which the study team also must follow.

The Requesting Review by a Non-UM IRB (a.k.a. "ceding") application provides the project information necessary for related local (i.e., U-M) review functions not handled by an external IRB and for the administration of the research at the U-M performance site, such as:

  • Ancillary Committee review (e.g., conflicts of interest, radiation safety, research pharmacy, and clinical billing.)
  • Human subjects protections training fulfillment for U-M personnel via PEERRS or other training equivalent
  • Amendments (e.g., changes impacting ancillary review or decision to cede oversight, project holds/suspensions)
  • AE/ORIOs for related serious adverse events that occur in U-M subjects, unanticipated problems that occur in U-M subjects, and serious and/or continuing non-compliance determinations regarding U-M participation
  • Annual continuing review to track study status

Study teams must receive both the U-M acknowledgement letter and the external IRB approval notice before beginning any research related activities.

FAQs

A single IRB-of-Record (sIRB) is the institution review board that is designated (with negotiated terms via a formal service/authorization agreement) to act as the sole provider to conduct the initial, continuing, and any subsequent review of the research project to ensure human subjects protection regulations will be/are followed.

 

From U-M's perspective, an external IRB is any non-UM institutional review board.  An external IRB can be an accredited commercial, central, other academic, or hospital-based IRB.  When a U-M study team is not utilizing a U-M IRB for a non-exempt, multi-site human subjects research project, it will be using an external IRB.

 

A central IRB is an institutional review board that specializes in reviewing a specific type(s) of human subjects research; or is established to review projects funded by a specific agency.  For example, the NCI Central IRB reviews projects sponsored by the National Cancer Institute.

References and Resources

  • Commercial IRB Guidance Link to IRBMED's Central IRB Information (External IRBs) webpage.  This webpage includes "Working With" guidance documents for each of the commercial IRBs with which U-M or Michigan Medicine has a master agreement.

Questions?

To ask a question, express concerns, or provide suggestions about human subjects research protections at U-M, please send a message to hrppumich@umich.edu.