Thomas Jefferson University

About IRB Reliance

What is IRB Reliance?

IRB Reliance (or “single IRB review”) is a legal arrangement that allows one IRB to review a study that is occurring at multiple sites or to review a single-site study that involves personnel from multiple institutions. Opportunities for single IRB review are established by entering into formal IRB reliance agreements.

A reliance agreement is signed by two or more institutions that normally would be required to conduct their own IRB review. The reliance agreement allows for one IRB to conduct the review that fulfills federal requirements about human subjects protection. The other institutions ‘rely’ on the Reviewing IRB, thus streamlining the approval process. Even when relying on another IRB, all institutions must comply with applicable state laws and institutional policies.

  • When the Jefferson IRB is being asked to serve as the Reviewing IRB for a multi-center study
  • When Jefferson personnel plan to participate in research covered by another IRB
  • When Jefferson investigators plan to conduct research at non-Jefferson locations and personnel from the non-Jefferson location will be part of the study team, or
  • When non-Jefferson personnel come to Jefferson to participate in our research

Yes, in many cases Jefferson is able to serve as the single IRB. The IRB will evaluate the investigator’s plan to oversee the study and assist the investigator in making arrangements for review of the non-Jefferson sites.

When requesting oversight by an outside IRB, investigators must always start with a permission from their home institution.

Every institution is responsible for research conducted by its own personnel, regardless of where the research occurs. When Jefferson personnel conduct human subjects research, the institution has two options:

  • Review the research through the Jefferson IRB, or
  • Arrange reliance on another qualified IRB

Jefferson personnel may not conduct human subjects research until approval has been obtained through one of the above options and all institutional requirements have been met.

Our current IRB reliance arrangements include:

  • SMART IRB (a network of 500+ academic institutions, hospitals, and institutes)
  • NCI CIRB
  • Advarra
  • WIRB-Copernicus Group
  • NIH Strokenet

Even when an external IRB reviews and oversees a project, there are other institutional requirements that must be addressed. These include requirements for investigator training, conflict of interest review, HIPAA, data security, SKCC PRC, radiation safety, management of grants and contracts, and compliance with state laws. These additional requirements are categorized as “local context” issues that are evaluated at the time the study is proposed.

Investigators using an external IRB remain responsible to update the IRB when key events occur. The IRB must be aware of:

  • Changes to study personnel
  • Annual review report
  • Updates on conflict of interest disclosures
  • Injury to a Jefferson subject
  • Protocol deviations that could impact safety or data integrity

Please request a single review as early as possible, in the planning stages of your project.

  • For new studies, the PI should pursue this step before the grant submission (if applicable) or before submitting the protocol to any IRB for review.
  • When a new site or external collaborator is added to a study that is already approved at Jefferson, please contact the IRB office as soon as the site or collaborator is identified. The Jefferson IRB office can work with the other organization to see if they will rely on our review.

All research proposals are submitted through our electronic IRB Portal system.

In general, any institution located in the United States that is engaged in cooperative (involving more than one institution), federally funded research (where each site will conduct the same protocol), must rely upon approval by a single IRB for that portion of the research that is conducted in the United States. Please see the policy for additional information.

If preparing a grant proposing that Jefferson IRB serve as the reviewing IRB, contact the IRB at least 4 weeks before proposal is due to ensure the IRB is willing to serve. Similarly, if the grant will require that Jefferson rely on an external IRB, contact the IRB In plenty of time to receive a response prior to the grant deadline.

You should submit these documents to the Jefferson IRB for review. The Jefferson IRB will update its tracking system to reflect the new approval period. You are not required to complete the Continuing Review Form (OHR-9).

You should first submit a closure request to the IRB of Record for review and approval according to their submission procedures. Once the IRB of record has closed the study, you should submit a copy of the closure letter to the Jefferson IRB.