Request for ISMMS to Serve (R2S) as the Reviewing IRB
For all NIH grant applications with due dates on or after January 25, 2018, and contract solicitations published on or after January 25, 2018, NIH expects that all sites participating in multi-site studies, which involve non-exempt human subjects research funded by the NIH, will use a single Institutional Review Board (sIRB) to conduct the ethical review required for the protection of human subjects. This policy applies to the domestic sites of NIH-funded multi-site studies where each site will conduct the same protocol involving non-exempt human subjects research. It does not apply to career development, research training or fellowship awards. Click here for more information from the NIH, including the full policy.
ALL REQUESTS FOR THE ISMMS IRB TO SERVE AS THE REVIEWING IRB MUST BE DISCUSSED WITH, AND APPROVED BY, THE PPHS AT LEAST TWO WEEKS IN ADVANCE OF THE GRANT SUBMISSION. LAST MINUTE REQUESTS MAY NOT BE ACCOMODATED AND WILL BE REFERRED TO AN EXTERNAL IRB.
The ISMMS PPHS is willing to serve as the Reviewing IRB for all sites, at the discretion of the PPHS Executive Director, after consideration of the protocol complexity, the role of ISMMS in the research, and the PPHS resources required to facilitate this review. At a minimum, the following criteria must be met:
- In addition to the ISMMS site, there are 5 or fewer external sites.
- The external sites have joined, or are willing to join, the SMART IRB Master Common Reciprocal Institutional Review Board Authorization Agreement (SMART IRB Agreement).
Requests for the ISMMS IRB to serve as the Reviewing IRB for all sites under the NIH sIRB mandate must be made well in advance of your grant submission.
Prior to your grant submission deadline, you must submit a Request to Serve (R2S) inquiry to the IRB inbox (email@example.com) by providing the HRP-230 form. The following information must be clearly included in the request or the form will be sent back for revisions:
- The name of each site requesting to rely on the ISMMS review, and
- whether they are members of the SMART IRB Agreement (membership can be confirmed at https://smartirb.org/participating-institutions/)
- what research activities will be conducted at each site
- The role of the ISMMS site in the research, including
- coordinating center responsibilities,
- research activities that will be conducted, and
- whether Sinai will be the prime awardee of the grant.
If the ISMMS IRB agrees to serve as the Reviewing IRB, PPHS staff will provide budget information and a letter of support from the PPHS Executive Director. Researchers are encouraged to use the Grant Applications, Template Description of SMART IRB in their application.
Once there is an indication from the NIH that a project will be funded, please notify the PPHS as soon as possible for further guidance on the review process. A full IRB application must be completed via Ideate and all sites, including the ISMMS site, must be reviewed separately. The initial submissions must include:
- A title that begins with “R2S” to make it clear that the submission is a request for the ISMMS IRB to serve as the Reviewing IRB
- A Sites tab that lists all sites to which this request applies and an indication that they will rely on the ISMMS IRB
- All participant materials (including consent and assent forms) should be submitted as templates (i.e. no specific site information should be included) for review. These documents, once approved, will then be used by all sites to create their site-specific forms. Please use the following ISMMS consent template as a guide for creating the overall study consent template: HRP-502f MSHS Template Consent for Adult Subjects R2S template (new rule - 1.16.19)
Of note, these projects will be reviewed following the regular ISMMS Board meeting deadlines. Once the overall project is approved, further details for submitting modifications to activate individual sites will be provided by the PPHS.
Please note that most sites will likely still require a submission to their local IRB for the review of their local documents and completion of the forms associated with the SMART agreement. Each site should be in touch with their local institutions to ensure they are aware of the requirements as early as possible.
A modification to the approved overall protocol must be submitted for each site. Sites will be granted approval once all components of the review are complete, and expiration dates will be set to match those of the overall protocol. A member of the Lead Site or Coordinating Center will be required to ensure that all sites have provided:
- a Local Context Survey for Relying Site SMART IRB POCs*
- a SMART IRB Agreement Implementation Checklist*
- Site-specific study material that have been revised to meet all local site requirements
Local study teams are not permitted to submit directly to the ISMMS IRB, and a member of the ISMMS team is required to manage each sites paperwork for completeness prior to submission through Ideate. The paperwork for each individual site activation modification should be submitted via the IRB inbox (firstname.lastname@example.org) for review, prior to submission in Ideate, to avoid an individual sites from delaying the activation of other sites. Once a site is deemed ready for activation, the team will receive notification that the Ideate modification can be submitted.
No individual site may begin the conduct of research locally until a specific modification adding the site has been approved by the ISMMS IRB, and all local requirements and approvals have been fulfilled following the investigator’s home institutions policies and/or guidance for relying on an external IRB.
* These forms will be provided to the Lead Study Team after IRB review is complete and must be provided by each site in addition to their site-specific study materials.