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109.6b Organization Policy on Continuing Review of Approved Research

 August 2013

The Organization requires JHM IRB continuing review of approved human subjects research.  The JHM IRBs are authorized to conduct the process in accord with federal regulations using either (1) an expedited review process (see Policy No. 110.1) or (2) a convened review process (see Policy No. 111.1).  Principal Investigators (PIs) are responsible for submitting continuing review applications containing sufficient information to allow the IRBs to determine whether the research may continue, should be modified, or should be terminated. 

In determining how often continuing review should occur, the JHM IRBs will consider the risks posed by the study intervention, what type of data and safety monitoring is provided for, and any other factors which affect the health and welfare of the study participants. IRBs may approve research for a defined time period of not more than one year minus one day, or for a limited number of subjects.  Thus, the IRB will calculate the approval period for research per the following example:

A protocol is reviewed and approved (or approved with administrative changes) on February 1, 2013.  Since the protocol will expire on February 1, 2014, the IRB must complete its continuing review no later than that date minus one day—January 31, 2014.  This applies to studies receiving either convened or expedited review.* Once the period of approval is established, it will be communicated to the investigator in writing in the approval notification. 

As part of the continuing review process, information submitted by the investigator may involve discrepancies or may not be able to be verified by the IRB.  In such cases, the IRB may request verification of information from sources other than the investigators.  The IRB may contact the Department or Division Chair for assistance in obtaining such verification.  For projects that involve ICTR-CRU funding, the IRB may contact the ICTR-CRU for assistance in obtaining such verification. For projects that involve medical procedures, the IRB may contact institutional officials at the JHM Hospitals for verification of information. Verification may be required if the IRB finds inconsistency with data submitted from previous years, determines there is a history of serious non-compliance with continuing review requirements, or  believes material changes have occurred since the last IRB approval of a protocol.  The IRB may also request verification for any other cause or may request verification without cause.

Approval to conduct the research automatically expires if a continuing review application is not submitted for IRB review prior to the expiration date.  In limited circumstances, the IRBs may permit continued study activity where the PI has submitted the continuing review application prior to the expiration date, but the IRB’s approval for continuation does not occur before that date (see Policy No. 109.7).

The IRBs have the authority to monitor the data produced by the study, the consent process, and the research itself through either the compliance monitoring program of the OHSR or independent consultants. 

If the IRBs determine that significant new findings regarding the research might affect participants’ willingness to continue taking part in the research, the IRBs have the authority to require provision of such information to participants.  This may include requiring re-consent of the subjects.

 

(* Renewal of exempt research and non human subjects research submitted in the eIRB system shall occur at three-year intervals.)


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