New Investigator Tips: What Should I Do if I am Bringing a Research Study from My Old Institution to VCU?
Federal regulations for the protection of human subjects contain various areas of flexibility, where institutions are allowed to set policy and procedures for certain aspects of the conduct of human research. While many aspects of conducting human research remain the same between institutions, there are certain areas that can vary between institutions. This means investigators moving from one institution to VCU may encounter new or different policies and procedures for human research.
This “New Investigator Tips” blog post series is intended to help investigators who are joining VCU learn about the nuances of VCU’s application of human subjects protections. See the other posts in this series by visiting the “new investigator tips” tag on our blog.
A common question new-to-VCU investigators have is: “What should I do if I am bringing an active research study from my old institution over to VCU?”
The fact is that IRB review is institution-specific, not project-specific. Just because another institution’s IRB approved a study does not mean that an investigator can continue that research at VCU without obtaining new IRB approval from the VCU IRB. Investigators new to VCU who have ongoing research projects initiated at another institution must arrange to obtain new IRB review for their projects at VCU.
The reason IRB review is institution-specific, rather than project-specific, is because the creation of an IRB involves the institution certifying to the federal government that all its employees and agents will comply with applicable regulations. VCU cannot make this guarantee for employees or agents of other institutions, since VCU does not have relationships with or authority over those individuals. This is why special arrangements must be made for research projects that are multi-site. Each study site must be covered by an IRB’s review, either through each site obtaining its own IRB review, or by each site entering into an agreement to allow a single site’s IRB to review for all involved sites. The latter option requires formal agreements and contracts to ensure that the reviewing IRB is able to have adequate oversight over the project at each involved site.
Exactly how a research project is transferred to and reviewed by the VCU IRB will vary depending on the nature of the project, and the stage the project is in. For example, a project that is in data analysis only will have different review requirements and processes than a research study that is still actively recruiting.
New-to-VCU investigators should plan ahead for how to transfer their research projects from their old institutions to VCU. Schedule a consultation with IRB staff to discuss the best way to obtain VCU IRB approval for your ongoing project. If individuals from your old institution will continue to work on the project, you may wish to consult with IRB Reliance staff, specifically, to discuss whether or not those individuals will continue to be “engaged” in the research, and the best way to ensure all study site locations have IRB oversight. IRB Reliance staff can be reached through the link above, or can be emailed at [email protected].
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