Harmonization

Strategic, efficient, and cooperative approaches

Inconsistent approaches to implementing single IRB review introduce new burdens and inefficiencies for investigators, collaborating institutions, and IRBs. SMART IRB seeks to harmonize approaches by promoting the alignment of policies and processes and the adoption of common forms, practices, and workflows.

Guidance, Tools & Templates

Recommendations for the Harmonization of Ancillary Reviews

Best practices for defining ancillary reviews and recommendations for centralizing reviews, timing, and allocating responsibilities in an sIRB context. Includes guidance and an implementation checklist.

Conflict of Interest Review Processes

Addresses responsibilities of a Relying Institution and a Reviewing IRB/Reviewing IRB Institution in the COI review process, including FAQs and guidance for determining and managing COI.

Post-Approval Auditing

Identifies best practices and provides tools to support for-cause and not-for-cause audits in an sIRB context. Includes guidance, checklists, and a template report.

Single IRB Continuing Review Process

Recommendations for the roles and responsibilities of Reviewing IRBs, Relying Institutions, Overall PIs, and Relying Site Investigators as they relate to continuing review.

Responsibilities Associated with Review of Study Personnel

Recommendations for ensuring study personnel are appropriately trained and qualified to conduct the research under review.

Reportable Events

Recommendations for investigator-initiated multisite studies, reviewing noncompliance and unanticipated problems, and ensuring prompt reporting.

Institutional Profile

Captures institutional, local, and state requirements that apply to all protocols. Documents information about an institution’s IRB(s), if applicable. Institutions can create and manage their profile in the Reliance System.

Protocol-specific Document

Captures a Relying Institution’s protocol-specific requirements and documents how the IRB reviewed/approved the protocol for the Relying Institution.

Fees and Costing Models under NIH sIRB Policy

Addresses charging fees for single IRB review, as well as structuring and justifying fees and federal regulations on direct/indirect costs.

Institution v. IRB Responsibilities Guidance

Delineates the regulatory purview of a Reviewing IRB and the role and responsibilities for Relying Institutions.

For Review and Comment

Documents are posted as they become available. Your feedback helps ensure these resources reflect and can be used by diverse research institutions and practices.

Recommendations for the Harmonization of Local Considerations

Identifies challenges related to local considerations (“local context”) and recommends harmonization in three key areas to improve the process for providing, collecting, and reviewing local considerations.

Comment period is closed; comments are under review.

Steering Committee

The Harmonization Steering Committee (HSC) is led by SMART IRB and NCATS and is composed of representatives from the following institutions:

Advarra

Association for the Accreditation of Human Research Protection Programs

Boston Children’s Hospital

Food and Drug Administration

GSC Advising

Harvard Catalyst

Johns Hopkins University School of Medicine

Mass General Brigham

National Center for Advancing Translational Sciences

New York University Langone

NIH Intramural Research Program

NIH Office of Science Policy

North Star Review Board

Office of Human Research Protections

University of California, San Diego

University of Cincinnati/StrokeNet

University of Kentucky

University of Texas Health Science Center at San Antonio

US Department of Defense

US Department of Veteran Affairs

Washington University in St. Louis

WCG IRB

How We Work

Since 2017 the HSC has come together to advance harmonization in the implementation of single IRB review.

  1. Inventory Current Practices
    • Find common elements, identify differences, aggregate successful workflows, learn from current practices.
  2. Prioritize Topics
    • Addresses those topics with the greatest need for alignment and strongest likelihood of achieving consensus for best practice across the nations.
  3. Convene Workgroups
    • HSC members and experts across the US are tasked with identifying and developing proposed solutions.
  4. Develop Resources
    • Iterative drafting and review incorporates feedback from the HSC and other SMART IRB teams and external experts.
  5. Test and Review
    • Draft resources are opened for public review and comment and revised accordingly to ensure broad utility.
  6. Disseminate
    • Resources may continue to be revised as needed to meet changing needs and/or regulations.