IRB Authorization Agreement (IAA):
An IRB Authorization Agreement (IAA) is a written agreement between two or more institutions used to document the delegation of IRB review responsibilities. This agreement may also be referred to as a reliance agreement or cede review agreement. Any non-Exempt research study in which Brown University is considered engaged is eligible for an IAA. Any US institutions engaged in a non-Exempt, federally-funded research study is required to comply with the single IRB Mandate (sIRB).
Initiating an IAA at Brown
If we are serving as the IRB of Record
If we are the relying institution
HRPP will internally create an amendment once your study has been approved. This is a more efficient approach as it allows a timely approval of the study while accommodating the procedural demands of coordinating with the relying site. Additionally, relying sites generally want an approved protocol before agreeing to cede review.
Determining the IRB of Record
There are several factors that can influence the decision on which site should maintain ethical oversight. In making this choice, the following factors could be components:
Home Institution of the overall Principal Investigator
Location of Research Activities
Location of Data Storage and Analysis
Brown is only able to be the IRB of record for up to 3 sites total, including Brown. Studies that involve more than 3 sites must either a) rely on one of the other sites or b) contract an independent IRB.
SMART IRB serves as a central, cloud-based location where all sites involved can view the procedures, access study documents and make a determination to cede or provide oversight. Brown University has joined SMART IRB by signing their joinder agreement, which delineates all of the expectations and requirements in entering into a reliance agreement. By using Smart IRB, institutions agree to comply with the established terms, eliminating the need to sign reliance agreements for each study. The SMART IRB request is in conjunction with the actual submission to be reviewed and approved by Brown's HRPP. The initiation of the reliance should be done by the overall PI. Investigators can delegate this role to a member of their research team (e.g., a co-investigator or study coordinator) or other staff by having them request an account.
There is a standard IAA Letter of Agreement that we can use for sites that prefer not to use the SMART IRB portal. This usually occurs with international studies, though there are some domestic sites that prefer not to use Smart IRB. In this situation, we will send our letter to their IAA contact for review and signature from their signatory official.
Advarra is a commercial IRB providing comprehensive ethical oversight for all areas of research. Brown has negotiated a Master Reliance Agreement with Advarra, which eliminates the need for an additional signed contract to rely on Advarra for IRB review. However, a signed cover page is required with all
submissions to indicate to Advarra that Brown is aware and accepting of the pending review. To initiate this process:
- Submit an IAA Application to [email protected] indicating your request to rely on Advarra.
- Upon initial review and acceptance, a cover page will be issued for inclusion with any submission to Advarra.
- Once Advarra has approved the study, an approved protocol and approval letter must be submitted to Brown for processing. A Brown Approval Memo will be issued once the IAA has been fully executed.
There is no institutional funding available to cover costs associated with using a commercial IRB. Advarra's fee schedule is available upon request.
Local context review
IRBs must consider many different regulations as part of their review, including state and local policies. Some external IRBs will require information about the state and local policies that apply to Brown University research. External IRBs request this information in a variety of ways, e.g. worksheets, surveys, questionnaires. If the external IRB requires this information for the study, the Brown HRPP will work with the Brown PI to provide information about local context considerations.
Researcher responsibilities for externally reviewed research
Brown University PIs are responsible for following the policies of the external IRB and knowing the terms and conditions of your IAA. This includes submitting to the reviewing IRB using their forms and processes (or assisting the lead site with that process), following their reporting requirements for unanticipated problems and new information about the study, and complying with the stipulations of the IRB’s approval.
Brown University PIs are also responsible for:
Ensuring that any relevant financial conflicts of interest are disclosed to the reviewing IRB as required;
Obtaining any required ancillary review and approvals (e.g., biosafety, radiation safety, etc.) and providing the results of these reviews to the reviewing IRB if requested;
Making copies of IRB approvals available for inspection.