University of Colorado Denver Colorado Multiple Institutional Review Board Standard Operating Procedures SOP - WIRB Protocols Version #: 001 Effective Date: 11/1/2008 Supersedes Document: This Policy Pertains to: WIRB Protocols Responsibility for executing this policy: Director, WIRB Coordinator Last Reviewed on: 10/24/2008 Result: Approval Authority: Director Approved by: Alison Lakin, Director, COMIRB Date: 11/1/2008 1. PURPOSE To describe the procedures/communications required when WIRB (Western IRB) serves as the primary IRB of record. 2. POLICY WIRB provides Full Board Review for Particular industry sponsored protocols. As of July 19, 2006, investigators from UCHSC and its affiliates who have already opted-in to this system will have their industry-sponsored protocols be reviewed by WIRB (Western IRB), an independent central IRB. This applies to industry-sponsored protocols only. Investigator-initiated, grant-supported or expedited/exempt protocols may not be reviewed by WIRB and must be reviewed by COMIRB, as indicated on the WIRB Eligibility Form (CF-051). Those studies that were reviewed by WIRB during the shutdown in 2000, will remain with WIRB until they close, using the mechanism that was put in place at that time (refer to 5.1.5 through 3.1.7 for applicable procedures), unless they receive administrative approval to return back to COMIRB. 3. SPECIFIC POLICIES 3.1 a) In order to have a protocol reviewed by WIRB, the PI must go through the ‘opt-in’ procedure, to be done during a specified time frame. b) Administrative approval to ‘opt-out’ of WIRB and return to COMIRB for non-industry sponsored protocol reviews will be done on an annual basis during a specified time frame. 3.2 The PI will submit 2 copies of the initial review packet to COMIRB, which will include both COMIRB and WIRB required documents. If the study sites include DHHA or UCH, the clearance letters should be included in the packet (all required documents listed on the WIRB Initial Review Cover Letter, CF-050). WIRB coordinator will do in-house review of the packets for eligibility. HIPAA Authorization forms will also be reviewed/noted by WIRB coordinator. Packets that do not meet eligibility requirements will be returned to the PI and will need to be submitted to COMIRB for full board review. If the protocol does meet eligibility criteria, one packet will be kept in a yellow file folder at COMIRB (per CP-017), and the other packet will be sent to WIRB. 3.3 After approval, WIRB will send both the PI and COMIRB the Approval letter, approved consent form, and any other approved documents. COMIRB will send the PI a hard copy of the feedback letter, noting the HIPAA Authorization form(s) and any suggested changes. If the DHHA or UCH WIRB Protocols CP-015, Effective 11-1-2008 1 of 2 University of Colorado Denver Colorado Multiple Institutional Review Board Standard Operating Procedures are study sites, COMIRB will provide the approved consent form and the HIPAA Authorization form to the regulatory personnel. 3.4 For all updates or changes to a protocol (including amendments, advertisements, SAE’s, etc.), the PI/study coordinator will send the documents directly to WIRB. Personnel and site changes should be submitted to both WIRB and COMIRB. All approval letters/acknowledgements will be sent by WIRB (including approved annual continuing reviews), to both the PI and to COMIRB. 3.5 PI will send their closure request to both WIRB and COMIRB. WIRB will send an acknowledgement to both the PI and COMIRB. 3.6 WIRB may contact COMIRB for questions requiring contact with a PI/study coordinator regarding a protocol. When appropriate, COMIRB acts as liaison between the PI/study coordinator and WIRB. 3.7 WIRB will notify the COMIRB of all reportable actions regarding the protocol and COMIRB will be the institution responsible for investigating and reporting to the appropriate federal and institutional entities (see SOP IR-075 4. RESPONSIBILITY The COMIRB Director and WIRB Coordinator are responsible for review and implementation of the SOP. The COMIRB Director is responsible for day-to-day oversight of this SOP. 5. APPLICABLE REGULATIONS AND GUIDELINES 45 CFR 46. 103, 108, 109 21 CFR 56. 103, 108, 109 OHRP Guidance: General Guidance on the Use of Another Institution’s IRB, 1991 Up-date Suitability of a Designated Institutional Review Board (IRB), 1997 Knowledge of Local Research Context, 1998 updated 2000 6. ATTACHMENTS CF-050 WIRB Initial Review Cover Letter CF-051 WIRB Eligibility Checklist CP-017 Study File Folder Organization Suspensions and Terminations: Reporting to Federal Authorities 7. PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY Who Director WIRB Coordinator Task Oversees Opt-in/Opt-out process In-house review of WIRB protocol packet. Determines eligibility of WIRB protocol. Reviews and notes HIPAA Authorization forms. Sends protocol packet to WIRB. Upkeep of WIRB files at COMIRB throughout the life of the protocol. Acts as liaison between PI/study coordinator and WIRB when necessary. WIRB Protocols CP-015, Effective 11-1-2008 2 of 2