Full-Board and FDA-Regulated studies may be approved by the IRB for up to one year. Continuing review (CR) must be conducted to prevent a protocol approval from expiring. If a protocol expires, the investigator must cease all research activities and may not enroll new subjects in the study. The E-IRB system begins prompting the CR submission around 3 months prior to the expiration date to give investigators ample time to submit and disperse submissions so that the IRB can accommodate the volume.
How the CR approval date works:
So, while a study is approved for up to a year, some of that time must be used to obtain CR approval. The next cycle starts on the date of the convened meeting in which the study was approved or approved pending minor revisions. Therefore, the next annual cycle will not have identical dates to the first cycle. However, this should not be a concern, as the investigator can continue to conduct research while the CR is pending.
Why submitting your CR submission early is best practice?
- The boards meet every three weeks, but submitting early provides time for the IRB to conduct its review at a convened meeting.
- If the investigator makes or IRB requests revisions, adequate time is needed for screening and placing the CR on a full-board meeting agenda.
- Investigators can not submit a modification request (MR) while a CR is pending.
- To reactivate an expired protocol, the investigator must complete the CR and resubmit an initial review application. It is much less work to complete the CR on time.
To save time, download a sample CR form in advance to begin collecting the information that will be requested with the CR.
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