IRB Authorization/Reliance Agreements
IRB authorization agreements (also called Reliance Agreements) are arrangements between two or more institutions that allow IRBs to cede review to one another.
When investigators are collaborating on research across multiple institutions that have IRBs, they may request that one IRB become the IRB of Record for some or all institutions engaged in research activities (see FAQ below for information about “engagement”). This is often referred to as ceding review, executing a reliance agreement, or deferring IRB oversight. The IRBs that agree to cede review for the research are called Relying IRBs.
While reliance agreements help investigators avoid duplicate IRB review, they do not lessen investigators’ responsibilities for oversight of the research at all institutions and sites. It is also important to note that institutions, not investigators, make the final determination about whether a reliance agreement can be executed, and which IRB will be the IRB of Record.
As of January 2020, all federally-funded, non-exempt research is required to be reviewed by a single IRB of Record (sIRB).
Agreement Types
Reliance agreements can be in many different forms, but the two main agreements between institutions are IRB Authorization Agreements (IAAs) and Master Reliance Agreements (MRAs). A third type of reliance agreement, Individual Investigator Agreements (IIAs), can be used when requesting that Tufts SBER IRB extend its oversight to individual non-Tufts study team members conducting research with a Tufts investigator, on behalf of Tufts University.
An IAA is an agreement between Tufts University and another institution that holds a Federal Wide Assurance (FWA) with the Office of Human Research Protections (OHRP) of the U.S. Department of Health and Human Services (HHS). Any institution (e.g., university, medical centers, NGOs, community organization, survey research organization) receiving funds from HHS must have a FWA. This agreement type is used to establish the IRB of Record (whether that's Tufts or the other institution). The IAA is signed by the Institutional Officials or designee at each institution.
Master Reliance Agreements are IAAs that may involve multiple projects between FWA-holding institutions. MRAs can be utilized in a variety of different situations. For example, when two institutions are ceding review of multiple protocols to one another, or when multiple institutions enter into a general agreement to cede review of protocols when their investigators collaborate, a Master Reliance Agreement may be used. Master Agreements may be reciprocal in that signatory institutions can act either as the IRB of Record or the Relying IRB. The Tufts SBER IRB is a member of SMART IRB, a master reliance agreement with over 1,000 participating institutions.
An Individual Investigator Agreement (IIA) is an agreement between Tufts University and an individual collaborator who is not affiliated with a FWA-holding institution. Examples of individual investigators include, but are not limited to: community partners, former students working after graduation with their faculty mentor, professionals or experts who do not normally conduct research, and occasionally affiliated investigators whose home IRB has determined that their institution does not need to conduct a review.
The IIA form outlines the responsibilities of the individual investigator for the protection of human subjects. Individual investigators must sign a separate IIA for each study on which they are working. They must also complete Tufts’ human subjects protection training requirements.
Submission Process
Investigators must request reliance agreements prior to conducting human subjects research on new studies, and before adding new research team members or study sites to approved studies. Communication about reliance agreement requests should come from the Tufts research team, not collaborating non-Tufts investigators/teams.
SMART IRB Requests
If your collaborator's institution uses SMART IRB you will use the SMART IRB Online Reliance System. Check the Participating Institutions list to see if your collaborator’s institution is a member of SMART IRB.
Non-SMART IRB Participant Requests
If your collaborator's institution does not use SMART IRB, reliance requests must be submitted to the IRB on the Reliance Agreement Request Form.
If you are requesting that the Tufts SBER IRB serve as the IRB of Record for another institution:
- For new studies: Submit the Reliance Agreement Request Form along with the initial IRB application. Also note the request for reliance in the Protocol.
- For approved studies: Submit the Reliance Agreement Request Form along with a Modification in eIRB.
If you are requesting that the Tufts SBER IRB rely on another IRB for review:
- Submit the Reliance Agreement Request Form along with an External IRB request via eIRB.
For any questions regarding the feasibility of the Tufts SBER IRB serving as the IRB of Record for a multi-site or collaborative study, or for additional assistance, please contact sber@tufts.edu.
Reliance Agreement FAQs
Upon receiving a new request to be the IRB of Record or to rely on another IRB for review, the main factors the Tufts SBER IRB considers are:
• Where the research activities are taking place
• What research activities will be conducted by each institutions’ investigator(s)
• The research methods and procedures
• The study population
• Any risks to participants
• The qualifications and experience of the investigator(s)
• The investigator’s record of conducting research overseen by Tufts SBER IRB
• The external IRB, institution, or individual investigator
• Funding (source and awardee institution)
This depends on the type of submission and the reliance agreement being requested, and whether Tufts SBER IRB will be the IRB of Record or the Relying IRB.
For requests that ask the Tufts SBER IRB to serve as the IRB of Record, the IRB needs to ensure that the other site is engaged in human subjects research and that the protocol accurately reflects the role of each institution involved. The non-Tufts institution also needs to have a Federal Wide Assurance (FWA) in place prior to executing the agreement.
For all reliance agreements where the Tufts SBER IRB will be the IRB of Records and for IIAs, non-Tufts investigators must provide documentation that they have completed required human subjects protection training requirements. Training must meet or be commensurate with the Tufts University human subjects research ethics training standards.
For requests that ask the Tufts SBER IRB to cede review to, or rely on, another IRB (Tufts IRB is the Relying IRB), the IRB needs to review the protocol, consent(s), and any other relevant study documentation being submitted to the IRB of Record. The Tufts SBER IRB also needs to receive documentation of approval from the IRB of Record when it becomes available.
Generally, an institution is engaged in the conduct of human research when investigators from that institution do any of the following:
• Obtain consent to participate
• Interact or intervene with participants as part of the research
• Collect data from participants
• Analyze data that is either directly or indirectly identifiable
• Receive federal funding for human subjects research
For more information regarding how to determine if a site is engaged, see the OHRP Guidance on Engagement of Institutions in Human Subjects Research .
Tufts SBER IRB does not enter into IRB Authorization Agreements or master reliance agreements with international sites. However, Tufts does accept IIAs from international researchers. For example, if you are hiring enumerators to conduct field research, each enumerator will have to sign an IIA.