Federal regulations and OHRP guidance are quite clear about the requirements for continuing review: all studies need to be reviewed for approval at least annually. Investigators are responsible for tracking each study's approval period. Using the 'My Studies' tab in PRISM to confirm your study's expiration date. The expiration date is also noted on the most recent approval notice and on each page of each approved consent form.
- It is important to note that study approval, not merely the consent form, expires on the last day stamped on the consent from.
- Once approval expires, no further recruitment can occur.
- All research must stop unless doing so would place subjects at risk.
- The regulations do not permit extensions or exceptions beyond the twelve month period.
Continuing review reminder notices
- Continuing review notices are e-mailed to the principal investigator 60 days in advance of expiration.
- Reminders are again e-mailed 30 days later.
- Final notices are e-mailed shortly after expiration, and the study is considered terminated 2 weeks later if no continuing review application is received.
In preparing your application
- Carefully review your study's progress.
- Consider if information arising during the implementation of the study, information from the literature, or new standards of care require a reevaluation of the study risks and benefits or changes to procedures or consent forms.
- Submit a completed Application for Continuing Review of Research (ACAR), via PRISM.
- Check this website for new requirements in advance of submission. The revised Common Rule requires specific changes to the Consent Form. Please review our updated CF Template and revised Common Rule guidance.
Submission and Review
- For studies first approved at the Full Board, continuing review requires consideration at the Full Board unless subject enrollment has not commenced, the study is completed except for data analysis, or the Full Board has agreed that the study no longer requires Full Board review.
- For those studies requiring Full Board review, please allow sufficient time in advance of the expiration date of your study and submit material a minimum of 2 weeks prior to a scheduled meeting. This allows for scheduling and preparing the material for review by IRB members.
- Studies approved using an expedited process are reviewed at continuation using the expedited procedure. Time your submission accordingly.
Annual Progress Report (APR)
An Annual Progress Report is required for minimal risk studies approved after January 21, 2019. These studies have an approval date but no expiration date. A short summary of activities is submitted annually via PRISM and is a condensed version of the ACAR discussed above.