October 31, 2022
As part of Michigan State University’s (MSU) reaccreditation process, sections of the MSU Human Research Protection Program (HRPP) Manual were updated.
Several new HRPP Manual sections were included in the updates:
1-6, Institutional Review Board Registration (new HRPP Manual section that describes the process for registering IRBs)
2-2-H, Certificate of Confidentiality (new HRPP Manual section that describes the requirements for human research studies that involve a certificate of confidentiality
4-12, Engagement (new HRPP Manual section that describes the criteria related to when an individual “engages” MSU in a human research study)
8-11, External IRB Submissions (new HRPP Manual section that describes the review process when MSU relies upon an External IRB for IRB review and approval)
8-12, MSU as IRB of Record for Other Institutions (new HRPP Manual section that describes the additional processes and procedures when another institution relies on MSU for IRB review and approval)
Included below is a summary of the changes. Many updates did not change current processes (e.g., clarifying language, clarifying processes). Updated HRPP Manual sections are available at: https://hrpp.msu.edu/help/manual/index.html
HRPP Manual 1-3, Use of Institutional Authorization Agreements
Added reference to HRPP Manual 1-5, Use of National Cancer Institute Central Institutional Review Board
Added information about Single IRB requirements
Added information about SMART IRB process
Added information about considerations for reliance
Added information about the review process for Institutional Authorization Agreements
Added information about termination of reliance
HRPP Manual 1-4, Reliance on External Independent (Commercial) Institutional Review Boards
Added information about Single IRB requirements
Removed procedural information about the external IRB submission process and added reference to the new HRPP Manual 8-11, External IRB Submissions
Added requirement that a finalized contract is required before submitting to an independent (commercial) IRB
HRPP Manual 1-5, Use of the National Cancer Institute Central Institutional Review Board
Formatting edits (e.g., abbreviations)
Added a statement that the PI is responsible for the oversight of each NCI CIRB study and for assuring that NCI CIRB requirements and SOPs are followed
Minor updates to NCI CIRB submission process
Updated the prisoner review process so it is consistent with the current NCI CIRB process
Updates to the process for reporting potential local unanticipated problems and serious or continuing noncompliance so it is consistent with the current NCI CIRB SOPs
HRPP Manual 1-6, Institutional Review Board Registration
New HRPP Manual section that describes the process for registering IRBs
HRPP Manual 2-1, Ethical Principles
Updated title for ICH GCP (E6) (R2)
Updated webpage links
Spelled out an acronym
HRPP Manual 2-2, Federal Guidelines and Regulations
Removed listing of HRPP Manual sections and instead referenced overall HRPP Manual Section 2
Grammatical edits
HRPP Manual 2-2-A, U.S. Department of Defense
Updated to incorporate the revised DoD Instruction 3216.02, Protection of Human Subjects and Adherences to Ethical Standards in DoD-Conducted and -Supported Research (effective April 15, 2020)
Added that when a survey crosses DoD Components, additional review is required
Clarified reporting requirements to the DoD
Added information that needs to be included in the consent document for DoD studies
Added restrictions on use of human subjects for testing of chemical or biological agents
Added information about compensation
Clarified that MSU does not accept classified projects
HRPP Manual 2-2-B, U.S. Environmental Protection Agency
Added information to be submitted to the EPA Human Subjects Research Review Official
Added regulatory language in the Subpart K section for clarification
Added clarification that the IRB cannot approve certain research under Subpart L
HRPP Manual 2-2-C-i, U.S. Department of Justice, Bureau of Prisons
Grammatical edits
Clarified that requirements also apply to exempt determinations
Added Bureau of Prisons requirements
HRPP Manual 2-2-C-ii, U.S. Department of Justice: National Institute of Justice Funded Research
Grammatical edits
Updated “NIJ Form Request” to “request”
Removed outdated website link
Added several consent requirements for NIJ funded research
HRPP Manual 2-2-E, U.S. Department of Energy
Incorporated updated DOE requirements
Added requirements from the Contractor Requirements Document (e.g., exemptions, multiple DOE sites, human terrain mapping, social media data, DOE federal and/or contractor employees as subjects, study of human in a systematically modified environment, informal internal review)
Updated requirements related to personally identifiable information
Updated reporting requirements
Clarified that MSU does not accept classified projects
Grammatical edits
Added bulleted lists to help simplify requirements
Removed reference to SABA and updated to ORA LMS
Grammatical edits
Added language from the NIH Single IRB policy and FAQs related to genomic data sharing and Single IRB requirements
HRPP Manual 2-2-G, Revised Common Rule Single IRB Requirement
Grammatical edits
Added reference to HRPP Manual 1-3, Use of Institutional Authorization Agreements and 1-4, Reliance on External Independent (Commercial) Institutional Review Boards
Added limitation to serving as IRB of record when MSU is a subcontractee for a Small Business Innovation Research (SBIR) / Small Business Technology Transfer (STTR) award
HRPP Manual 2-2-H, Certificate of Confidentiality
New HRPP Manual section that describes the requirements for human research studies that involve a certificate of confidentiality
HRPP Manual 2-3, State and Local Guidelines and Regulations
Updated Michigan Compiled Law references
Updated from Michigan Department of Community Health to Michigan Department of Health and Human Services
Updated records related to HIV infection requirements
Updated child abuse or child neglect reporting requirements
HRPP Manual 2-4, International Conference on Harmonization Good Clinical Practice E6 (R2)
Grammatical edit
Clarified evaluation consideration by the IRB and added a reference to relevant HRPP Manual section
Clarified ICH-GCP expectation that the written consent form should be signed and personally dated by the participant or the participants’ legally authorized representative, and by the person who conducted the informed consent discussion
HRPP Manual 3-1, MSU Human Research Protection Program Plan
Grammatical edits and acronym updates
Added explanation that other units not described in the document may be notified and/or assigned as an ancillary reviewer in the MSU IRB online system as appropriate
Updated information about ancillary review process, including examples of when and what units or individuals are notified
Added description of MSU Office of Audit, Risk, and Compliance
Added description of Department and/or College notification or access to IRB submissions
HRPP Manual 3-3, Evaluation and Quality Improvement
Grammatical edits
Added Compliance office PI self-assessment process
Added sharing of information related to feedback surveys
Updated review timelines
Clarified evaluation process for chairs and vice-chairs
Clarified evaluation process for outreach activities
HRPP Manual 4-7, Recordkeeping for Institutional Review Board Records
Grammatical edits
Clarified retention requirements
Revised and added language regarding reliance documentation
HRPP Manual 4-8, Reporting Policy
Grammatical edits
Added citation for Revised Common Rule
Clarified that reporting applies to non-exempt studies
Added timeframe for reporting and review process when review of the report by relying sites is needed
Modified the minimum information needed
Clarified that the report will be sent in the format required by the federal department or agency when applicable
Updated report review process
Updated and clarified who the report will be sent to
Added description of the follow-up report process
HRPP Manual 4-9, Designation as Principal Investigator
Grammatical edits
Updated when an emeritus/retired faculty member may serve as PI
Clarified that librarians can serve as PI
Clarified that a paid appointment is needed to serve as PI, unless approved as a waived PI
Clarified that a PI who is appointed on an academic year basis remains responsible for the duty and non-duty period
Described the process for when a change in PI occurs, including when a PI leaves MSU
Updated the waived PI process, including what materials are needed and who reviews the requests, and clarified that the IO retains final authority on whether an individual can serve as PI on a human research study
New HRPP Manual section that describes the criteria related to when an individual “engages” MSU in a human research study
HRPP Manual 5-2-B, Compliance Office
Grammatical edits
Clarified that protocols undergoing initial review receive compliance reviews
Added that site visit reports also include best practices
Incorporated remote monitoring
Added oversight related to Family Educational Rights and Privacy Act, General Data Protection Regulations, and applications to market a drug or device
Added that the manager of the Compliance office trains/acts as a resource for compliance staff
Added examples of units in which the compliance office manager interacts and communicates
Grammatical edits
Added tasks currently being performed by the IRB Manager (e.g., ancillary reviews, reporting, some of the duties of IRB administrators, roster updates)
Modified language regarding online systems and clarified record retention
Added cross training
Added tasks performed by IRB Administrator II (e.g., expedited FDA studies, studies with special federal funding requirements, requests for 45 CFR 46.118)
Added tasks performed by IRB Administrators III (e.g., rosters)
Added tasks performed by the reliance coordinator (e.g., assisting with implementation of reliance procedures, managing reliance submissions)
HRPP Manual 5-3, IRB Membership
Grammatical edits
Clarified information provided to the IO for IRB member nominations
Updated IRB membership composition to include regulatory language
Clarified role of alternate members
Simplified IRB registration information
Clarified determination of experienced
Added several IRB member responsibilities (AAHRPP, site visits)
HRPP Manual 5-4, Additional Expertise
Grammatical edits
Updated process of contacting an individual who may be asked for additional expertise
Clarified process if information is provided verbally
Grammatical edits
Updated for remote IRB meetings
Clarified quorum requirements
Added information about attendance of guests
Added information about recording
Clarified meeting minutes requirements
Added that the minutes document actions taken by the IRB, including documenting the criteria for approval are met
Added that the minutes document votes for each protocol as numbers for, against, or abstaining
HRPP Manual 5-6, Contact Information
Removed reference to online feedback form
Clarified remote work as needed
Reformatted contact information
HRPP Manual 6-8-B, Special Categories of Research Subjects: Prisoners
Grammatical edits
Revised to indicate that the prisoner representative has the appropriate background and experience to serve in that capacity
Revised to indicate that presence of the prisoner representative at a convened meeting could be in-person or through web conferencing or teleconferencing
Added certification information for collaborative research studies
Added reference to HRPP Manual 2-2-A, U.S. Department of Defense
Added that a majority of the IRB (exclusive of prisoner members) shall have no association with the prison(s) involved, apart from their membership on the IRB
Clarified that the IRB chair assigns the prisoner representative as a primary reviewer
Added the process if a subject becomes temporarily incarcerated
Added headers and made grammatical changes
HRPP Manual 6-8-E, Special Categories of Research Subjects: HIV and AIDS
Added webpage links to related guidance documents
Updated HRPP from IRB
Added confidentiality considerations
HRPP Manual 6-9-C, Community Based Research
Removed reference to online feedback form
Updated references
HRPP Manual 6-9-F, Multiple Research Sites When MSU is the Lead
Updated to focus on when there are multiple research sites and MSU is the lead (responsible for overall conduct of the study)
Added reference to Single IRB requirements
HRPP Manual 7-2, Significant Risk and Nonsignificant Risk Medical Devices
Grammatical edits
Updated document title
Clarified that if the FDA has already made the risk determination, the agency’s determination is final
HRPP Manual 7-7, Humanitarian Use Device
Updated the definition of a humanitarian use device to indicate that it impacts 8,000 individuals a year instead of 4,000
HRPP Manual 7-8-A, Clinical Research Billing Compliance Coverage Analysis
Updated language to indicate that if the study does not meet the criteria of a Medicare qualifying clinical trial and there are billable events that could generate a charge, a Billing Grid for Coverage Analysis is finalized by the Compliance Office and the PI
Added that Compliance staff will review federal qualifying clinical trials to assure compliance with agency requirements for billing
Grammatical edits
Added requirement for PI to confirm they will conduct study in accordance with researcher responsibilities if PI proxy submits the study
Clarified process to document the exempt determination
Updated ancillary review examples
Clarified process when a study does not meet the exempt criteria
Added non-exempt IRB review process of projects likely to have a significant adverse lasting impact on the subjects or likely that a reasonable person would find the interactions offensive
Clarified that limited IRB review exempt categories are not being used at this time
Clarified that more than minimal risk research requires non-exempt IRB review
Clarified parent or guardian permission requirements when research involves children
Clarified consent requirements
Updated circumstances when modifications are required for exempt research
HRPP Manual 8-2, Expedited Review Procedure
Grammatical edits
Added clarification regarding continuing review “when required”
Added clarification language “unless otherwise specified in law or regulation”
Clarified reviewer assignment process
Added reference to HRPP Manual 4-3, Determination of Human Subject Research and 8-1, Exemptions
Added a statement that when using the expedited procedure, reviewers are prohibited from disapproving research
Clarified use of the watermark applied through the MSU IRB online system
Removed reference to the Flexibility Initiative
Updated review timelines
HRPP Manual 8-3, Committee Review Procedure
Grammatical edits
Clarified lead review process
Clarified process when continuing review submissions also include modifications
Added review criteria that require additional documentation at convened meetings (diminished capacity, device risk determinations)
Clarified availability of documents in the MSU IRB online system
Clarified the modifications required to secure “approved” process
Updated information related to remote meetings
Clarified that other determinations may be made by the convened IRB (e.g., exemptions, not human subjects)
Updated review timelines
HRPP Manual 8-4, Request for 45 CFR 46.118 Designation
Grammatical edits
Clarified that a copy of the funding materials is needed
Clarified that either an exempt determination or IRB approval is needed
HRPP Manual 8-6, Modifications to an Approved Research Study
Added regulatory text
Clarified definitions of minor and non-minor changes
Clarified expedited review procedure process for modifications
Removed statement that the MSU IRB online system will not allow submission of an incomplete submission
Removed criteria for considerations related to further verification and replaced with reference to HRPP Manual 8-7, Renewed Approval
HRPP Manual 8-7, Renewed Approval
Grammatical edits
Expanded description of process to determine whether research that doesn’t require continuing review is active or could be closed
Added items that are included in the Click continuing review submission and updated consent finalization process
Added considerations for FDA regulated studies when research studies may require verification from sources
Grammatical edits
Added language regarding risk-based approach and reference to HRPP Manual 3-3, Evaluation and Quality Improvement
Added meeting remotely
Added process of IRB discussion of the site visit if there is no response from the PI
HRPP Manual 8-11, External IRB Submissions
New HRPP Manual section that describes the review process when MSU relies upon an External IRB for IRB review and approval
HRPP Manual 8-12, MSU as IRB of Record for Other Institutions
New HRPP Manual section that describes the additional process and procedures when another institution relies on MSU for IRB review and approval
HRPP Manual 9-1, Unanticipated Problems Involving Risks to Subjects or Others
Grammatical edits
Added a statement regarding conflict of interest
Clarified some of the examples that may be possibly related
Clarified MSU IRB online system process
Updated corrective actions
Added an explanation of communication with investigators and the appeal process
HRPP Manual 9-2, Noncompliance
Grammatical edits
Clarified that noncompliance applies to allegations of IRB noncompliance
Added information about conflict of interest
Updated materials made available to be consistent with the MSU IRB online system
Removed information about investigator’s attending convened IRB meeting and referenced HRPP Manual 5-5, Meetings
Updated corrective actions
Clarified information about misconduct investigations
Added that the appeal process will follow the process described in HRPP Manual 8-3, Committee Review Procedure
HRPP Manual 9-4, Subject Complaints
Grammatical edits
Clarified when complaints need to be reported to the IRB and how the complaints are reported (MSU IRB online system)
HRPP Manual 9-5, Unapproved Change in Protocol
Grammatical edit
Fixed incorrect regulatory citation and added regulatory citation for 2018 Requirements
HRPP Manual 10-1, Conflict of Interest
Grammatical edits
Updated name of Standards of Official Conduct for Senior University Administrators
Updated COI process to incorporate display and ancillary review assignment in the MSU IRB online system
Added section on management of financial conflicts of interest
Added section on education requirements related to conflict of interest
HRPP Manual 11-1-B, Education: IRB Members
Grammatical edits
Incorporated remote training
Removed reference to old learning management system, Saba
Removed reference to subscriptions
Removed reference to training at each meeting and added information about webinars
HRPP Manual 11-1-C, Education: HRPP Staff
Grammatical edits
Removed reference to old learning management system, Saba
Updated orientation checklist to clarify that its used to guide the training
Updated information to provide flexibility regarding meetings
Added information about webinars
Removed reference to subscriptions
Removed sentence regarding forwarding list-servs
HRPP Manual 11-2, Outreach and Engagement
Grammatical edits
Removed reference to online feedback form
Updated hyperlinks
HRPP Manual Guidance 12-4 Consent Form Guidelines
Updated HRPP contact information
Added references to HRPP Manual 6-4-E, Informed Consent Exception for Screening, Recruiting or Determining Eligibility, 6-4-F, Posting of Clinical Trial Consent Form, and 12-9, Guidance on the New Informed Consent Requirement for a Concise and Focuses Presentation of Key Information
HRPP Manual Guidance 12-6 Pregnancy Testing When Research Involves Non-Contrast MRI of the Head
Removed criteria for research to involve children
HRPP Manual Guidance 12-7 Investigational Drug Accountability for Study Drugs
Added references to the PI or study team
HRPP Manual Guidance 12-10 U.S. Department of Defense Requirements – US Air Force
New guidance document that provides information specific to US Air Force requirements when conducting human research
HRPP Manual 12-11 – U.S. Department of Defense Requirements – US Navy
New guidance document that provides information specific to US Navy requirements when conducting human research