Reliance agreements and the single IRB mandate: what the reviewing IRB does, what the relying institution still requires
Analyzes the regulatory architecture of reliance agreements at portfolio scale, building tracking systems for retained institutional obligations and workflows that accommodate structural variation across studies.
The most dangerous assumption in modern IRB management
There is an assumption that I encounter at almost every site I advise, and it is this: once the central IRB approves the study, the regulatory work is done. The reliance agreement delegates everything to the reviewing IRB. The site simply waits for the approval letter, files it, and proceeds.
This assumption is wrong. And the consequences of acting on it range from delayed site activation to regulatory findings during monitoring visits that could have been entirely avoided.
A reliance agreement does not transfer all oversight to the reviewing IRB. It transfers ethical review authority -- the power to approve, require modifications, or disapprove the research protocol and its associated documents. But the relying institution retains a set of obligations that no central IRB can discharge on its behalf. These retained obligations are institution-specific, study-specific, and, in many cases, poorly documented in the reliance agreement itself. They include ancillary committee reviews (pharmacy, radiation safety, biosafety), local context assessments, financial conflict of interest determinations, facility credentialing, and institutional signatory requirements.
The RC who manages 18 studies across three different central IRBs, each operating under different reliance agreement structures with different retained obligation profiles, faces a tracking challenge that is qualitatively different from managing submissions to a single IRB. This lesson addresses that challenge -- not at the conceptual level, but at the level of system design.
What you will learn
By the end of this lesson, you will be able to: