Working with Other IRBs

The OHSU IRB allows the use of a single or central IRB. This meets the requirements under the National Institutes of Health (NIH) policy on the use of a single IRB (sIRB) for multi-site research and the Cooperative Research (§45 CFR Part 46.114(b)) requirements of the revised Common Rule (effective January 20th, 2020). Until that date, the only studies required to utilize a central IRB are studies subject to the NIH sIRB policy.

The OHSU IRB typically will NOT agree to be reviewing IRB (i.e., the single or central IRB) for multi-site studies. There are other IRBs setup to specifically function as a reviewing IRB for multi-site studies. OHSU study teams should plan to use an external IRB as the reviewing IRB, even when OHSU is the lead site or the OHSU PI is the overall lead PI of the study.

Note: Even if IRB review is waived to another IRB, OHSU will NOT waive Institutional Biosafety Committee (IBC) review.

See the working with other IRBs section of the IRB FAQs page for further information.

Waiving oversight to an external IRB

To waive oversight to an external IRB, there must be an agreement between the two institutions. The agreement can either be an IRB Authorization Agreement (IAA) or a Memorandum of Understanding (MOU). The SMART IRB agreement is a commonly used MOU.

Submit your study in the OHSU eIRB system so the OHSU IRB can ensure institutional requirements are met:

  • Agree to rely on the external IRB
  • OHSU required consent language
  • Training requirements
  • Ancillary reviews
  • Process any agreements that need signatures

Before the study may start both the external IRB and the OHSU IRB office must sign off on the study.

Applicability of the NIH sIRB policy

The NIH sIRB policy applies to studies that meet these criteria:

  • Studies funded by competing NIH grants (new, renewal, revision, or resubmission), contracts, or cooperative agreements submitted on or after 1/25/2018.
  • Multi-site studies with domestic (US) sites conducting the identical protocol.

For questions about whether this policy applies to your study, contact your NIH program officer, your OPAM departmental contact, or see the NIH single IRB policy for multi-site research website.


For human research conducted at both the VA Portland Health Care System (VAPORHCS) and OHSU,  the PVAMC IRB utilizes Panel 3 of the OHSU IRB for regulatory review and oversight. Researchers proposing human subjects studies that will be conducted at both OHSU and VAPORHCS (i.e., "joint studies") should submit their study in the OHSU eIRB system. When creating the new study, please begin the short title with the phrase "VAPORHCS/OHSU J".

When completing the electronic submission form in the OHSU eIRB system, question #2 on the Ancillary Reviews and Notifications page should be answered to indicate the VA components that will be included in the VA portion of the proposed research. Other VA specific questions will also appear on other pages of the electronic submission form, and should be answered as applicable. For full details of the process, see Preparing a Combined VA-OHSU IRB Submission. Please contact OHSU Research Integrity and the PVAMC IRB with questions about joint studies.