Just-in-Time and IRB Review

Some sponsors require IRB approval or pending approval before accepting new grant proposals. Other sponsors, including NIH, NSF, and some private, non-profit organizations will accept new grant proposals with the understanding that the researcher will proceed with the IRB review process upon receiving notification of a score in the fundable range. This is sometimes referred to as the “Just-in-Time” procedure. Review this UW Office of Sponsored Programs (OSP) webpage for more information about IRB and other responsibilities in Just-in-Time situations.

Researchers who are informed that their proposal may be funded because the award was scored in the fundable range, should submit the appropriate application for review. This should be done as soon as possible as it can take 60 days or longer to obtain IRB approval, depending on the study specifics.

• In some cases, the sponsor may request a determination of Delayed Onset Human Research (DOHR) rather than an IRB approval or exempt determination. If the sponsor makes this request, a formal determination from HSD is required.

If your IRB/HSD application is still pending as the Just-In-Time submission date approaches, it is important to know that the pending status does not jeopardize your funding opportunity and there is no cause for alarm. The review process can take some time to complete. Often, informing the funder of the anticipated IRB review date, or letting them know that the application is under review is sufficient.

Contact HSD if you have questions about which application you should submit. Submitting a DOHR or exempt determination request when IRB approval is required is likely to delay receipt of funds. An award will be restricted until final IRB approval has been received and human subjects research cannot begin until final IRB approval or an HSD determination has been received.

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Keywords: Funding and support