University of Washington
Human Subjects Division
Federalwide Assurances,
IRB Authorization Agreements, and
Individual Investigator Agreements
What is the Federal Policy?
Under the Department of Health and Human Services (DHHS) human subjects
protection regulations (at 45 C.F.R. 46.103), every institution engaged in
human subjects research
funded or conducted by DHHS must obtain an Assurance Of
Compliance approved by the Office for Human Research Protections (OHRP).
Both "awardee" institutions and collaborating "performance site"
institutions must file Assurances.
The "awardee" is responsible for ensuring that all collaborating
institutions engaged in the research hold an OHRP approved Assurance prior
to their initiation of the research.
What does it mean to be "Engaged in Research"?
Institutions are
engaged in research whenever their employees or agents (i) intervene
or interact with living individuals for research purposes; or (ii) obtain,
release, or access individually identifiable private information for
research purposes.
What does this mean for University of Washington Researchers?
University of Washington researchers who are conducting research
with human subjects that is
funded by, or conducted by, the Department of Health and Human
Services, and who are
engaged in research at sites that are not
UW-affiliated
sites, must do the following:
- Ask collaborating institutions to provide a Federal Wide Assurance Number.
If an institution does not have an approved FWA, ask the
institution to apply for an FWA immediately.
- Once the collaborating institution has provided an assurance number,
or when it has applied for the FWA, you should help the collaborating
institution prepare an
IRB
Authorization Agreement.
- Complete Section 3.A-F as the University of Washington researcher
- Obtain the signature of the appropriate official at the
collaborating institution
- Submit the original signed document to the Human Subjects Division. The
Director of the Human Subjects Division (or designee) will sign the
document and return a copy to you.
- Forward a copy of the signed document to the collaborating
institution. (This is the responsibility of the Principal
Investigator.) The Human Subjects Division will file the
original document with the approved Human Subjects Application.
Keep a copy of the agreement in your human subjects application
file.
- If an individual (as opposed to an institution) at an non-UW-affiliated
site is engaged in the research, that individual must submit an
Individual Investigator Agreement.
- Assist the unaffiliated individual investigator by completing the
information under "Specify Research Covered by this Agreement."
- Submit the original document, signed by the unaffiliated individual
investigator, to the Human Subjects Division. After the document
has been signed by the Director of the Human Subjects Division (or
designee), a copy of the document will be returned to you.
- Forward a copy of the signed document to the unaffiliated
individual investigator. The original will be filed with
the approved Human Subjects Application. Keep a copy of the
agreement in your human subjects application file. Individual
unaffiliated investigators are not
required to have a Federalwide Assurance.
How does one apply for an FWA?
The OHRP website provides the
information, and the application form, needed to apply for a
Federalwide Assurance (FWA) including step-by-step instructions for
domestic (U.S.) and international (non-U.S.) institutions. The FWA form is
to be completed and signed by the collaborating institution. The FWA form
does not need a signature by anyone at the University of Washington.
Step-by-step instructions provided by the OHRP web site should be followed
by the institution completing this form. The FWA form, Section 5,
"Designation of Institution Review Boards IRBs," requests that the
institution designate IRB(s) for review of research under their Assurance. The
institution may list the
University of Washington IRB(s), and other IRBs, if and as
appropriate.
Resource Links
-
Assurances and IRB Registration (Applications
for Domestic and International FWA, IRB Registration)
-
"Engaged in research" (definition of)
-
Federal agencies requiring an FWA (List of HHS agencies)
- Institutions
with assurances (OHRP list)
- University of Washington
affiliated sites and cooperative agreements with other
institutions
- University of Washington
IRB Registration (for registration numbers of UW's
IRBs requested in Item 5 of the FWA Form)
-
Guidance, Individual Investigator Agreement (1/31/2005,
change of policy regarding unaffiliated investigator/individual
investigator agreement)
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