CONTINUING REVIEW / CLOSURE
Federal regulations require an IRB to conduct Continuing Review of research at intervals appropriate to the degree of risk, but not less than once per year. Recent changes to the Common Rule, however, allow for exceptions to this general rule. Specifically, Continuing Review of research is no longer required for:
- Minimal risk research reviewed and approved by the Expedited procedure; and
- Greater than minimal risk research (reviewed and approved by the Full Board) that has progressed to the point that it involves only one or both of the following:
- data analysis, including analysis of identifiable private information or identifiable biospecimens, or
- accessing follow-up clinical data from procedures that subjects would undergo as part of clinical care.
For these and also Exempt studies, however, LSUHSC IRB policy requires Study Status Updates every three years until Closure of the study.
Continuing Review is required until the Principal Investigator has completed all research-related interactions and interventions with participants or when the collection and analysis of identifiable private information, as described in the IRB-approved research protocol, has been completed. This review allows the IRB to monitor the progress of the study and ensures that the study continues to meet the requirements for approval. The continuing review process begins when the Principal Investigator submits the Continuing Review information to the IRB Office as described below.
How to Submit
Continuing Reviews are submitted using the Renewal form in the Kuali Research (KR) electronic submission platform. Links to instructional material are provided below under Resources.
When to Submit
To ensure adequate time for the IRB to review a Renewal application, the Principal Investigator is required to submit the Renewal form no later than 30 days (for studies approved by the Full Board) or 15 days (for studies approved by the Expedited procedure) before the Continuing Review Date, the date which signifies the end of study approval.
To prompt submission of a Renewal application in a timely manner, KR automatically sends Continuing Review reminder notices for active studies at 45, 30, and 15 days prior to the end of the study approval period (i.e., Continuing Review Date). All study team members will receive these notices and the team should initiate a Renewal or Closure Request (see below) application as applicable.
Investigators are strongly encouraged to devise an additional system for ensuring the submission of continuing reviews. Suggestions include setting reminder notices in electronic calendars and frequent meetings with study staff to review expiration dates.
For ongoing studies that are, or have become, exempt from Continuing Review, investigators must submit a Status Update every three years. Status Updates are submitted using the Renewal form in KR. Links to instructional material are provided below under Resources.
When to Close a Study
If all research-related interventions or interactions with participants have been completed and collection and analysis of identifiable private data (as described in the IRB-approved protocol) are finished, the study should be closed with the IRB.
How to Close a Study
Closure Requests are submitted in KR. Links to instructional material are provided below under Resources.
The IRB may request additional information to ensure that the study is in good standing and ready to be closed. Once the submission is approved, the study is considered Closed by the IRB and will be archived. If an investigator wishes to resume the research after the study has been closed or if the study is closed in error, a new study will have to be submitted.
Once a study has been closed, investigators may keep the data collected (including identifiable, private data) if consistent with the IRB-approved protocol. Investigators should continue to honor any confidentiality protections of the data. Investigators should also honor any other commitments that were agreed upon as part of the approved research. For example, providing information about the study results to research participants or honoring reimbursement commitments for participation.
Lapse in IRB Approval
If IRB Approval Lapses
If IRB approval lapses (i.e., the Renewal application has not been approved by the Continuing Review Date), the investigator must stop all research activities related to that study, except when the investigator judges it to be in the best interest of current participants to continue, in which case s/he must notify the IRB Office promptly. If the Board determines it is not in the best interest of current participants to continue, all research activities must stop. This includes intervening/interacting with subjects and/or obtaining or analyzing identifiable private information about the participant(s).
How to Resume the Study
The investigator may resume research activity once a Renewal application has been reviewed AND approved by the IRB. Continuing Review approval must be obtained before the study Expiration Date, which is 60 days after the Continuing Review Date.
Study Expiration and Administrative Closure
A lapsed study that has not obtained Continuing Review approval by the Expiration Date will be administratively and permanently closed. As a reminder, KR will automatically send study Expiration notices at one (1) day after the Continuing Review Date and at 45, 30, and 15 days prior to the Expiration Date. Please be mindful of these notifications and take appropriate actions to prevent permanent closure of the study. A study that is permanently closed cannot be re-activated. Continuation of research that is administratively closed will require submission, review and approval of a completely new protocol in KR.
Accessing Kuali Research
- HRP-2827: Renewal on the Kuali Quickguides Webpage
- HRP-2828: Closure Request on the Kuali Quickguides Webpage