Can independent IRBs (not affiliated with an institution) participate in SMART IRB?

Yes. Under the Agreement, independent IRBs are referred to as “IRB Organizations.” These organizations may participate in the Agreement to provide IRB review to other Participating Institutions if they meet the applicable eligibility criteria (the second and fourth of the criteria noted in the eligibility criteria question above) and execute a Joinder Agreement. As the term “IRB Organization” is used in the Agreement, it refers to organizations that only provide IRB review (and do not themselves conduct research); therefore, for purposes of the Agreement, an institution that is an IRB Organization may not have, and is not required to have, an FWA.