If my institution’s FWA specifies that we rely on the IRB of another legally separate institution, do both institutions need to join SMART IRB?

My institution’s FWA specifies that we currently rely on the IRB of another institution, with which we are affiliated but from which we are legally separate. If both institutions want to participate in SMART IRB, do they both need to join?

Yes. Each institution must join SMART IRB (i.e., must be registered with SMART IRB and execute its own Joinder Agreement), regardless of any pre-existing affiliations or reliance arrangements that may be in place between the institutions. This is required so that each legal entity that wishes to participate is identified and so that there is clear and simple documentation that each of them is directly agreeing to the terms of the Agreement. In this case, both institutions may join SMART IRB if they wish; however, the joining of one does not enable the other to participate in any reliance relationships under the SMART IRB Agreement.

Use this decision tree to help you determine how an affiliate of another institution may join and participate in SMART IRB.