If one institution provides IRB review for several affiliated but legally separate institutions do all institutions need to join individually?

My institution provides IRB review for several affiliated but legally separate institutions (distinct legal corporations). If all of our institutions want to participate in SMART IRB, do we all 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, all institutions may join SMART IRB if they wish; however, the joining of one does not enable the others 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.