My institution is part of a group, of affiliated institutions that are legally separate but are all covered under a single FWA (held by one institution with all others listed as ‘components’). Do all institutions need to join SMART IRB individually?
Yes. Each legally separate institution covered under the FWA must join SMART IRB, that is, must register with SMART IRB and execute its own Joinder Agreement. This is required so that each legal entity that wishes to participate is identified and so that there is clear simple documentation that each of them is directly agreeing to the terms of the Agreement.