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Continuing review Changes under the revised Common Rule (2018) Developed by: U-MIC University of Michigan IRB Collaborative

Continuing review changes Revised Common Rule scheduled to take effect January 19, 2018 continuing review no longer required for most studies that qualify for expedited review no more than minimal risk must meet federal criteria for an expedited review category studies that have completed subject intervention/interaction and in which activity is limited to final analysis of identifiable data and biospecimens accessing follow-up clinical data Developed by: U-MIC

Continuing review changes Existing studies U-M IRBs will evaluate need for continuing review at next amendment/scheduled continuing review for expedited studies that were approved prior to January 19, 2018 full-board studies in which subject intervention/interaction is complete Developed by: U-MIC

New studies Continuing review changes approved via expedited review on or after January 19, 2018 U-M IRB’s expedited reviewer will determine need for continuing review set "Continuing Review (CR) / No Continuing Review (No CR)" flag Most expedited studies will not require continuing review. When requiring continuing review of studies that meet regulatory No CR criteria, IRB should state reasons for requiring continuing review document reasons FDA-regulated or sponsor requires continuing review involves additional regulatory oversight, e.g., conflict of interest (COI) management research conducted internationally / at non-UM sites amendment or incident report reveals findings that require additional oversight investigator has had previous serious noncompliance or a pattern of non-serious noncompliance Developed by: U-MIC

Reminder e-mail Continuing review changes Even when continuing review is not required, study team must submit amendments for study changes report adverse events/ORIOs terminate study once it ends when personal identifiers are removed from data/biospecimens and all codes and keys are destroyed In absence of SCR process automated annual email reminder issued prior to anniversary approval date Developed by: U-MIC

Continuing review changes U-M IRBs may re-evaluate CR/No CR decision depending on type of changes proposed in amendment such as a protocol change that increases risk as outcome of review of adverse events/ORIOs Developed by: U-MIC

Continuing review changes under the revised Common Rule (2018) Developed by: U-MIC

Thank you. Brian Seabolt IRBMED Developed by: U-MIC