Step 3: Application Review Process
Once submitted, your research proposal will be reviewed by IRB administrators and, if needed later in the process, board members and expert consultants. To avoid delays, researchers are expected to provide a fully complete application where all required documents are attached and the details remain consistent across all materials.
What Happens After You Submit?
Once you submit your application, the IRB staff performs an initial check called “pre-review.” Pre-review is only done after the application is submitted to the IRB office, not before. During this step, IRB staff will:
- Assess the application and supporting documents for consistency across materials and that nothing is missing.
- Verify that the required human subjects research training is complete and valid for all NC State University members of the research team and any individual investigators. Please note: Research team members may be required to complete other training due to a federal funder, research sponsor, or research site. The NC State IRB only checks for the IRB-required training. It is the research team’s responsibility to check and ensure that they are compliant with all training requirements.
- Review applicable research regulations, guidelines and risks to decide what kind and level of IRB review the study needs (e.g., Is the study minimal risk or more than minimal risk? Is the study eligible for an exemption determination or does it require a higher level of review?)
Please Note: It is completely normal for the IRB to return an application for revisions once or twice at this stafe. Researchers may be asked to provide more detail, upload missing materials, or align documents with regulatory requirements or recent changes. Prolonged revision cycles are usually a result of researchers ignoring or not fully incorporating the IRB’s provided feedback. Reviewing and thoroughly addressing all IRB feedback before resubmitting a protocol application is expected if you wish for your application to move forward.
Final Review
Protocol applications move to final review once the pre-review process is complete and the application has been submitted to the IRB office in a condition that it is ready for final review. The final review process and associated timeline greatly depend on the level of IRB review required, the risk involved in the study, and what policies, regulations, and standards the study is subject to.
Once the application is ready for final review, IRB staff will either:
- Conduct the final review and approval for studies that are eligible for an exemption determination, including a limited review if necessary. This is a quicker process than the other more stringent levels of IRB review because exempt studies are low risk in nature but an exemption determination is not always immediately upon submission for final review. The actual IRB approval timeline depends on when the application is ready and submitted for final review (not the date of initial submission), the number of other protocols waiting in line to be reviewed when the application is resubmitted, and IRB staff availability when the protocol is ready for final review. Please note: A study that receives an exemption determination doesn’t mean that a research team skips the IRB review process; it just means that the study is exempt from some of the stricter U.S. regulations for human subjects research. Even if a study is exempt, all policies, regulations, and standards that apply to the study must be followed – especially if it is stricter than what the IRB requires.
- Refer the application with all supporting documents for final review by one or two convened full board member with relevant research methods and participant population(s) expertise for studies that are minimal risk and eligible for review at the expedited (mid-level) review level. The board member(s) have 15 business days, excluding University closures, to evaluate the protocol and return the application to the IRB office with a determination to approve the study with no changes, approve with minor changes (and specify what those changes are), or to send the application to the convened full board for review.
- Refer the application and all supporting documentation to the entire convened full board membership for final review. These are studies that are more than minimal risk, are minimal risk but cannot fit into any of the federally designated IRB review categories at the exempt or expedited level, are assessing the safety or efficacy of a test article” as defined by 21 CFR Part 50.3 and other federal regulations, and other types of studies as needed. All convened full board studies are reviewed by the full committee. This type of final review takes the longest because board meetings only occur on set dates and members are sent and review all application materials in advance of the meeting. At a meeting, the members will discuss the application as a group, sometimes invite the main researcher (and their faculty member if this is a student protocol) into the meeting to answer questions about the application, and vote whether or not to approve an application with no changes, approve with stipulations that the researcher needs to address, defer the application for a future meeting so that application materials can be revised or issues identified by the convened full board are addressed, or to disapprove a study (this decision is final).
Addressing Final Review Feedback
After the final review, the IRB will either approve your study or, more commonly, return it with a list of required changes (often called “stipulations”). This is where many researchers get tripped up and experience delays in their IRB approval process.
To get your study approved as quickly as possible, avoid these common mistakes:
- Not explaining and documenting your changes: When resubmitting an application that received approval with stipulations, clearly communicate what was changed and where the IRB can find those changes to verify them.
- Only addressing some of the approval stipulations: It is easy to miss a comment but skipping requested changes guarantees your application will be sent back again. Read the stipulations carefully and treat them as a mandatory revision checklist.
- No justification provided for unaddressed stipulations: If you decline to make changes that were stipulations of approval because you disagreed with them, you can respectfully provide your reasoning. Ignoring stipulations without providing a rationale will delay your approval; even with a rationale, the application package with the researcher’s justification for not addressing the stipulation(s) must be reviewed by the stipulating party before any final determination can be made.
- Research description, procedures, and supporting documents inconsistencies: If the convened full board asks you to change an activity in your research procedures, it’s likely that you also need to edit your consent material to match. Fixing an issue in one procedural document but forgetting to update the others is a very common cause for delays.
- Changing your research design, procedures or participant groups in ways that were not specified in the approval stipulations nor reviewed as part of the “approve with stipulations” process.
Before clicking resubmit, do a final side-by-side comparison of the stipulations provided to you with your revised application and supporting documentation to ensure every single point has been addressed.
Researchers should utilize the following IRB webpages to prepare for the IRB review process and for guidance on how to draft application materials.
- IRB Forms and Templates webpage
- IRB Policies, Rules, and Regulations webpage
- IRB Procedures and Guidance webpage
Estimated Review Timeframe
The review timeframes provided are only for planning purposes and are not guaranteed deadlines. Please note that the review “clock” begins only when a fully complete application—including all required supplemental documents—is ready for final review. This is usually not when an application is first submitted to the IRB office.
What Affects Approval Timeline?
Protocol approval will likely take longer (or, occasionally, happen sooner) based on a few key factors:
- The quality, clarity, and completeness of your submitted materials
- The complexity of your study design
- The specific level of IRB review required
- Whether additional (ancillary) reviews are needed
Average Approval Processing Times
- Administrative Review (Exemption Determinations including Limited Review and FLEX): 1-2 weeks
- Expedited Review: 4-5 weeks
- Convened Full Board Review: 6-7 weeks
- Renewals of Existing Protocol Approval: 2-7 weeks (depending on the level of review needed)
- Amendments to Existing Protocols: 2-7 weeks (depending on the level of review needed)
Important Note for Student Researchers
The estimated timelines above do not apply to student projects. Because student research requires a highly collaborative, iterative process, IRB approval typically takes much longer. If you are a student, please be aware of the following:
- Faculty Submission Required: Students cannot submit applications directly to the IRB. Only your faculty advisor can submit the protocol on your behalf.
- Collaborative Drafting and Editing: While the NC State IRB provides templates, training, and guidance, students must work closely with their faculty advisor to draft and revise all IRB application materials. Faculty members are subject matter experts in your field and they are overseeing your academic process, including your IRB application and human subjects research.
- Setting Appropriate Expectations: Please work directly with your faculty advisor to establish realistic timelines for your specific project’s review and approval. Typically, these are much longer that the estimated timelines above due to learning curve and processes that student protocols demand.
Additional (Ancillary) Reviews
Depending on your study’s design, funding, or technology, your protocol may require additional reviews. These reviews usually occur during the IRB pre-review process; a few occur after IRB approval. All of these reviews ensure your study meets specific legal, regulatory, or safety standards.
Clinical Trials
Federally funded studies are classified as clinical trials (under 45 CFR 46.102(b) if they prospectively assign human participants to an intervention to evaluate biomedical or behavioral health-related outcomes.
- The Process: The NC State IRB will evaluate your study during the normal review process to determine if your study meets the federal definition of a clinical trial.
- Post-Approval Requirements: If your study is a clinical trial, you will receive a special clinical trial letter alongside your IRB approval. You must then register your study on http://www.clinicaltrials.gov publicly post your consent forms, provide annual updates, and share final results.
- NC State University IRB Clinical Trials Unit Standard
Cooperative Research
Cooperative research involves collaborating with outside people, groups, or organizations. For a detailed discussion, please go to our Cooperative Research webpage, but the summary is:
If NC State is the IRB of Record
When collaborating with other institutions and NC State is taking the lead on IRB review, two concurrent reviews are required during the standard IRB process
- Research Site Context Review: Helps the IRB understand the structure and operations of outside research sites so the IRB can assess and manage research risks. The principal investigator and collaborators use complete the Research Site Context Worksheet and upload it as a supporting document.
- Conflicts of Interest (COI) Review: Assesses actual or perceived conflicts for members of the research team. The principal investigator must ensure all collaborators complete the Conflicts of Interest Attestation or Management Plan form and upload all completed forms as supporting documents.
If Another Institution is the IRB of Record
If an external institution’s IRB is the IRB of Record, NC State researchers must file a request with the NC State IRB for either a:
- Letter of Acceptance of an Exemption Determination: For studies deemed exempt by another IRB with an FWA number and the NC State researcher and their role/tasks were listed on the application that received the exemption determination.
- Reliance Agreement: For non-exempt studies reviewed by another IRB with an FWA number
If Collaborating with Individual Investigators
If your research team includes independent researchers or individuals who are not affiliated with an institution that has its own IRB (with an FWA number) who will be assisting you on your research study, they must be officially covered by NC State’s IRB.
- The Process: The NC State principal investigator must establish individual investigator agreement (IIA) for each unaffiliated researcher. This legally bind the individual to NC State’s human subjects research policies and ethical standards. The individual’s human subjects research training and IIA request form must be complete and uploaded for IRB review and the protocol must be approved and the IIA executed before the individual can begin assisting you with any research activities.
Data Management
If your study involves specific technologies or sensitive data, you will need NC State University OIT clearance.
- Code Review: Required if you will use human data with any modified or purpose-built technology not licensed by NC State University. An independent reviewer (not on the research team or possessing other conflicts of interest) must assess the code for security and compliance.The completed review form must be submitted with your IRB application.
- Data and Access Security Plan (DASP): Required if your study will collect highly sensitive (red) data, ultra-sensitive (purple) data, or involves data controls (like a DUA, MTA, or NIH DMSP). Once your IRB materials are fully drafted, request a DASP through the OIT ServiceNow portal. The completed DASP must be uploaded to your IRB application.
- IT Purchase Compliance (ITPC) Review: Required for any technology not currently licensed by NC State that you wish to use in research reviewed by the IRB. Contact OIT’s Software Licensing Management team to complete ITPC review before IRB approval.
Department of Defense (DoD) Affiliated Research
Studies funded by the Department of Defense or utilizing DoD personnel/resources have additional mandatory oversight controls.
- Scientific Merit Review: Required for all non-exempt DoD studies. An independent expert must review the scientific merit of your study. You must facilitate this review and submit the results with your application (typically after IRB staff determine your materials are ready for final review).
- HRPO Review: Required for all DoD studies (including exempt ones). This review is facilitated between the researcher and the DoD’s HRPO officer after NC State IRB approval is granted. Research cannot commence until after the protocol has been approved by the NC State IRB and DoD HRPO.
Local and Participant Context Reviews
If you are studying unique or international populations, an independent subject matter expert may need to evaluate the cultural or legal risks to participants before the IRB conducts the final review of the study.
- When is it Required: Always required for international studies reviewed at the expedited or convened full board level. It is occasionally required for domestic studies with unique populations at any IRB review level, including exemptions.
- The Process: The researcher is responsible for facilitating this review with an expert who has no conflict of interest with the study. This occurs prior to the final IRB review when the application and all supporting documentation is ready for final review. IRB staff will let the principal investigator know in the pre-review process when the appropriate time is for the local or participant context review to be done.
Medical Device Studies
If your study will involve the use of a medical device, ancillary reviews, processes, and regulatory requirements can apply. Please note that if you will be studying a health-related outcome and prospectively assigning participants to an intervention, your study will also be subject to clinical trial regulations.
Investigational Device Exemptions (IDEs)
The U.S. Food and Drug Administration categorizes medical devices by risk which dictates whether you need their direct review and approval for your study.
- Investigational Device Exemption (IDE) (Rare at NC State): Devices that pose significant risks to participants require researchers to apply directly the the FDA for a full Investigational Device Exemption (IDE) before the study can begin.
- Abbreviated IDE (Most Common at NC State): Nonsignificant risk devices that will be tested for basic efficacy or safety usually qualify for an abbreviated IDE. You don’t need to submit an application to the FDA; instead, the NC State IRB convened full board acts as the FDA’s surrogate to approve an abbreviated IDE for the study.
- IDE Exempt: Nonsignificant risk devices used only as research tools, are not the focus of the study, and no safety/effectiveness data will be collected are exempt from FDA IDE requirements. IDE Exempt does not mean that the study is exempt from IRB review, minimal risk, eligible for an exemption determination, or doesn’t need to comply with all applicable regulations.
IRB Review
The level of IRB review depends directly on the FDA medical device risk category: significant risk or non-significant risk.
- Expedited IRB Review: For IDE Exempt medical devices that are noninvasive, not the focus of the research study, and will be used only as research tools. There is no testing the medical device for safety or efficacy.
- Convened IRB Full Board Review: For nonsignificant risk devices that are eligible for an abbreviated IDE.
- External WCG Review: For all significant risk medical devices that require a full IDE from the FDA.
- Required Forms and Templates
- Medical Devices Used In Research Form for each device that will be used in the study
- BME Participant Procedures Template if you are in the BME department; other researchers can use it if they want
- If applicable to the study:
- Completed code review
- AI participant information sheet – NOTE: This is in addition to information about the AI tool(s) that is included in the consent and Broad Consent forms
- AI supplemental information form
- Application software informed consent addendum
- Application software participant information sheet
- Homegrown, purpose-built, and modified application software information sheet
- Researcher personal device use attestation
Clinical Trials
Regardless of the medical device’s risk level or IRB approval path, a medical device study is a clinical trial if research participants will be prospectively assigned to an intervention to evaluate a health-related outcome.
If your study is a clinical trial:
- The study must be registered on http://www.clinicaltrials.gov
- Consent forms must be publicly posted
- Annual research progress reporting requirement
- Finalized research results must be provided
Technology and Security Clearances
If your study uses a modified or purpose-built (custom) device, you may need additional University review and clearances before the NC State IRB will approve your study.
Those clearances could be from:
- Office of Information Technology (OIT)’s Security & Compliance (S&C)
- Office of Information Technology (OIT)’s IT Purchase Compliance
- Office of Research Commercialization
- Independent code review of the modified or purpose built technology
Relevant Links and Resources
- NC State University IRB Medical Devices Unit Standard
- NC State University IRB Reviewing Research from the Joint BME Department Unit Standard
- Medical Devices Used in Research Form
- BME Participant Procedures Template
- BME Study Submission or Update Checklist
- Mobile Software Applications and Wearables as Medical Devices
IRB Lifecycle
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