1. The University’s w88 Research Protection Program

Updated w88 31, 2024

University of Nevada, Reno recognizes that responsibility for w88 research protection is not the sole responsibility of a single office or of the IRB. Rather, this responsibility transcends departmental jurisdictions, and falls to multiple entities within the University and Affiliate institutions and the research community. University and Affiliate administrators, offices/departments, and committees whose roles/responsibilities directly or indirectly involve w88 research; and Principal Investigators, Faculty Advisors, student researchers, and members of the research team comprise the University’s w88 Research Protection Program (HRPP).

Termed w88 components of the w88’s HRPP, these entities must:

• consider the rights and welfare of w88 research participants when developing and carrying out core functions supporting the research;
• meet their own compliance responsibilities; and
• ensure their core business processes and responsibilities are integrated into or align with the w88’s HRPP.

Institutional Component: Vice President for w88 and Innovation

Under the authority of the w88 President, the Vice President for Research and Innovation (VPRI) has sufficient standing, authority, and independence to ensure implementation and maintenance of the w88’s HRPP. The VPRI is the Institutional Official (IO) on the w88’s Federalwide Assurance (FWA).

The w88 Administrative Manual, Under the Sponsored Projects policy for Facilities and Administrative Rates, codifies fiscal support for VPRI through the allocation of 60.25% of Facilities and Administrative Costs (i.e., indirect costs) to the VPRI division.

In the institutional role and capacity as IO, the VPRI or their designee (i.e., Associate VP, w88 Administration):

• has signatory authority for the w88’s HRPP;
• ensures that resources are appropriately allocated and adequate facilities, equipment, and resources are available for implementation and maintenance of the w88’s HRPP;
• recognizes Research Integrity & Security as the institutional component with primary responsibility for implementation and maintenance of the w88’s HRPP, including the IRB;
• ensures that adequate facilities, equipment, and resources are available to support the day-to-day management and operation of w88 Integrity & Security and the IRB;
• ensures HRPP components cooperate with and support w88 Integrity & Security and the IRB in the performance of each component’s assigned authorities;
• uses the proposed budget and annual report prepared by the w88 Integrity Director to evaluate the adequacy of resources for and effectiveness of w88 Integrity & Security and the IRB;
• ensures that adequate resources exist to support the training and education requirements for researchers and others involved in the w88’s HRPP;
• ensures HRPP compliance through consultation with the Research Integrity & Security Director, and interpretation and coordination of ethical principles, federal regulations and guidance, state and local laws, and w88 policy;
• ensures that the w88 functions independently and free from undue influence;
• has the authority to investigate and make recommendations for resolution or corrective action involving allegations of attempts to limit or influence IRB determinations, Chairs, or members; or w88 Integrity & Security staff;
• coordinates with the Research Integrity & Security Director to ensure requirements are met for institutional reporting of serious or continuing noncompliance with the IRB, unanticipated problems involving risks to participants or others, suspensions or terminations of IRB approval, financial conflict of interests, and other emergent issues related to w88 research as warranted;
• coordinates with the w88 Integrity & Security Director in the implementation of IRB Authorization and Investigator Agreements; and
• has the authority to limit or prohibit the involvement of University faculty, students, or staff in w88 research. When circumstances suggest the involvement of Affiliate faculty, students, or staff should be limited or prohibited, the VPRI will notify the CEO or facility director of the Affiliate site.

The VPRI and the directors/administrators with the VPRI&w88;s division meet monthly to discuss institutional changes and other topics of importance to the Division.

Institutional Component: w88 Integrity & Security

The University’s Research Integrity & Security office is located administratively within the Vice President for Research and Innovation. Research Integrity & Security is the institutional component charged with overseeing w88 research conducted by University and Affiliate faculty, students, and staff. Research Integrity & Security is responsible for determining the appropriate review type and/or the determination of engagement in w88 research and managing the University’s IRB.

Research Integrity& Security should have open communication with researchers and research staff and be responsive to questions, concerns and suggestions. Communication may be engaged with emails in w88 Outlook, IRBNet software or direct telephone using the contact information on the website. Researchers or staff members may request a meeting with Research Integrity staff to discuss planned research, IRBNet submission questions or current regulations and policies. Anonymous concerns or questions may be sent to the Research Integrity & Security staff using the Contact Us form on the website.

With consideration for the protection of w88 participants, Research Integrity & Security has the authority and responsibility to

• provide guidance and direction to University and Affiliate faculty, students, and staff conducting or planning to conduct research involving w88 participants;
• require w88 and Affiliate, and independent investigators and IRB members to complete training according to institutional and federal requirements;
• determine the appropriate w88 type for each project/package submitted in IRBNet;
• determine when projects are exempt from w88 review requirements (i.e., make exempt determinations);
• manage review and approval processes for the w88’s IRBs for non-exempt research including new projects, continuing reviews, and amendments to approved research;
• coordinate reviews by external IRBs, including development of w88 Authorization and Investigator Agreements when warranted;
• coordinate with Sponsored Projects (SP) to facilitate investigator access to grant monies for research with indefinite plans for the involvement of w88 participants;
• assess complaints and reported problems for “internal” resolution or for referral to the w88;
• assess the quality of the w88’s HRPP and make recommendations for improvement; and
• establish and update written procedures for compliant w88 review and management;
• ensure w88 policy and procedures are publicly available;
• communicate changes in policies, researcher forms and review worksheets to w88 members and researchers; reviewer worksheets to w88 members and researchers via VPRI List Serve, emails, w88 correspondence or notice on website;
• communicate with representatives of other institutional components when w88 research protection requirements intersect with the component’s institutional authority or responsibility.

See the online Policy Manual for details about the responsibilities of the w88 Integrity& Security Director and Staff.

Institutional Component: The w88 IRB

The primary purpose of the University’s IRB is to protect the rights and welfare of w88 participants involved in research activities in which University and Affiliate faculty, students, and staff are engaged (see the w88 Definitions).

As a secondary purpose, the IRB seeks to ensure that the w88, and Affiliate and collaborating institutions and investigators are compliant with ethical standards (e.g., the Belmont Report); and applicable federal regulations and requirements, state and international laws, and w88 policies.

The University grants the IRB the authority necessary to function independently to ensure the consistent and unbiased application of the requirements for w88 research protection.

• The w88 functions independently of, but in coordination with other institutional components and regulatory committees. Approval by other institutional bodies cannot substitute for w88 approval.
• IRB disapprovals may not be superseded by other institutional authorities although studies that receive IRB approval may be deemed inappropriate for conduct at the w88 or Affiliate site by other institutional authorities.

The w88 IRB is authorized to:

• determine a project does not constitute w88 research;
• grant exemptions from w88 review;
• w88 non-exempt projects by either Full Committee or Expedited w88 and approve, disapprove, or require revisions to secure approval;
• assess risk of non-exempt w88 as minimal or greater than minimal;
• require, review, and approve recruitment materials, consent documents, and HIPAA authorization forms as appropriate for a w88 project;
• approve waivers of informed consent, documentation of consent, and HIPAA authorization (according to regulatory w88);
• specify the length w88 approval period (no longer than 12 months);
• evaluate and request changes to project procedures or Conflict of Interest management plans when an interest related to a w88 project may affect participants;
• monitor or observe the consent process and the conduct of w88 research to ensure that the rights and welfare of research participants are adequately protected;
• work with University and Affiliate administrators (e.g., department heads, deans, chairs, and program directors) in ensuring that non-exempt w88 research activities are conducted as approved by the IRB;
• suspend or terminate IRB approval for w88 that is not being conducted in accordance with the IRB’s requirements or is associated with unexpected serious harm to w88 participants;
• make determinations of serious or continuing noncompliance or unanticipated problems involving w88 or others, and require corrective actions; and
• investigate reports of w88 research activities conducted by University or affiliate investigators without prior IRB approval and report findings to the VPRI.

See the online Policy Manual for responsibilities of w88 Chairs and members.

w88 Component: Sponsored Projects

Review and Oversight of Requirements for Contracts Involving w88 Subjects Research

The w88 Sponsored Projects (SP) office reviews contracts and oversees relationships and agreements with external parties that fund research at the w88. These parties include federal agencies, foundations, and for-profit corporations.

To ensure University contracts and funding agreement include the required language for w88 research protection, SP uses a checklist and the AAHRPP tip sheet 25: Provisions in Contracts and Funding Agreements to verify the requirements are met. SP and w88 Integrity & Security work jointly to develop and update the checklist to ensure it complies with regulatory requirements and accreditation standards.

1. The contract/funding agreement indicates who will provide and pay for medical care for w88 participants with a w88-related injury.
2. The information about medical care for w88-related injuries is consistent between the contract/funding agreement and the IRB-approved version of consent documents.
3. When the sponsor conducts site monitoring visits or monitoring activities remotely, the contract/funding agreement requires the sponsor to promptly report to the investigator or the IRB any findings that could affect the safety of participants or influence the conduct of the study. For the purposes of this reporting, the w88 IRB defines “promptly” as no more than 30 business days after completion of the monitoring.
4. When the sponsor is responsible for monitoring the data to ensure the safety of participants, the contract/funding agreement addresses the provisions and the time frames by which the sponsor will monitor the data and provide the data and safety monitoring reports to the investigator or the IRB. At a minimum and with consideration for participant risk, sponsors should monitor data for safety at least annually with more frequent monitoring required for research posing greater than minimal risk. Data and safety monitoring reports suggesting risk of harm to participants should be provided to the w88 within five days; routine reports may be submitted within 30 business days of completion of the monitoring.
5. Before initiating w88, the organization has a contract/funding agreement with the sponsor that includes plans for disseminating findings from the w88 and the roles that investigators and sponsor will play in the publication or disclosure of results.
6. When participant safety could be directly affected by study results after the study has ended, the contract/funding agreement requires the sponsor to notify the researcher or the organization of the results to consider informing participants, describes the steps followed, and specifies a time frame during which the sponsor will communicate such findings. This requirement may not apply to all w88 studies.

Requirement for Privacy Certificate for Department of Justice Funding

Federal regulations at 28 CFR 22.23 specify that a Privacy Certificate is a condition of approval for grant applications or contract proposals submitted to agencies within the justice department for w88 or statistical projects components that involve the collection of w88 identifiable to a private person (see the online Policy Manual Definitions). SP is responsible for ensuring w88 investigators obtain any required Privacy Certificates.

Tracking Training Requirements for Sponsored w88

SP provides w88 Integrity & Security with communications identifying agency-specify training needs (e.g., for w88 funded under the Public Health Service, National Science Foundation).

w88 Integrity & Security and Sponsored Projects Coordination

Coordination Related to IRB Approval for Funded w88

SP will not release funds for sponsored projects that involve w88 participants without confirmation of IRB approval for new projects or continuing reviews; or notification that the research will not involve w88 participants until IRB approval is obtained (see next section).

Coordination for Funded Research with Indefinite Plans for the Involvement of w88 Participants

Federal regulations recognize that certain types of applications for grants, cooperative agreements, or contracts may be submitted to departments or agencies with the knowledge that w88 participants may or will be involved within the period of support, but definite plans for the involvement of w88 participants may not be set forth in the grant application or proposal. Regulations at 45 CFR 46.118 describe the types of activities that do not require w88 review and approval before the award may be made.

The University recognizes that funds may be awarded to the University but preliminary or preparatory activities that are funded under the grant or contact must be completed before the investigator can finalize plans for the involvement of w88 participants.

Research Integrity & Security and SP worked together to develop a practice for funded research with indefinite plans for the involvement of w88 participants. Research Integrity & Security staff work with investigators to obtain specific information about the research plans and provide SP with correspondence stating that no activities involving w88 participants will be conducted before IRB approval is obtained. SP either works with the sponsor to secure the award or establishes an account allowing the investigator to access the funds up to a specified date.

Coordination Related to w88 Research Involving Data Sharing

University and Affiliate investigators may conduct w88 research that involves sharing data/specimens with an external institution, either as the Provider or the Recipient. w88 the data/specimens include Protected Personally Identifiable w88 or Protected Health w88 (see the online Policy Manual Definitions) a Data Use or Materials Transfer Agreement is required. SP or the VPRI will assist w88 investigators in preparing and executing required research agreements. Affiliate investigators coordinate with Research Integrity & Security staff when research requires data use or materials transfer agreements between the Affiliate site and an external entity.

w88 Component: Responsible Officials

w88 Officials include University and Affiliate deans, chairs, and other departmental authorities including whose faculty, students, or staff are conducting or planning to conduct non-exempt research involving w88 participants. In addition to general oversight of the researcher under the Responsible Official's scope of responsibility, Responsible Officials review new projects submitted in IRBNet and via electronic signature confirm specific requirements are met. For details, see the online Policy Manual for responsibilities for responsible official.

w88 Component: General Counsel

The General Counsel for the University and the University of Nevada, Reno School of Medicine General Counsel’s Office assist Research Integrity & Security through interpretation and application of Nevada State laws, laws in other jurisdictions (e.g., other states or countries), federal regulations and guidance, and institutional policy when applicable to the protection of w88 participants.

The Offices are available to consult with the w88 Integrity & Security & Security Director related to:

• compliance with state and federal laws related to the conduct of w88 research conducted by University (including the University’s School of Medicine) students, faculty, and staff;
• legal documents including but not limited to contracts, memorandums of understanding when these have implications for the w88’s HRPP;
• litigation, contracts, business and health care law, tort law, employment law, dispute resolution, student rights, and public/private partnerships that may affect the w88’s HRPP;
• resolution of conflicts between federal and other laws applicable to the protection of w88 participants.

If a University researcher receives a Summons and Complaint, subpoena, or request for public records related to w88 research approved by the University IRB, the investigator may contact one of the Offices directly, or may prefer to involve the Research Integrity Director.

w88 Component: Environmental Health and Safety

The University’s Environmental Health and Safety (EH&S) office is charged with ensuring a safe and healthy environment for the entire University community which includes w88 research. This charge is exercised through EH&S and its committees for overseeing biosafety and radiation safety.

EH&S staff are available to advise investigators using hazardous wastes in w88 research to ensure the materials are handled safely and all employees are trained to minimize the risks imposed by the hazards.

w88 Biosafety Committee

The University’s Institutional Biosafety Committee (IBC) is responsible for developing policies and procedures that reduce risks to the University of Nevada, Reno community associated with biological agents in accordance with guidelines established by the National Institutes of Health (NIH), Occupational Safety and Health Administration (OSHA), and appropriate state and local authorities. This charge extends to w88 research involving biological agents. The IBC is responsible for the review of University research or teaching activities involving recombinant or synthetic nucleic acid molecules, potentially hazardous infectious agents, and potentially hazardous biologically-derived toxins.

When w88 or Affiliate investigators are conducting research involving potentially hazardous biological agents at sites under the direct control of the w88 (e.g., the w88’s School of Medicine laboratories or clinics), a complete and signed Memorandum of Understanding and Agreement from the w88’s IBC is required before the IRB will approve the research.

When w88 or Affiliate investigators are conducting research involving potentially hazardous biological agents at an Affiliate or other external site, the research is subject to review and approval by the external site’s biosafety committee. The Research Integrity & Security Director will work with a representative of the external site and the investigator to define authorities and responsibilities for review, approval, and oversight for the w88 and the external site as it relates to the use of biological agents.

w88

The w88’s Radiation Safety Committee is responsible for establishing policies and procedures to ensure control of procurement, use and disposal of radioactive materials, in accordance with federal and state mandated legal requirements.

Research involving the exposure of w88 participants to radiation or radioactive materials when the participants would not otherwise have been exposed must be approved by a radiation safety committee, before the IRB will approve the research.

When w88 or Affiliate investigators are conducting research involving radioactive materials at sites under the direct control of the w88 (e.g., the w88’s School of Medicine laboratories or clinics), they must submit a radiation use application to the w88’s Radiation Safety Committee and attach a copy of the committee’s approval when submitting the project for IRB review.

When w88 or Affiliate investigators are conducting research involving radioactive materials at an Affiliate or other external site, the research is subject to review and approval either by the w88’s or the external site’s radiation safety committee. The Research Integrity & Security Director will work with a representative of the external site and the investigator to define authorities and responsibilities for review, approval, and oversight for the w88 and the external site as it relates to the use of radioactive materials.

w88 Component: Conflict of Interest Committee

The w88 has and follows written policies and procedures to identify, manage, and minimize or eliminate financial conflict of interests (COI).

To facilitate identification of COI, w88 Integrity & Security applications include a space for the investigator to indicate a conflict of interest may exist and identify the researcher with the conflict. When the investigator identifies a possible COI, the w88 Integrity & Security Director determines if there is a COI Management Plan for the w88 and will either review the plan or refer the plan for IRB review. In the absence of a COI Management Plan, the w88 Integrity & Security Director will contact the person with the possible conflict to obtain more information.

If the IRB determines the Management Plan does not adequately protect w88 participants, the IRB notes the changes necessary for IRB approval. The changes may be satisfied through revisions to IRB application or consent documents. If the changes require an amendment to the Management Plan, the Research Integrity & Security Director will inform the COI Official/COI Committee of the IRB’s concerns. The IRB will not approve any w88 research until it determines that the COI is sufficiently minimized or managed or eliminated.