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WIRB® Submission

As of July 12, 2017 the University of South Alabama (USA) has entered into an agreement with the WIRB Copernicus Group (WCG) to become the IRB of record for eligible studies. WCG is AAHRPP accredited and used by many institutions across the country. WCG conducts rigorous reviews of the materials provided to them and ensures that the informed consent and HIPAA Authorization documents meet the stipulations set forth in the agreement. The conditions and procedures concerning the IRB review are contained in a memorandum of understanding between USA and WCG. Materials submitted for WCG review will be pre-screened by the IRB staff to ensure USA IRB requirements are fulfilled.

Be sure to review the complete USA policy and procedure for the use of the WCG.

IRB SOP 1101: WCG IRB (Formerly WIRB)

▼   What Studies Are Eligible for WCG Submission?

The criteria for studies to be eligible for review by the WCG include:

  1. Research meets the NIH definition of a clinical trial.  “A prospective biomedical or behavioral research study of human subjects that is designed to answer specific questions about biomedical or behavioral interventions (drugs, treatments, devices, or new ways of using known drugs, treatments, or devices)”. 
  2. Research is a Phase II/III/IV clinical trial.
  3. Protocol must be written and designed by sponsor.
  4. The sponsor is a for-profit entity or company.
  5. The sponsor holds all INDs/IDEs.
  6. The research has not previously been submitted to the USA IRB for review.

Studies which involve any of the following are not eligible for submission to WCG:

  1. Phase I Studies (including I/II, studies)
  2. Planned emergency research
  3. Single patient emergency use or compassionate use situations
  4. Embryonic stem cell or gene therapy research
  5. Federally funded protocols
  6. Protocols funded by a Cooperative Oncology Group/NCI sponsored trials
  7. Investigator-initiated research
  8. Industry sponsor that refuses to pay WCG fees and/or the USA IRB fees
  9. Research involving prisoners
  10. Other studies to be determined by the local IRB, such as COVID-19 trials

USA may also require dual review by the USA IRB when the institution deems that the rights and welfare of subjects would be better served by local review.

▼   How do I Submit to WCG?

How to Submit WIRB

Step Action
Step 1: Investigator begins LOCAL processes for submission to USA IRB

WCG Copernicus has partnered with IRBNet and the online submission portal will remain unchanged.

Create a New Project in IRBNet

Package 1:

  • Upload the following items:
    • USA IRB Part A Application
    • IRB External Review Request Form (located in IRBNet)
    • WCG Boilerplate Consent checklist (ensure the sponsor specific additions to the USA IRB Consent language is noted)
    • Consent form with track changes is only needed if the consent template has NEVER been reviewed by WCG
    • Documentation of consent language approval, generally an email, from the sponsor
    • Sponsor Protocol  
  • PI must electronically sign package 1 for USA IRB local review
  • All key personnel listed on Part A IRB application must have completed the required applicable human subjects training, ACRP (as applicable), and HIPPA for Research.
  • Submit Package 1 for USA IRB pre-preview and acknowledgment. NOTE:   WCG should be selected from the drop down menu and the WCG link to the forms menu should be accessed for the appropriate submission forms. 
  • Acknowledgment will be published in Package 1 

NOTE:  Fees 

  • IRB fees should be included in the study budget.  There is a one-time USA administrative review fee of $2000 for initial submissions. The contract agreement will include this fee to be paid to USA by the sponsor.
  • The WCG IRB fee schedule is available in the IRBNet Library

WCG will bill the sponsor directly, if allowed.  Include this information on the WCG Billing Section of the Initial Review Form.

Step 2: Submission to WCG

Create a New Package in IRBNet under the same project

Package 2: 

Standard Submission Requirements Include:

  • Current WCG initial review submission form (Note:  WCG Institution #87329)
  • site specific consent form
  • PI’s current professional license (unless already on file)
  • PI’s CV (unless already on file)
  • The USA IRB Acknowledgment Letter (from package 1 in IRBNet)
  • Signed WCG Boilerplate Checklist (from package 1 in IRBNet)
  • Correspondence, such as an email, that the sponsor approves the consent language
  • site specific documents such as subject material and advertisements
  • If the study has never been reviewed by WCG then include:
    • Consent form with track changes
    • Protocol
    • Investigator's Brochure (if applicable)

Instructions on submitting your project are available from the WCG website. (Access the WCG Submission Forms)

Step 3: Review by WCG What happens after you submit Package 2 to WCG?
  • An IRBNet submission notification is generated and located in IRBNet Messages and Alerts
  • WCG will unlock package 2 if there are questions about the submission.  Attach / drag updated documents into package 2 and select mark revisions complete.  This will notify WCG that the requested revisions are ready for additional review.
  • Once the submission has been reviewed, WCG will issue an IRBNet email notification of Board Action / Multiple Board Documents Published when the review has been completed.  All approval documents will be published in IRBNet, and located under Reviews when the title of the project has been selected. 
  • Any questions that the PI/contact person may have regarding the WCG review process should be directed to WCG

Consent Documents: For WCG approved projects, the WCG stamped consent document for enrolling subjects must be utilized.  The USA IRB is not the IRB of record for the protocol, and will not be USA stamped.

NOTE:  Commencement of project should not begin until all approvals and the clinical trial agreement are in place

▼   What Happens After I Receive WCG Approval?

The WCG is now the IRB of records for your study. You should refer to WCG’s policy and procedures for their reporting requirements of continuing review, amendments, adverse events, protocol deviations, closure notifications, and any other submissions.

However, the USA IRB must still ensure adequate institutional oversight of research activities. Therefore, in addition to notifying WCG, investigators should notify the USA IRB of any of the following events:

  • Protocol deviations that may represent a systematic problem requiring local evaluation by USA IRB to determine that sufficient local resources are available for safe conduct of the study
  • Study holds or suspensions that are not built into the study design from WCG or Sponsor (e.g.: interim analysis or enrollment complete need not be reported)
  • Study Closure
  • Study Terminations from CIRB or sponsor
  • Subject complaints
  • Amendment to change PI or key personnel (NOTE: IRB Application Part A must be updated to reflect personnel changes)
  • Conflict of Interest updates
  • Breaches of confidentiality/HIPAA Privacy and/or Security violations
  • Completion of annual check-in form (more information below)

Annual Check-In: This is not the same as a continuing review. Therefore, it may occur at a different time than the continuing review required by WCG.

Project Personnel Updates: USA IRB application Part A should be updated, as needed, (i.e., study personnel, PI change and submitted to USA IRB)

Monitoring of WCG approval protocols: WCG will arrange for monitoring ongoing research, as its policies and procedures require.  The USA IRB/ Office of Research Compliance and Assurance may monitor any WCG approved protocol as part of its quality assurance program.

Record keeping: Record keeping procedures for all files must be established, and WCG documents, e-mail notifications, and other correspondence must be stored / filed as previously maintained through normal USA IRB approval.

▼   What Specifically Do I Need to do with the Informed Consent Form? 

The USA IRB local context consent language for WCG provides an outline of sections which may need to be included in your consent form.  All sections may not be applicable, rather they are dependent on the study to be conducted. 

The site is required to communicate with the sponsor to determine the applicable language and to seek sponsor approval. Sponsor approval for consent language should be received before submitting to the USA IRB for preliminary review.

The site should ensure that the current consent template is used to insert the Local Context Language. The USA IRB’s account manager at WCG should be contacted to obtain the current WCG approved consent template. If WCG does not have an approved consent, then the site should obtain the consent template from the sponsor.

IMPORTANT: No deletions or modifications can be made to the USA IRB Local Context Language. The sponsor can request additional language. However, the addition cannot duplicate local language. Furthermore, additions can only be inserted before or after local language. Additions cannot be inserted in between local language paragraphs, sentences, etc.

USA IRB Local Context Consent Language for WCG

▼   Who Do I Contact if I Have Any Questions? 

Questions during Step 1 of submitting a new study- Submission to USA IRB for Pre-Review and for any USA IRB related issues:

 

SuzAnne Robbins
USA IRB Compliance Specialist
Office of Research Compliance and Assurance                                                                  Email: srobbins@southalabama.edu
Telephone: (251) 460-6308

Questions during Step 2 of submitting a new study- Submission to WIRB and for general questions while the study is open with WIRB:

WIRB Client Services
Telephone: (800) 562-4789
Email: clientservices@wirb.com
Web: www.wcgirb.com

Questions or concerns that WIRB Client Services cannot address:

Deena Horowita, CIP
Telephone: (360) 252-2442
Email: dhorowitz@wirb.com
Web: www.wcgirb.com

▼   Additional Resources