The sponsor requested the IRB approval notice prior to releasing funds, but my study is not ready for review. What should I do?

.118 Determinations are granted to satisfy sponsoring agency requirements to allow investigators to have access to funding to begin aspects of the project that do not involve human subjects.  Funds may not be used to conduct research with human subjects until a study-specific protocol has been reviewed and approved.

Under the federal regulations (§46.118) and in accordance with the OSU IRB’s Standard Operating Procedures, certain types of applications for grants, cooperative agreements, or contracts are submitted to departments or agencies with the knowledge that subjects may be involved within the period of support, but definite plans would not normally be set forth in the application or proposal.

These include activities such as:

  • institutional type grants when the selection of specific projects is the institution's responsibility;
  • research training grants in which the activities involving subjects remain to be selected; and,
  • projects in which human subjects' involvement will depend upon the completion of instruments, prior animal studies, or purification of compounds.

These applications need not be reviewed by an IRB before an award may be made. However, no human subjects may be involved in any project supported by these awards until the project has been reviewed and approved by the IRB.

To request a .118 Determination, please email the HRPP at [email protected] and include the following information:

  • Principal Investigator
  • Funding agency
  • Cayuse award number
  • Grant title
  • A copy or forward of the email from the sponsor with the request for IRB approval

If you have already submitted an application to the IRB:

If you have already submitted your application to the IRB, it is under review. Please contact the HRPP immediately upon receiving any favorable correspondence from the sponsoring agency indicating that your proposal may be funded or recommended for an award. 

If your project already has IRB approval:

If your funding proposal is for a project that already has IRB approval, please submit a project revision to add the sponsor if your proposal is funded.

For NSF-funded Proposals:

NSF has provided institutions with the template language for these determinations and will accept them under the circumstances listed above.

If you encounter issues having this determination accepted by a program officer, please refer them to Jeff Mantz, Human Subjects Research Officer, National Science Foundation ([email protected] or (703) 292-7783).

If you have any questions, please email them to [email protected]