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Step 3: Do I Qualify For Expedited Review?


​If you have determined that your study does qualify as "human subject research", and is not eligible for one of the 5 "Exempt Categories" listed in Step 2, you are conducting research regulated under federal legislation 45 CFR 46, which requires continuing COMIRB oversight over the life of the study. 

The accordion folders at the bottom of this page will help you determine if you are eligible for one of the 7 "Expedited Categories" that would allow your study to be reviewed by only a panel Chair Member, or if your study requires review by the Full Board Panel. Your study must be "minimal risk" to qualify for Expedited review. All research that is greater than "minimal risk" must be reviewed by a Full Board Panel.

Before you review the accordion​ folders, please review the following bullet points that may include information relevant to your study:

  • If you are conducting research that involves a biologic, drug, or medical device, you may be subject to different regulations under the Food and Drug Administration. Please see the accordion folder labeled 'Am I conducting "human subject research" regulated by the U.S. Food and Drug Administration?' at the bottom of Step 1.
  • Your study may be subject to additional regulatory requirements if it includes specific vulnerable populations (prisoners, children, pregnant women,  neonates), or if your study includes veterans.

Please review the accordion folders below to determine if your study qualifies for Expedited review:
 
Is my study "minimal risk"?

Definition of "minimal risk":

That the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests.

If your study does not meet the definition of "minimal risk", than it must be submitted for Full Board review and you can proceed to Step 4. Please be aware that your interpretation of "minimal risk" may not be the same as our Panel members.

If your study does meet the definition of "minimal risk", proceed to next accordion folder to determine if your study is eligible for Expedited review based upon the 7 "Expedited Categories" outlined in the federal regulations.

Does my study fit into any of the 7 "Expedited Categories"?

The following link includes a document that outlines the 7 "Expedited Categories" by which an initial submission of a study can be approved. Click here to access that document.

Important Note: Certain types of research do not qualify for initial Expedited review and must be reviewed by a Full Board:

  • Research involving human genetic testing
  • Research involving prisoners
  • Research involving major deception in which the researcher misleads subjects about their health status, the researchers, or research purpose.

Further Available Resources:

If you are unsure whether or not your study qualifies for Expedited review, this decision tree from the Office of Human Research Protection may be helpful. Please call the COMIRB Help Line at 303-724-1055 with any questions.

Next Steps:

If you have determined that your study is eligible for Expedited review, please check the accordion folder below entitled "Does my study include vulnerable populations?" to see if your study is subject to any additional regulations, then click the accordion folder entitled "How to submit for Expedited review".

If you have determined that your study is not eligible for Expedited review please check the folder below to see if any special regulations apply based upon the inclusion of "vulnerable populations, then proceed to Step 4 by scrolling to the top of this page and clicking the link in the grey column to the left of the page.

Does my study include "vulnerable populations" that have additional regulatory requirements?

"Vulnerable populations" include those individuals whose status may create additional risk for study participation or undue coercion, such as: children, prisoners, pregnant women, neonates, mentally disabled persons, adults who lack the ability to consent, or economically or educationally disadvantaged persons.

COMIRB will determine if appropriate additional safeguards are in place to protect the rights and welfare of subjects if they are likely to be members of a vulnerable population.

If COMIRB reviews research that involves categories of participants vulnerable to coercion or undue influence, the review process will include one or more individuals who are knowledgeable about or experienced in working with these participants. For example, COMIRB will include one or more individuals who are knowledgeable about or experienced in working with children, prisoners, or adults with limited decision-making capacity, when reviewing research that involves individuals from these populations.

45 CFR 46 has additional subparts designed to provide extra protections for vulnerable populations which also have additional regulatory requirements:

Subpart B - Additional Protections for Pregnant Women, Human Fetuses and Neonates Involved in Research

Subpart C - Additional Protections Pertaining to Biomedical and Behavioral Research Involving Prisoners as Subjects

Subpart D - Additional Protections for Children Involved as Subjects in Research

If your study potentially includes any of vulnerable populations, please review the following links for guidance from COMIRB:

Submission instruction for Expedited review

Select the appropriate instructions below for information on how to proceed:

My study is not eligible for one of the 7 "Expedited Categories" listed in the accordion folder above:

Please proceed to Step 4 for information on how to submit your study for Full Board review by scrolling to the top of the page and clicking the link in the grey column on the left side of the page.

I believe my study qualifies for one of the 7 "Expedited Categories" listed in the accordion folder above:

Click here for an Initial Submission Checklist and Submission Instructions.

Expedited applications are reviewed on a continual basis, in the order they are received. The investigator will be notified of the review findings by email. Research may not begin until the investigator has received documentation of COMIRB approval. If the research involves the VA, the project may not begin until it is approved by COMIRB and then the VA R&D Committee.

Investigator's continuing responsibilities

We strongly recommend you review the following COMIRB documents which highlight the continuing responsibilities of investigators for approved studies:

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