For sponsored projects involving human subjects research, no funds can be requested and no obligations made against funds for research involving human subjects during a period not covered by Institutional Review Board (IRB) approval.

However, if the sponsored project funds are needed to conduct activities not involving human subjects research prior to IRB review/approval, the Principal Investigator may request a portion of the budget to be released for spending. Pre-IRB activities include development of study instruments, hiring staff, obtaining space in facilities, etc.

In these cases, it may be appropriate for PI to submit an interim funding request through the PI Work Center. 

Use of Award Funds in the Pre-IRB Period

Spending authority on the cost center will expire when the pre-IRB period ends, and no additional expenses can be posted until the IRB has been approved. If an extension is needed, RIO must approve in writing. The PI must indicate on the expenditure documents paid during this period, the purpose and benefit of pre-IRB costs to demonstrate that they do not involve human subject research.