IRB and HRPP AdministrationFrom Coordinator to CIP
A complete lecture course on Institutional Review Board administration, built on PRIM&R's public 2025 CIP Body of Knowledge and Exam References. The lessons follow the exam blueprint across its three domains, and every lesson cites the regulation it teaches so you can verify it yourself. Each lesson page adds the learning objectives, the exam traps to avoid, a recap, and practice questions with explained answers.
Course at a glance
Course outline
26 lessons across the three exam domains, plus an orientation and a capstone · ~25 hours total · click any lesson to start
Module 0: Course Orientation
Module 1: Domain 1: Human Subjects Protection (29%)
- Lesson 1
Why IRBs Exist: Tuskegee, Nuremberg, and the Rules They Wrote
- Sequence the major research ethics scandals and the response to each
- Explain how the National Research Act of 1974 created IRBs and the National Commission
- Trace 45 CFR 46 from 1974 through 1991 to the 2018 Requirements
- Lesson 2
The Belmont Report Explained: Three Principles, Three Applications
- State the three principles and the application paired with each
- Explain the boundary between practice and research
- Apply the three components of consent: information, comprehension, voluntariness
- Lesson 3
Nuremberg, Helsinki, CIOMS, and ICH GCP: The International Codes
- State the ten principles of the Nuremberg Code and their origin
- Explain Helsinki's authorship, audience, and positions on placebo, post-trial access, vulnerable groups, and registration
- Describe the CIOMS guidelines and their focus on low-resource settings
- Lesson 4
The Common Rule Explained: 45 CFR 46 Definitions That Decide Everything
- State to whom and to what 45 CFR 46 applies and how the FWA extends it
- Recite and apply the definitions of research, human subject, minimal risk, and the related terms
- Name the four activities deemed not to be research
- Lesson 5
FDA Human Subject Regulations: 21 CFR 50, 56, 312, and 812 Explained
- State when FDA regulations apply and how that differs from Common Rule applicability
- Contrast the FDA definitions of human subject, clinical investigation, and test article with the HHS definitions
- Describe the IND framework in 21 CFR 312, including exemptions and the roles of sponsor, investigator, and IRB
- Lesson 6
HUDs, Expanded Access, and Emergency Use: FDA's Special Pathways
- Explain the Humanitarian Use Device designation and the IRB's role in HDE use
- Distinguish the expanded access categories in 21 CFR 312 Subpart I
- Apply the emergency use exemption from IRB review and the emergency exception from consent at 50.23
- Lesson 7
DOD, DOJ, NIH, VA, and EPA: How Agencies Layer the Common Rule
- Explain how Common Rule agencies codify Subpart A and add their own requirements
- Describe Department of Defense additional protections for research involving service members
- Describe Department of Justice and Bureau of Prisons requirements for research with prisoners
Module 2: Domain 2: IRB Responsibilities (54%)
- Lesson 8
IRB Membership, Quorum, and Authority: 45 CFR 46.107 to 46.113
- State the membership requirements of 45 CFR 46.107 and 21 CFR 56.107
- Define quorum and the conditions under which a convened IRB may act
- Describe the roles of chair, alternates, consultants, and the Institutional Official
- Lesson 9
The 8 Exemption Categories and Limited IRB Review: 45 CFR 46.104
- State all eight exemption categories in 45 CFR 46.104(d) with their conditions
- Explain limited IRB review and when it is required
- Apply the restrictions on exemptions for research with children, prisoners, and pregnant women
- Lesson 10
Expedited, Full Board, and Continuing Review: The 9 Categories and 46.109(f)
- State the nine expedited review categories and the conditions for using the expedited procedure
- Explain who may conduct expedited review and what they may and may not decide
- Describe convened review and when it is required
- Lesson 11
The Criteria for IRB Approval: 45 CFR 46.111 Line by Line
- Recite the criteria for approval in 45 CFR 46.111(a)(1) through (a)(8) and (b)
- Explain how an IRB evaluates risk minimization and the reasonableness of risks relative to benefits
- Apply the equitable selection criterion, including its attention to vulnerable populations
- Lesson 12
Informed Consent Elements, Key Information, Broad Consent, and Waivers
- State the general requirements for informed consent in 45 CFR 46.116(a)
- Recite the basic elements in 46.116(b) and the additional elements in 46.116(c)
- Explain broad consent under 46.116(d) and its relationship to exemption categories 7 and 8
- Lesson 13
Documenting Consent: Short Form, Waivers, LARs, Assent, and eConsent
- State the documentation requirements of 45 CFR 46.117 and 21 CFR 50.27
- Apply the short form procedure, including who signs what
- Apply the three waiver-of-documentation criteria in 46.117(c) and the two in 21 CFR 56.109(c)
- Lesson 14
HIPAA in Research, Certificates of Confidentiality, FERPA, and GINA
- Distinguish privacy from confidentiality and identify the IRB criterion governing each
- Explain how the HIPAA Privacy Rule applies to research: covered entities, PHI, authorization, waiver, limited data sets, de-identification, preparatory to research, and decedents
- Explain Certificates of Confidentiality, what they protect, and their exceptions
- Lesson 15
Subparts B and C: Pregnant Women, Fetuses, Neonates, and Prisoners
- Apply the conditions for research involving pregnant women or fetuses in 45 CFR 46.204
- Distinguish research with viable, nonviable, and uncertain-viability neonates under 46.205
- State the prisoner definition, the IRB composition rule, and the additional duties in Subpart C
- Lesson 16
Subpart D Children: 404 to 407, Assent, Permission, and Wards
- Define children, assent, permission, and guardian under 45 CFR 46.402 and 21 CFR 50.3
- Apply the four risk categories in 46.404 through 46.407 and their FDA counterparts in 50.51 through 50.54
- State the assent and permission rules in 46.408 and 50.55, including when each may be waived
- Lesson 17
Adverse Events vs Unanticipated Problems: The OHRP Test and FDA Safety Clocks
- Define adverse event, serious adverse event, unexpected adverse event, and suspected adverse reaction
- Apply the three-part OHRP test for an unanticipated problem involving risks to subjects or others
- Distinguish which adverse events must be reported to the IRB and by whom
- Lesson 18
Noncompliance, Research Misconduct, and IRB Suspensions Explained
- Define noncompliance, serious noncompliance, and continuing noncompliance and describe how an IRB handles each
- Distinguish protocol deviations from violations and from unanticipated problems
- Explain research misconduct under 42 CFR 93: definition, standard of proof, process, and the roles of the RIO and ORI
- Lesson 19
IRB Meeting Minutes: Exactly What 45 CFR 46.115 Requires
- State the minute content required by 45 CFR 46.115(a)(2) and 21 CFR 56.115(a)(2)
- Record attendance, quorum, recusals, and votes in the form regulators expect
- Document controverted issues, the basis for requiring changes or disapproval, and risk and category determinations
- Lesson 20
From Intake to Approval Letter: Three IRB Protocols Worked End to End
- Sequence the determinations an IRB office makes on a new submission from intake to approval letter
- Apply the Domain 2 rules to three worked protocols of different types
- Produce the documentation trail each determination requires
Module 3: Domain 3: Institutional Responsibilities (17%)
- Lesson 21
Single IRB, Reliance Agreements, and Local Context: 45 CFR 46.114
- 1. State the single IRB requirement in 46.114 and its exceptions
- 2. Distinguish the NIH sIRB policy, the Common Rule requirement, and FDA 56.114
- 3. Explain reliance agreements, IRB Authorization Agreements, and SMART IRB
- Lesson 22
IRB Written Procedures, Records, and Retention: 46.108 and 46.115
- 1. State the written procedures required by 46.108(a) and 56.108(a) and (b)
- 2. List the IRB records required by 46.115(a) and 56.115(a) and the retention period
- 3. Distinguish IRB retention from HIPAA, FDA investigator, and ICH retention periods
- Lesson 23
Conflict of Interest in Research: 42 CFR 50 Subpart F, 21 CFR 54, and IRB Members
- 1. State the PHS FCOI rule: SFI threshold, disclosure, determination, management, reporting
- 2. State the FDA financial disclosure requirements in 21 CFR 54
- 3. Apply the IRB member conflict rule in 46.107(e) and 56.107(e)
- Lesson 24
Reporting to OHRP and FDA, Compliance Oversight, and HRPP Education Programs
- 1. State what an institution must report to OHRP and FDA, when, and through whom
- 2. Describe OHRP and FDA compliance oversight processes and possible outcomes
- 3. Identify intersecting reporting obligations: ClinicalTrials.gov, FCOI, misconduct, state law
Module 4: Capstone: Exam Strategy and Mixed Review
Questions, corrections, or a topic the course should cover?
This course is for educational purposes only and is not legal, regulatory, or compliance advice. Regulations and guidance change, so confirm every requirement against the current eCFR text, OHRP and FDA guidance, and your institution's IRB policies before relying on it. CIP® is a registered certification mark of Public Responsibility in Medicine and Research (PRIM&R). This course is produced independently by Subthesis and is not affiliated with, endorsed by, or reviewed by PRIM&R or the CIP Council. The instructor is not a Certified IRB Professional. Completing this course does not confer CIP certification, satisfy CIP eligibility requirements, or count as CIP recertification continuing education.