The IRB not only reviews and approves human subjects research subject to the federal regulations, it also review several other types of applications for activities that do not require IRB approval. While not approving these activities, the IRB does acknowledge that they agree with the investigator's determination that the research does not require IRB review and approval.
Not Human Subjects ResearchMany activities that take place at CHOP and similar institutions is not research or if it is research, does not meet the definition of human subjects research.
HIPAA Attestations HIPAA permits the use of personal health information without requiring an authorization for Work Preparatory to Research and for research limited to the use of Decedents. Investigators must submit an attestation to the IRB prior to beginning either type of work.
Exempt Research Human subjects research in several categories, that has minimal risk and meets the exemption criteria per 45 CFR 46.104(d). At CHOP, the IRB is required to review applications for Exempt research and to make a determination that it agrees (or not) with the investigator's own determination.