Creates IRB submission packages with protocol summaries, consent forms, and risk-benefit analysis. Use when submitting to IRB, preparing ethics applications, or writing consent documents.
Every human-subjects research study in the United States requires IRB review under the Common Rule (45 CFR 46) and, for FDA-regulated research, 21 CFR Parts 56 and 50. Incomplete or non-compliant submissions cause weeks of delays, stalling enrollment timelines and burning sponsor confidence. This skill encodes the complete IRB submission package assembly workflow so that initial submissions, amendments, and continuing reviews meet institutional and federal requirements on the first pass.
Checkpoint A — Intake and Scoping
Before drafting any submission documents, confirm:
Required Intake Questions
What type of IRB review is needed (initial, amendment, continuing review, reportable event, closure)?
Which IRB has jurisdiction (institutional IRB, central/commercial IRB such as WCG, Advarra)?
Is the study FDA-regulated (IND, IDE) or non-regulated?
Does the study qualify for exempt or expedited review per 45 CFR 46.104 or 46.110 categories?
Does the study involve vulnerable populations (children, prisoners, pregnant women, cognitively impaired)?
Is this a single-site or multi-site study? If multi-site, is a single-IRB arrangement required per the 2018 Common Rule revision?
What is the funding source (federal, industry, foundation)?
Are there HIPAA considerations requiring a separate authorization or waiver?
Is a Data Use Agreement (DUA) or Material Transfer Agreement (MTA) involved?
Conflict-of-interest disclosures (financial and non-financial)
Data management and safety monitoring plan
Sponsor-investigator agreements (if applicable)
Certificate of Confidentiality (if applicable)
Step 1 — Determine Review Category
Classify the study into the correct regulatory category:
Exempt (45 CFR 46.104): Educational research, surveys/interviews with non-identifiable data, benign behavioral interventions, secondary research on existing data. Note: exempt does not mean no review — the IRB or designee must confirm exemption.
Expedited (45 CFR 46.110): Minimal-risk research fitting one of the nine expedited categories (e.g., collection of small blood volumes, non-invasive data collection, research on existing specimens). Document which specific category applies.
Full Board: Greater-than-minimal-risk research, or any study involving vulnerable populations where expedited review is insufficient. Requires convened IRB quorum with at least one non-scientist member.
Flag studies that the PI believes are exempt but that may actually require expedited or full review due to identifiability, sensitive topics, or deception.
Step 2 — Draft Protocol Summary for IRB
Create a lay-language protocol summary (distinct from the full protocol) that addresses IRB reviewers' key concerns:
Study purpose: One-paragraph plain-language description of the research question
Background and rationale: Why this research is needed; gap in current knowledge
Study design: Type (RCT, observational, qualitative), arms, blinding, duration
Study population: Target N, key eligibility criteria, recruitment strategy
Study procedures: What participants will experience at each visit — described in participant-facing language
Risks: Enumerate known risks by likelihood and severity; distinguish drug-related, procedure-related, and privacy risks
Benefits: Direct benefits to participants (if any) and benefits to society; do not overstate therapeutic benefit for early-phase studies
Risk-benefit analysis: Explicit statement that risks are minimized and reasonable in relation to anticipated benefits and the importance of the knowledge to be gained (45 CFR 46.111(a)(2))
Alternatives: What alternatives to participation exist (standard treatment, other studies, no treatment)
Data confidentiality protections: De-identification methods, data storage security, access controls, Certificate of Confidentiality status
Step 3 — Prepare Informed Consent Document
Draft the consent form per 45 CFR 46.116 required elements and 21 CFR 50.25 (if FDA-regulated):
Eight Required Elements (45 CFR 46.116(b))
Statement that the study involves research; explanation of purposes, expected duration, procedures
Description of reasonably foreseeable risks or discomforts
Description of benefits to subject or others
Disclosure of appropriate alternative procedures or treatments
Description of confidentiality protections
For more-than-minimal-risk research: explanation of compensation and treatment availability for injury
Contact information for questions about research, rights, and research-related injury
Statement that participation is voluntary; refusal involves no penalty
Additional Elements When Appropriate (45 CFR 46.116(c))
Emergency research (21 CFR 50.24): Exception from informed consent with community consultation documentation
Step 4 — Compile HIPAA Documentation
If the study involves protected health information (PHI):
HIPAA Authorization: Standalone or embedded in consent; must specify PHI elements, who will access, purpose, expiration
Waiver of Authorization (45 CFR 164.512(i)): If seeking waiver, document that (1) use involves no more than minimal risk to privacy, (2) research could not practicably be conducted without waiver, (3) adequate plan to protect identifiers and destroy them at earliest opportunity
Limited Data Set with Data Use Agreement: Alternative to full waiver for research using dates and geographic data
Step 5 — Prepare Supplementary Materials
Assemble all ancillary documents:
Recruitment materials: Advertisements, social media posts, screening scripts — all must be IRB-approved before use
Questionnaires and survey instruments: Include validated instruments with permission documentation
Investigator qualifications: Current CVs (NIH biosketch or sponsor format), medical licenses, GCP training certificates
Financial disclosure: Per 42 CFR Part 50 (PHS-funded) or 21 CFR 54 (FDA-regulated) — significant financial interests >$5,000
Vulnerable-population protections match the actual study population
Consent form version number and date are in the footer of every page
Contact information includes three required contacts (PI, IRB, institutional representative)
All referenced attachments are actually included in the submission package
No exculpatory language exists in the consent form (prohibited by 45 CFR 46.116)
Sponsor-required language does not conflict with federal requirements
All [VERIFY] flags have been resolved or escalated
Guidelines
Never include exculpatory language in consent forms — statements that waive participant rights or release investigators from liability are prohibited under 45 CFR 46.116
Consent forms must be understandable to a lay audience; avoid medical jargon or define it in parentheses
Risk descriptions must be specific and quantified where possible (e.g., "nausea occurs in approximately 15% of patients" not "nausea may occur")
Do not promise therapeutic benefit in Phase I studies — use language like "this study is not designed to treat your condition"
For multi-site studies under single-IRB arrangements, identify the reviewing IRB and document reliance agreements
IRB submissions are living documents — amendments must be submitted before implementing any change (except to eliminate immediate hazards per 21 CFR 56.108(a)(4))
Recruitment material review by the IRB is required before any advertising begins
When consent processes involve electronic consent (eConsent), ensure 21 CFR Part 11 compliance for electronic signatures
Mark any uncertain risk characterization with [VERIFY] for PI review
This skill produces submission drafts — final approval requires PI signature and IRB determination
1---2name: writing-irb-submissions3description: Creates IRB submission packages with protocol summaries, consent forms, and risk-benefit analysis. Use when submitting to IRB, preparing ethics applications, or writing consent documents.4tags:5 - drafting6 - clinical-research7 - risk8metadata:9 author: casemark10 practice_areas:11 - Clinical Research12 - Biostatistics13 - Regulatory Affairs14 document_types:15 - Written Document16 skill_modes:17 - Drafting18---1920# Writing IRB Submissions2122## Why This Skill Exists2324Every human-subjects research study in the United States requires IRB review under the Common Rule (45 CFR 46) and, for FDA-regulated research, 21 CFR Parts 56 and 50. Incomplete or non-compliant submissions cause weeks of delays, stalling enrollment timelines and burning sponsor confidence. This skill encodes the complete IRB submission package assembly workflow so that initial submissions, amendments, and continuing reviews meet institutional and federal requirements on the first pass.2526---2728## Checkpoint A — Intake and Scoping2930Before drafting any submission documents, confirm:3132### Required Intake Questions331. What type of IRB review is needed (initial, amendment, continuing review, reportable event, closure)?342. Which IRB has jurisdiction (institutional IRB, central/commercial IRB such as WCG, Advarra)?353. Is the study FDA-regulated (IND, IDE) or non-regulated?364. Does the study qualify for exempt or expedited review per 45 CFR 46.104 or 46.110 categories?375. Does the study involve vulnerable populations (children, prisoners, pregnant women, cognitively impaired)?386. Is this a single-site or multi-site study? If multi-site, is a single-IRB arrangement required per the 2018 Common Rule revision?397. What is the funding source (federal, industry, foundation)?408. Are there HIPAA considerations requiring a separate authorization or waiver?419. Is a Data Use Agreement (DUA) or Material Transfer Agreement (MTA) involved?4210. What is the anticipated date of first enrollment?4344### Required Source Documents45- Final or near-final protocol (version-controlled)46- Investigator's Brochure (for IND/IDE studies)47- Draft informed consent form(s)48- HIPAA authorization or waiver request49- Recruitment materials (flyers, scripts, advertisements)50- Investigator CVs and medical licenses51- Conflict-of-interest disclosures (financial and non-financial)52- Data management and safety monitoring plan53- Sponsor-investigator agreements (if applicable)54- Certificate of Confidentiality (if applicable)5556---5758## Step 1 — Determine Review Category5960Classify the study into the correct regulatory category:6162- **Exempt** (45 CFR 46.104): Educational research, surveys/interviews with non-identifiable data, benign behavioral interventions, secondary research on existing data. Note: exempt does not mean no review — the IRB or designee must confirm exemption.63- **Expedited** (45 CFR 46.110): Minimal-risk research fitting one of the nine expedited categories (e.g., collection of small blood volumes, non-invasive data collection, research on existing specimens). Document which specific category applies.64- **Full Board**: Greater-than-minimal-risk research, or any study involving vulnerable populations where expedited review is insufficient. Requires convened IRB quorum with at least one non-scientist member.6566Flag studies that the PI believes are exempt but that may actually require expedited or full review due to identifiability, sensitive topics, or deception.6768---6970## Step 2 — Draft Protocol Summary for IRB7172Create a lay-language protocol summary (distinct from the full protocol) that addresses IRB reviewers' key concerns:73741. **Study purpose**: One-paragraph plain-language description of the research question752. **Background and rationale**: Why this research is needed; gap in current knowledge763. **Study design**: Type (RCT, observational, qualitative), arms, blinding, duration774. **Study population**: Target N, key eligibility criteria, recruitment strategy785. **Study procedures**: What participants will experience at each visit — described in participant-facing language796. **Risks**: Enumerate known risks by likelihood and severity; distinguish drug-related, procedure-related, and privacy risks807. **Benefits**: Direct benefits to participants (if any) and benefits to society; do not overstate therapeutic benefit for early-phase studies818. **Risk-benefit analysis**: Explicit statement that risks are minimized and reasonable in relation to anticipated benefits and the importance of the knowledge to be gained (45 CFR 46.111(a)(2))829. **Alternatives**: What alternatives to participation exist (standard treatment, other studies, no treatment)8310. **Data confidentiality protections**: De-identification methods, data storage security, access controls, Certificate of Confidentiality status8485---8687## Step 3 — Prepare Informed Consent Document8889Draft the consent form per 45 CFR 46.116 required elements and 21 CFR 50.25 (if FDA-regulated):9091### Eight Required Elements (45 CFR 46.116(b))921. Statement that the study involves research; explanation of purposes, expected duration, procedures932. Description of reasonably foreseeable risks or discomforts943. Description of benefits to subject or others954. Disclosure of appropriate alternative procedures or treatments965. Description of confidentiality protections976. For more-than-minimal-risk research: explanation of compensation and treatment availability for injury987. Contact information for questions about research, rights, and research-related injury998. Statement that participation is voluntary; refusal involves no penalty100101### Additional Elements When Appropriate (45 CFR 46.116(c))102- Unforeseeable risks (e.g., reproductive risks, unknown long-term effects)103- Circumstances for investigator termination of participation104- Additional costs to participant105- Consequences of withdrawal and procedures for orderly termination106- Notification of significant new findings during the study107- Approximate number of participants108109### Special Consent Provisions110- **Children** (45 CFR 46 Subpart D): Assent form (age-appropriate language, typically 7–12 and 13–17 versions) plus parental/guardian permission111- **Non-English speakers**: Consent translation with back-translation verification; short-form consent process per 21 CFR 50.27112- **Cognitively impaired**: Legally authorized representative (LAR) consent procedures113- **Emergency research** (21 CFR 50.24): Exception from informed consent with community consultation documentation114115---116117## Step 4 — Compile HIPAA Documentation118119If the study involves protected health information (PHI):120121- **HIPAA Authorization**: Standalone or embedded in consent; must specify PHI elements, who will access, purpose, expiration122- **Waiver of Authorization** (45 CFR 164.512(i)): If seeking waiver, document that (1) use involves no more than minimal risk to privacy, (2) research could not practicably be conducted without waiver, (3) adequate plan to protect identifiers and destroy them at earliest opportunity123- **Limited Data Set with Data Use Agreement**: Alternative to full waiver for research using dates and geographic data124125---126127## Step 5 — Prepare Supplementary Materials128129Assemble all ancillary documents:1301311. **Recruitment materials**: Advertisements, social media posts, screening scripts — all must be IRB-approved before use1322. **Questionnaires and survey instruments**: Include validated instruments with permission documentation1333. **Investigator qualifications**: Current CVs (NIH biosketch or sponsor format), medical licenses, GCP training certificates1344. **Financial disclosure**: Per 42 CFR Part 50 (PHS-funded) or 21 CFR 54 (FDA-regulated) — significant financial interests >$5,0001355. **Sponsor agreements**: Clinical trial agreements, budgets affecting conflict assessment1366. **Data and Safety Monitoring Plan (DSMP)**: Required for all NIH-funded clinical trials; describe monitoring entity, frequency, stopping rules137138---139140## Step 6 — Complete IRB Application Form141142Fill in the institution-specific or central-IRB application addressing:143144- Study title, PI information, co-investigators, study team roles145- Funding source and grant/contract number146- IND/IDE number (if applicable)147- Study sites and single-IRB documentation148- Participant population characteristics149- Recruitment methods and locations150- Consent process description (who obtains, where, waiting period)151- Data management and storage plan152- Conflict-of-interest attestations153- CITI training completion dates for all study personnel154155---156157## Checkpoint B — Pre-Submission Review158159Before submitting the package to the IRB, verify:1601611. [ ] All eight required consent elements are present and in lay language (8th-grade reading level target)1622. [ ] Risk-benefit analysis is explicit and balanced — not promotional1633. [ ] HIPAA documentation matches the data elements actually collected1644. [ ] Recruitment materials do not overstate benefits or use coercive language1655. [ ] All study personnel have current GCP/CITI training1666. [ ] Financial disclosures are complete and consistent with institutional COI records1677. [ ] Protocol version matches the consent form version1688. [ ] If amendment: tracked-changes version of consent and protocol are included with summary of changes1699. [ ] If continuing review: enrollment numbers, adverse events, and protocol deviations are summarized17010. [ ] Application form is complete — no blank required fields171172---173174## Quality Audit175176- [ ] Consent form reading level has been assessed (Flesch-Kincaid or SMOG formula)177- [ ] Regulatory citations (45 CFR 46, 21 CFR 50/56, HIPAA) are correctly applied178- [ ] Vulnerable-population protections match the actual study population179- [ ] Consent form version number and date are in the footer of every page180- [ ] Contact information includes three required contacts (PI, IRB, institutional representative)181- [ ] All referenced attachments are actually included in the submission package182- [ ] No exculpatory language exists in the consent form (prohibited by 45 CFR 46.116)183- [ ] Sponsor-required language does not conflict with federal requirements184- [ ] All [VERIFY] flags have been resolved or escalated185186---187188## Guidelines1891901. Never include exculpatory language in consent forms — statements that waive participant rights or release investigators from liability are prohibited under 45 CFR 46.1161912. Consent forms must be understandable to a lay audience; avoid medical jargon or define it in parentheses1923. Risk descriptions must be specific and quantified where possible (e.g., "nausea occurs in approximately 15% of patients" not "nausea may occur")1934. Do not promise therapeutic benefit in Phase I studies — use language like "this study is not designed to treat your condition"1945. For multi-site studies under single-IRB arrangements, identify the reviewing IRB and document reliance agreements1956. IRB submissions are living documents — amendments must be submitted before implementing any change (except to eliminate immediate hazards per 21 CFR 56.108(a)(4))1967. Recruitment material review by the IRB is required before any advertising begins1978. When consent processes involve electronic consent (eConsent), ensure 21 CFR Part 11 compliance for electronic signatures1989. Mark any uncertain risk characterization with [VERIFY] for PI review19910. This skill produces submission drafts — final approval requires PI signature and IRB determination
Run npx skillmds@latest add lev-os/writing-irb-submissions in your terminal (requires Node.js), paste this page's agent-chat prompt into Claude, Cursor, or any MCP-connected agent, or download the SKILL.md file and copy it into your agent's skills directory.
Creates IRB submission packages with protocol summaries, consent forms, and risk-benefit analysis. Use when submitting to IRB, preparing ethics applications, or writing consent documents. It is listed under Coding & Dev Tools on SkillMD.
This skill has not completed SkillMD's automated safety review yet. Independent scanners report: SkillSpector: PASS, Skill Scanner: PASS. Capability flags: docs only. SkillMD never runs a skill's scripts for you; review the SKILL.md before installing.
This skill is tagged as working with Claude Code, Claude.ai, OpenAI Codex. SKILL.md is an open format, so most agents that read a skills directory can load it too.
Yes. Installing skills from SkillMD is free, and the skill stays under its author's original license.
lev-os (@lev-os) published this skill. Their other Agent Skills are listed on their SkillMD profile.