The January 20, 2020 compliance date for the single IRB requirement for cooperative research at §46.114(b) of the revised Common Rule is only a few short days away.  While it is HRP’s understanding that OHRP intends to issue guidance about this provision, that guidance is not anticipated before January 20th. Here are a few key points for human research protection professionals to keep in mind: The scope of the revised Common Rule provision is broader than NIH’s sIRB policy which excludes certain award types The definition of “cooperative research” in the revised Common Rule is not the same as “multi-site study” in the NIH policy (see below), there is no reference to use of the same protocol. Revised Common Rule: “Cooperative research projects are those projects covered by this policy...