Collaborative Research/Single IRBs/Reliance Agreements
Collaborative Research
Collaborative research is research that may be conducted by researchers from more than one institution at just one site or when researchers from multiple institutions conduct different parts of a protocol. For example, non-Emory investigators may assist the Emory study team in conducting a research study at Emory. Another example is when an Emory study team conducts research interventions but another institution conducts the data analysis.
A critical first step is to determine whether Emory or the external collaborators are considered "engaged" in human subjects research. We have created the Engagement Guidance Checklist to assist you in making this determination. Once you complete the checklist, upload it in the protocol section of the smart form. Reliance agreements are not required for sites and/or external collaborators when an Emory researcher is not engaged in human subjects research.
If you determine the external collaborator is engaged in human subjects research, you may add external collaborators to an Emory IRB approved study if the research is federally funded and the research was not determined to be exempt. There are other scenarios where we may agree to provide oversight for external collaborators. Reach out to the reliance team at IRB.reliance@emory.edu to determine if you can add the external collaborator(s).
If you want to add an external collaborator to an Emory IRB approved study, follow the steps below:
- Send an email to IRB.reliance@emory.edu with the following information:
- the completed engagement determination checklist (see link above)
- the completed External Study Team Member List template (use only one list per study and include all external study team members.)
- a link to the Insight submission
- We will review the information and determine if we need to contact the external study team member's home IRB for additional information. If the external study team member does not have a home IRB, we will execute an agreement with the individual rather than an institution.
- We will respond to your email with any questions and/or the completed reliance documents.
It is important to know that researchers at external institutions are likely required to submit a reliance request to their local IRB. This often results in significant delays that are outside the control of the Emory IRB. Once you have discussed reliance with the Emory IRB reliance team, be sure to encourage your external collaborators to reach out to their local IRBs to determine what they need to do.
NOTE: You cannot add external collaborators who want to conduct secondary data analysis of data collected in your study. That requires a separate IRB submission.
Multi-site Research
Multi-site research is research that is being conducted by more than one site. Each site carries out the full protocol at their site.
Reliance Agreements
Reliance agreements, also known as IRB Authorization Agreements (IAAs), are needed to document one institution's reliance on another institution's IRB or a commercial IRB. The reliance agreement documents the terms of the agreement including the roles, responsibilities, and communication plan between the reviewing IRB and the person or institution relying on that IRB.
Single IRBs
A single IRB is one IRB that provides ethical oversight to multiple sites conducting the same protocol involving human research participants. The goal of Single IRB Review is to streamline the IRB review process for domestic sites conducting the same research protocol without compromising ethical principles or the protection of human research participants.
Use of a single IRB is required for domesitc sites conducting multi-site non-exempt human subjects research funded by the NIH or by a federal Common Rule Agency unless the funding agency granted an exception from this requirement. The IRB at the prime awardee institution may serve as the single IRB or another academic or commercial IRB may serve in this role. IRBs have a choice about serving as the reviewing IRB for other sites. Research sites located outside of the United States obtain local ethics committee approvals and are not required to use the single IRB in the United States.
While it is beneficial to use Single IRB Review for some studies, it does not mean that relying institutions no longer complete any reviews of the research when relying on a single IRB. It simply means the relying institution's IRB is not providing approval of the research. The work that would normally take place at the Emory IRB when reviewing and approving research for Emory study teams is simply replaced with other work by the Emory IRB to ensure all local requirements are met and reliance agreements are executed.
Please review the accordions below for important guidance about the reliance process.
NOTE: For multisite, industry-sponsored trials, Emory uses commercial IRBs for review. See the submission guidance to WCG IRB (WIRB) or Advarra IRB for more information. For multi-site studies, please use the same IRB that the sponsor is using for other sites.
For important guidance about the reliance process, click on the panels below.
To avoid delays in processing your submission, read the following information carefully.
Emory will agree to rely on AAHRPP accredited IRBs for non-exempt research when the use of a single IRB is required by the Revised Common Rule or the NIH Single IRB Mandate.
Submit a cede review study (external IRB study) to the Emory IRB once the overall study (protocol) is approved by the reviewing IRB.
Submission Instructions:
- Under attachments, upload the most recent protocol approved by the reviewing IRB.
- Include the master consent form(s) approved by the reviewing IRB and the initial study-wide approval letter from when the protocol was first approved.
- Use this checklist (DOCX) to determine the Emory language to be inserted into the master consent form and upload the completed checklist.
- Using the completed checklist, insert Emory's required language into the approved master consent form(s) using TRACKED CHANGES and upload in the submission. Do not revise any other language in the approved master consent form.
- Upload any reliance documents provided by the reviewing IRB.
Once the submission is complete, the Emory IRB will conduct a local context review and execute the reliance agreement. Once the local context review is complete, the Emory IRB will issue institutional signoff.
Do not submit your site to the reviewing IRB for approval until you receive institutional signoff from Emory, even if Emory has already signed the reliance agreement.
Once your site has received approval from the reviewing IRB, upload the external IRB approval letter and stamped consent forms and submit back to the Emory IRB.
For all External IRB studies, follow the guidance below for Amendments, Continuing Reviews and Other Events (OEs).
IMPORTANT NOTES: For External IRB studies, you are required to adhere to Emory IRB policies and procedures in addition to the external IRB's policies. For example, even if the external IRB approves use of a lottery for compensation or cold-calling as a recruitment method, you must adhere to Emory's policies and procedures and you would not be able to implement these procedures. Please review the Emory IRB Policies and Procedures and the study submission guidance page of our website. If you still have questions after reading this information, email the reliance team at irb.reliance@emory.edu.
When Emory relies on an external IRB, it is the Emory PI's responsibility to provide the external IRB with all information provided by the Emory IRB at the time of institutional signoff, adhere to the determinations of the external IRB, respond to requests of the external IRB in a timely manner, and ensure all study team members maintain the required CITI training while working on the study.
Submit amendments to the Reviewing IRB per their policies and procedures.
(Note: Most reviewing IRBs do not review local study team changes, other than PI. However, you can create staff updates that are not for changes in PI at continuing review or whenever a study staff needs access to the submission in Insight.)
You must also promptly inform the Emory IRB of the following changes:
- adding or removing drugs or devices used in the study
- change of Emory PI
- changes to Emory-affiliated study sites
- changes in financial interests on the part of Emory investigators
- new funding
While these are the only types of changes to cede review studies that the Emory IRB must review at this time, it is important to note that you are required to adhere to Emory IRB policies and procedures in addition to the external IRB's policies.
For example, even if the external IRB approves use of a lottery for compensation or cold-calling as a recruitment method, you must adhere to Emory's policies and procedures and you would not be able to implement these procedures. Please review the Emory IRB Policies and Procedures and the study submission guidance page of our website. If you still have questions after reading this information, email the reliance team at irb.reliance@emory.edu.
Ancillary Review Changes: It is the responsibility of the Emory Principal Investigator to notify ancillary review committees if changes are made to approved research that may impact the reviews of these committees. Examples include, but are not limited to, changes relevant to radiation, conflict of interest, and biosafety review.
How to Submit Amendments to Emory IRB
After Go Live for Insight, you will need to email the reliance team at irb.reliance@emory.edu with the approval letters for any of the changes outlined above along with a description of the amendment. The IRB analyst will make the administrative updates as needed to the cede review submission.When Emory relies on another IRB (Reviewing IRB), the Reviewing IRB is responsible for conducting continuing reviews and study closeouts. Once your site has received continuing review approval from or the study has been closed by the Reviewing IRB, submit the IRB letter to the Emory IRB following the steps below.
Continuing Reviews
After Go Live in Insight, email the reliance team at irb.reliance@emory.edu with the CR approval letter and stamped consent forms. Include in the email if there have been any events or noncompliance reported to the reviewing IRB.
Closeouts
After Go Live in Insight, email the reliance team at irb.reliance@emory.edu with the closeout letter. The IRB analyst will close the study.
You must submit Other Events (OEs) to the Reviewing IRB according to the Reviewing IRB's policies and procedures.
Most OEs should be submitted to the Reviewing IRBonly.
However, some OEs must also be submitted to the Emory IRB (see below). If in doubt, report to Emory anything that Emory IRB would require to be reported, and if the Reviewing IRB's rules go beyond our requirements, you must follow their policies as well.
Notify the following of egregious OEs promptly:
- Emory IRB
- Reviewing IRB
Note: Some events will also require reporting to the Emory Office of Research Integrity and Compliance and the Emory Risk Management offices (Emory Healthcare).
The IRB can assist in determining what types of reports are required, so please reach out immediately in the above scenarios.
Examples of egregious OEs:
- Internal (at this site) death related or possibly related to the research
- Surgery on the wrong side
- Drug provided to the wrong patient or a patient received the wrong drug
- Fabrication, plagiarism, or falsification of data
- HIPAA privacy matter (report any inadvertent data disclosure and we will help determine further actions)
- Study Suspension (related to compliance concerns)
How to submit OE: Click on "Create Other Event" on the left menu of the study workspace in Insight.
- Egregious events (reported promptly): Upload a copy of the report(s) made to the reviewing IRB, and any correspondence from the reviewing IRB (but do not delay to wait for their determination).
See our submissions guidance table (PDF).
The Emory IRB is now serving as the single IRB for multi-site federally funded non-exempt research when Emory is the prime awardee of the grant for studies including no more than five domestic sites.
If you are planning to submit a grant for a multi-site research study or are collaborating with a small business on an SBIR/STTR grant, please contact the Reliance Team early in the process to discuss options for the single IRB.
The Emory IRB has a choice about whether to serve as the single IRB for a multi-site study, and there are important factors for investigators to consider when choosing the single IRB for their projects.
You will need to schedule time to meet with the reliance team to discuss the research activities that will be conducted, the sites you plan to include and the impacts on your study team. You can contact the reliance team at irb.reliance@emory.edu.
There are several options for the single IRB of record (Reviewing IRB).
- Commercial IRB such as WCG IRB or Advarra
- Emory IRB
- Another Academic IRB
Below are documents you may need to complete and include with your grant application.
- Single IRB Plan instructions/guidance
- Single IRB Plan template
- Communication Plan template
- Sample of Completed Communication Plan
Single IRB Fees
Some academic IRBs, including the Emory IRB, charge fees for serving as the reviewing IRB for multi-site studies. Be sure to inquire about review fees and include the cost of the reviews in your budget.
If WCG IRB will be the single IRB, follow the instructions at the top of this Single IRB Quote Request Form to get a quote from WCG IRB.
Quotes for single IRB fees are based on the assumptions provided, and the study will only be billed for the services that are rendered. Also, keep in mind that if translations are needed, the cost of translation is an extra charge that you will want to include in your budget.
SMART IRB is the term for the Streamlined, Multisite, Accelerated Resources for Trials IRB Reliance platform. It is a master reliance agreement that uses a harmonized set of standard operating procedures. Institutions no longer need to use institution-specific reliance agreements that require review by legal departments on a study by study basis.
How does it work?
As part of SMART IRB, institutions may choose to rely on another IRB to review, approve, and oversee a research study.
The Reviewing IRB (often referred to as the single IRB sIRB) provides ethical review of the research for the life of the study. Relying Institutions provide local context information about state law, study team member training and qualifications, any applicable conflict of interests and any applicable ancillary reviews.
Investigators and institutions retain their respective responsibilities for the protection of human subjects, compliance with applicable laws, regulations, ethical standards, and the terms of the institution's FWA.
For more information, go to the SMART IRB website.
When Emory and CHOA are both engaged in the same research, the type of research and the funding source determine the IRB that will review it. Use this flowchart to determine which IRB will review the study.
Always submit this form to the Children's IRB even when Emory is the IRB of record: CHOA IAA Acknowledgement Form (DOCX)
Send general questions to irb.reliance@emory.edu.
If you have questions about a specific study at Emory that is ongoing, please contact the IRB analyst assigned to your study.
WCG IRB (WIRB, WCG, CGIRB, etc.)
In 2020, after integrating WIRB with four leading independent IRBs (Copernicus Group IRB, New England IRB, Aspire IRB, and Midlands IRB), WIRB became known as WCG IRB.
Emory has designated WCG IRB as its IRB for
- Industry-funded, designed, and sponsored clinical trials (Phases I to IV).
- Multi-site collaborative research that requires Single IRB review per NIH policy.
For WCG studies, the Emory study team completes the submission to WCG IRB through the Connexus online system and WCG IRB conducts the ethical review on behalf of Emory.
Study teams must also submit an external IRB (cede review) submission to the Emory IRB so that Emory can track the research conducted at Emory and ensure all local requirements are met.
WCG IRB (Formerly WIRB)
WCG IRB is a commercial IRB that is not affiliated with Emory University.
Emory IRB's role in WCG IRB-reviewed studies
As with other external IRB studies, the Emory IRB analyst assistant assigned to the study will verify that all local institutional requirements are met via a local eIRB submission, including
- study team training requirements
- ancillary committee reviews
Studies that may be reviewed by WCG IRB:
- All NEW Phase I-through-IV drug or analogous device studies that are industry-designed, initiated, and sponsored will be sent to WCG IRB for review (with a few exceptions listed below). Note, the Emory IRB reserves the right to withhold any new research study from being sent to WCG IRB.
- Federally funded studies where use of a single IRB is required and the funding agency or lead study team has chosen WCG IRB to serve in that role.
Studies that cannot be sent to WCG IRB (unless used to comply with NIH's sIRB mandate):
- Investigator-initiated
- Cooperative Group-led/coordinated
- Industry-funded studies for which an Emory PI holds the IND/IDE
- Those with the Atlanta VAMC as a study site
Note: If an industry sponsor is using an IRB other than WCG IRB, you will need to use the IRB chosen by the sponsor.
Follow the submission guidance under the "Emory Relying on External IRBs (cede review)" tab.
Fees associated with WCG IRB review
Please contact clientservices@wirb.com for current WCG IRB fees. (Please note: Emory charges an administrative fee of $550, plus 30% indirect cost, for all WCG IRB initial review submissions.)
For grant-funded multi-site studies that will be sent to WCG IRB, it is very important to calculate the cost of single IRB review into the budget that is submitted with the grant application. Follow the instructions at the top of this Single IRB Quote Request Form (PDF) to obtain a quote.
- Who should we list as "contacts" on the initial submission form?
You should add the Principal Investigator and one other contact, usually the Study Coordinator, as contact people in the initial form. You may ask Client Services if you want to add more staff members to the list, but no more than 15 people.
- What if I forgot a document in my initial submission?
If you submitted your study documents and later realized you forgot an important document, email Jonathan Gellert (information below) and he will add the information to their internal documents.
- How do I fill out the "billing" section of my application?
You are required to complete the billing section of the application. At this time, ALL studies should state that WCG IRB should bill the sponsor when there is one.
- How can I tell if my submission is completed correctly?
At the very end of the initial review form there is a button to validate the document and it will highlight the missing items.
- How do I identify Emory as the local institution when submitting a study via Connexus?
When submitting through Connexus, the study team can ensure that WCG IRB links the study to Emory's research program by naming "Emory University" as the institution which has a contract to use WCG IRB for IRB services. The Emory IRB institution number is 62571.
- How can I check the status of my submission once the study has been submitted to WCG IRB, including when the study seems to be delayed?
WCG IRB timeline for the review of a study starts with the assignment of the study to a WCG IRB staff member within the first 24 hours. Within 48 hours, the WCG IRB analyst will send the study staff a list of issues that need to be reconciled, including the institutional sign-off required by Emory. Once all the issues have been reconciled, the study is sent to review. Contact Jonathan Gellert at JGellert@wcgclinical.com for a breakdown on the timeline of your specific study. For all inquiries, please contact our WCG IRB contact Jonathan Gellert or email clientservices@wirb.com.
WCG IRB has advised emailing a list of current staff members to client services or Jonathan Gellert directly asking them to confirm its accuracy. WCG IRB will email you back confirming the personnel listed in your list.
Emory WCG IRB Contacts
- WCG IRB Listserv
- One of the Analyst Assistants listed on the IRB Staff webpage
- Julie Martin (Team Lead) at julie.t.martin@emory.edu
WIRB Contact
Jonathan Gellert (Institutions Partnership Manager)
- Email: jgellert@wirb.com
- Phone: 1-855-818-2289
National Cancer Institute Central Institutional Review Board (NCI CIRB)
National Cancer Institute eligible studies are sent to the NCI CIRB for IRB review.
NCI CIRB is the central institutional review board for the National Cancer Institute. For more information, visit:
National Cancer Institute - Central IRB WebsiteThe NCI CIRB is the IRB of record for many NCI-funded cooperative group studies. The NCI CIRB may review the following type of studies:
- Adult CIRB - Late Phase Emphasis - reviews NCI-sponsored adult phase 3 and large phase 2 studies
- Adult CIRB - Early Phase Emphasis - reviews NCI-sponsored adult phase 0, 1, and 2 studies
- Pediatric CIRB - reviews NCI-sponsored pediatric studies of all phases
Please review the NCI CIRB's guidance for new users as well as guidance on when to use the NCI CIRB, IRB Manager and CTSU websites.
You can find an overview of the NCI CIRB's study review process here.
After reviewing this information, send an email to irb.reliance@emory.edu if you need to be added to the NCI CIRB roster.
NCI CIRB limits changes to consent forms. Please review the NCI CIRB's Guidelines for Permitted Boilerplate Language Additions and Boilerplate language Q & A for more information.
Please note:
- The NCI CIRB requires a stand-alone HIPAA authorization document separate from the consent form.
- The NCI CIRB does not allow changes in the main consent form, other than injury coverage language.
- Study teams must use Emory's Site-Specific Consent-HIPAA Addendum.
- Use Emory's latest consent section table (DOCX) when modifying the main consent, and creating the Emory addendum.
- Study teams may also use our Withdrawal-Revocation Letter Template (DOCX), at any time. It does not require IRB review or stamping.
- The NCI CIRB does not review Assent forms. Use our usual Assent template for your CIRB studies, and submit with the above (see Consent Toolkit section of our website).
- Do not submit these additional Emory-specific forms to NCI CIRB. Just upload them in your Emory cede review submission.
- The Emory IRB will stamp the additional Emory-specific documents with the NCI CIRB approval date at initial review, but will not re-stamp unless they change (e.g. due to change in PI).
- If using remote consent, you must comply with the NCI CIRB's Policy on remote consent as cited in section 2.3.8 of the NCI CIRB SOPs which you can view at https://ncicirb.org/about-cirb/sops. If you are unable to document the reason for using remote consent under the signature line due to the electronic method you are using, please document the required information for 2.3.8.7.3 in a note to file (NTF) and retain in your regulatory binder.
After NCI CIRB Approval: Upload the NCI-CIRB-approved consent form to your submission and provide them to other Emory offices (such as OCR) ALONG WITH the NCI CIRB approval letter with the consent form's version date, so that Emory offices can cross-check the two.
The Emory IRB does NOT stamp the NCI-CIRB-approved consent forms, but does stamp the Site Information and HIPAA Authorization form. We will also restamp older combination forms at amendment and renewal.
*For VA studies, the consent forms will continue to be stamped with Emory's date of acknowledgement. For VA studies only, you should continue to put the main NCI CIRB consent forms on the document stamping template.
- Contact the CIRB Helpdesk at 1-888-657-3711I if you have any questions regarding the use of a new Change of PI worksheet.
- Don't forget to submit an amendment to update the PI and to revise the Site Information and HIPAA Authorization if the site is still enrolling. Contact the reliance team with any questions at irb.reliance@emory.edu.
NCI CIRB will notify the study team of any amendments to the overall study.
Amendments that require submission to NCI CIRB and Emory IRB
- Changes to PI
- Changes to Emory consent form language (changes to add or remove references to affiliate sites anywhere Emory is listed) in the main consent form (not just in the Emory addendum)
Amendments that require review by Emory IRB only:
- Changes to study staff that require immediate access to the cede review submission (other staff changes are reported at CR)
- Changes to research sites (after CTSU has been updated with site changes)
- Changes to the Site Information and HIPAA Authorization form
- Changes to the protocol approved by the CIRB that require new ancillary reviews at Emory (Examples: addition of radiation, addition of software or electronic data capture that requires review by OIT, a new Emory study team member COI, etc.)
How to Submit changes to the Emory IRB in eIRB
After Go Live in Insight, you will need to email the reliance team at irb.reliance@emory.edu with the approval letters for any of the changes outlined above along with a description of the amendment. The IRB analyst will make the administrative updates as needed to the cede review submission.
- Step 1: Submit renewal documents to the appropriate cooperative group when requested
- Step 2: Once your site has received the continuing review approval or study closeout letter from the NCI CIRB, next steps depend on whether you are the PI or a Co-I/Coordinator...
If you are the PI, select "Report Continuing Review Data" on the left menu in the study workspace in eIRB to update the Emory IRB, and submit the documents listed below.
If you are not the PI, submit the below items via "Log Comment" and select that you want to notify the IRB Coordinator.
Please submit the following to the Emory IRB:
- The renewal approval or study closeout letter from the reviewing IRB.
- Updates to local study team members (that have not already been reported)
- This must be done via a simultaneous study update (see Modifications section above)
- A summary of all internal Reportable New Information (RNIs) submitted to the reviewing IRB since the last review, if any (and if not already reported promptly).
- RNIs include but are not limited to unanticipated problems that increase risk of harm to others, noncompliance, breaches of confidentiality, wrong site surgeries, wrong drug administered, wrong patient, fabrication of data and falsification of data.
- In the summary, provide the outcome of the reviewing IRB's review (e.g. "Noncompliance," "Serious noncompliance," "Unanticipated Problem"...)
- Note: The reviewing IRB may call these submissions something different, e.g. "Reportable Events"
- Upload a copy of the report(s) submitted to the reviewing IRB.
- Attach the completed CR workbook (Excel file).
NOTE: The Emory IRB will not restamp any consent documents except older consent-HIPAA combination forms.
You must submit Reportable New Information (RNIs) to the NCI CIRB according to the NCI CIRB's policies and procedures. You can find the requirements under the CIRB's "CIRB Standard Operating Procedures" (under CIRB STANDARD OPERATING PROCEDURES entitled UNANTICIPATED PROBLEMS AND SERIOUS OR CONTINUING NONCOMPLIANCE).
Check with your CIRB contact or email the CIRB helpdesk for more information about reporting mechanisms.
Most RNIs should be submitted to the Reviewing IRB only.
However, some RNIs must also be submitted to the Emory IRB (see below). If in doubt, report to Emory anything that Emory IRB would require to be reported, and if the Reviewing IRB’s rules go beyond our requirements, you must follow their policies as well.
Notify the following of egregious RNIs promptly
- Emory Office of Compliance
- Emory Risk Management Office
- Emory IRB
- Reviewing IRB
Examples of egregious RNIs:
- Internal (at this site) death related or possibly related to the research
- Surgery on the wrong side
- Drug provided to the wrong patient or a patient received the wrong drug
- Fabrication, plagiarism, or falsification of data
- HIPAA privacy matter (report any inadvertent data disclosure and we will help determine further actions)
- Study Suspension (related to compliance concerns)
How to submit RNI: Click on "Report New Information" on the left menu of the study workspace in eIRB.
- Egregious events (reported promptly): Upload a copy of the report(s) made to the reviewing IRB, and any correspondence from the reviewing IRB (but do not delay to wait for their determination).
- Events reported to the External IRB in the past approval period: submit a CR update clicking on under the study history. Under question 4, attach the filled CR workbook (Excel File).
Advarra IRB
Advarra is a commercial IRB and is not affiliated with Emory University. Emory has agreed to rely on the Advarra IRB for some multi-site industry sponsored clinical trials and for federally funded research when use of a single IRB is required and Advarra has been chosen as the single IRB.
When using Advarra as the single IRB, the Emory study team must first submit an external IRB (XIRB) submission to the Emory IRB to ensure local requirements are met and will then submit to Advarra through the online CIRBI system.
Follow the submission guidance under the "Emory Relying on Extenal IRBs" tab.
Even though the Advarra IRB is considered the single IRB of record for the study, Emory study teams are responsible for reporting certain information to the Emory IRB for the life of the study. Click on the tabs below to learn more about these reporting requirements.
Advarra IRB
For studies reviewed by Advarra, the protocol-level review for the lead site/sponsor should already be completed, and Emory is simply added as an additional study site via amendment. Learn more from Advarra's website.
What is Emory IRB's role in Advarra-reviewed studies?
As in other external IRB (cede review) studies, Emory IRB will verify that all local institutional requirements are met via a local eIRB submission, including
- Study team training requirements
- Ancillary committee reviews
- External IRB Consent Checklist (DOCX)
- IRB Handbook (Reference Materials section of the Advarra CIRBI Platform)
- Advarra promptly reportable information form (Reference Materials Section of the Advarra CIRBI Platform)
Advarra Contacts
- For very general questions, view the General Contacts page.
- For questions contact Amanda Page at Amanda.Page@advarra.com.
- For questions regarding a specific Advarra submission, contact the Your Advarra analyst assigned to your study.