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If the only involvement of a County facility in a project is in the initial identification and recruitment of subjects, is IRB approval required?

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If the only involvement of a County facility in a project is in the initial identification and recruitment of subjects, is IRB approval required?

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All organized recruitment of potential research subjects at Bureau facilities must be reviewed. Organized recruitment would include contacting patients whose names have been extracted from medical records; stationing recruiters in clinic waiting rooms or other hospital areas; posting flyers or handing out recruiting leaflets on site. This is in contrast to an individual physician informing a patient during a clinical interaction about a research study that is available at another institution. As long as only descriptive information is given to the patient ( i.e., a summary of the research and the name and phone number of the physician conducting the trial), without any implied endorsement of the research, this interaction is considered to be a clinical referral, not organized recruitment.

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