Is it possible for an institution to review different federally-funded research projects under different versions of the Common Rule?

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The correct understanding is that an institution can indeed review different federally-funded research projects under different versions of the Common Rule. The Common Rule, which is a federal regulation regarding the protection of human subjects in research, has undergone revisions, with the most significant updates implemented in 2018. Institutions have the option to adopt the new version or continue to adhere to the previous version for certain studies, especially if those studies were initiated prior to the new rule's implementation. This flexibility allows for a transitional approach, wherein ongoing projects may still follow earlier guidelines while new projects may comply with the updated regulations.

The nature of federal funding does not dictate that all research must be uniformly assessed under the newest version of the Common Rule, hence allowing institutions to adapt their review processes to fit the context of each project. This multifaceted approach acknowledges the varying stages of research and funding timelines, ultimately ensuring that human subject protections remain effective regardless of regulatory version applied.

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