RESEARCH TRAINING REQUIREMENTS FOR EXTERNAL INVESTIGATORS
An external investigator (EI) is any individual who is not a LSUHSC-NO employee, faculty or student, but is engaged in a HSC-associated human subjects research (HSR) study or is a key personnel in the study.
When the LSUHSC IRB is not the IRB of Record for the EI, no documentation is required in the Kuali submission. Their training and COI disclosure requirements are evaluated by their own institution.
This page describes the documentation requirements for EIs when the LSUHSC IRB serves as their IRB of Record. Training for EI will be the same as LSUHSC-NO researchers beginning January 1, 2027. Current training requirements will remain in effect through December 31, 2026. Researchers should complete the newly required CITI courses by this date to prepare for the transition.
The specific training courses, the conditions under which they are required and the frequency at which they must be completed are listed in the table below.
Human Research Subject Protection Training
LSUHSC-NO has selected the Collaborative Institutional Training Initiative (CITI Program) as the provider of online courses necessary to fulfill initial and continuing training on human subject protection for HSC investigators. External investigators are also encouraged to complete the appropriate CITI courses to meet training requirements, although comparable courses from the EI's home institution or other providers may be acceptable.
EIs who already have a CITI account, either as independent learners or through their home institution, may complete the necessary courses through that account and submit a copy of the certificate of completion as part of the protocol submission process in Kuali Research. If necessary, EIs may also affiliate with LSUHSC-NO to access courses, such as the COI Basic and Refresher courses, that may not be available in their existing account. EIs who do not have a current CITI account may register at CITI Program and should affiliate with LSUHSC-NO at the time of registration. Instructions for creating an account, affiliating with an institution, selecting courses, and starting modules, are provided by CITI Program.
Conflict of Interest Training & Disclosure
An external investigator whose home institution is listed in the Financial COI Clearinghouse on the Federal Demonstration Partnership platform is exempt from LSUHSC's COI training and disclosure requirements as his/her institution has already certified that they are compliant with Public Health Service/NIH Financial Conflict of Interest (FCOI) rules and regulations. Listing in the FCOI Clearinghouse is verified by the IRB staff for each external investigator listed on the study.
If the EI's home institution is not listed in the FCOI Clearinghouse and DOES NOT have a comparable COI training and disclosure policy, the EI should take the CITI COI Basic course following the instructions provided above. Additionally, IRB staff will provide instructions to the EI for accessing and completing COI in Research Disclosure module in Kuali Research.
If the EI's home institution is not listed in the FCOI Clearinghouse but DOES HAVE comparable COI training and disclosure policies and procedures, please see below under "Alternative Training."
Training Topic |
Required Training Course/Disclosure |
Provider |
Frequency |
Required for the Following Studies |
|
Human Subject Protection |
Biomedical Research Basic - Initial or Refresher |
CITI |
Every 3 years |
Biomedical research studies |
|
Human Subject Protection |
Social & Behavioral Research Basic - Initial or Refresher |
CITI |
Every 3 years |
Social and behavioral research studies |
|
Human Subject Protection |
Good Clinical Practice (GCP) Drug and Device, FDA |
CITI |
Every 3 years |
NIH-funded clinical trials or FDA-regulated drug or device studies |
|
Conflict of Interest |
COI Basic or Refresher |
CITI |
Every 4 years |
All HSR studies |
|
Privacy |
HIPAA for Education and Research |
CITI |
Every 3 years |
All HSR studies |
|
Conflict of Interest Disclosure |
COI in Research Disclosure |
Kuali |
Annual |
All HSR studies unless external researcher institution is on the FDP Expanded Clearinghouse or FCOI Clearinghouse website |
Submitting a Protocol for IRB Review
When submitting a protocol in Kuali Research, please attach all relevant completion of training documents for each EI participating in the research study.