| Research and Partnerships

Who conducts Restricted Party Screenings?

Central administrative units, departments, and colleges will coordinate with Export Control on centralized procedures for Restricted Party Screenings and identifying international collaborations, travel, services, and online study abroad requiring OFAC licenses. All individuals affiliated with the University who work with international persons and entities must confirm via Restricted Party Screening and consultation with Export Control that activities are permitted with collaborators.

What is a denied entity/person or restricted party?

The U.S. government maintains lists of individuals or entities with whom the University and its employees may be prohibited by law or require a license to export to or engage in certain transactions.

Restricted Party Screening (RPS) is the process of reviewing foreign and U.S. individuals and entities to prevent illegal transactions with parties on the various federal government lists of restricted individuals, companies, and organizations.

What criteria must be met if a study can be exempted from requiring an IND?

A study can be deemed IND Exempt if all of the following criteria are met:

When is an IND not needed for studies involving marketed drugs?

An IND is not needed for studies involving marketed drugs such as:

Some studies using commercially marketed drugs
Some studies using in vitro diagnostic biological products (e.g., blood grouping serum, reagent red blood cells, anti-human globulin)
Studies using drugs in vitro or in laboratory research animals

What is Off-Label Use?

“Off-label use” is any difference in use, including indication, dose, route of administration, patient populations, and drug formulation from what is approved on the FDA label.

What is On-Label Use?

“On-label use” means the drug is being used in the same indication, dose, route of administration, patient populations, and drug formulation. There is no deviation from the approved FDA label. Studies involving the on-label use drug do not require an IND, as long as data will not be used in a marketing application.

What is Drug Labeling?

Drug labeling refers to all the printed material that accompanies a drug, including the label, the wrapping, and the package insert.

Do studies using Investigational Drugs require an IND application?

Yes, an IND application is a request to the FDA for authorization to administer an investigational drug (or biologic) to human or a marketed drug in a new indication and/or patient population. However, there are IND Exemptions. Please refer to the section on IND Exemptions for more information.

What is an Investigational Drug?

An investigational drug is defined as:

An article that is not approved (for marketing) in the US as a drug.
An approved drug that is not used according to the approved label (or a new combination of approved drugs).

What is a test article?

The term includes drugs (including botanicals, biologicals, and gene therapy, and genetically derived products that meet the definition of a “drug”), and medical devices for human use. The FDA has statutory authority to regulate the development and marketing of these products.

Subscribe to