I also thought this made no sense but here is the response from our IRB 
administrator to whom I posed this question: (and I did not ask his permission 
to pass on this information but "assume" that since it's in a public email to 
me it is now up to me to decide what I do with it)
===================================
"IRBs are required to review all active research projects at least annually. 
The situation in question appears to be what happens when a researcher fails to 
submit anything to the IRB before the year is up, i.e. if neither a summary 
report nor a continuation request is submitted, then what? In that case I would 
agree with the IRB chair that the study is automatically terminated and no 
further work on the study can be done.

I thinks this is different that the situation where you have submitted a 
summary report indicating that the human subjects research part of the study is 
complete. In that case the study is not terminated but rather enters a phase of 
data analysis and publication that does not involve further interaction with 
human subjects, and which also follows whatever confidentiality/anonymity 
agreements the researcher made with the subjects."
=====================================
I guess this makes sense if you consider that a study for which no paperwork is 
filed in a timely fashion violates and negates the original contract between 
the researcher and the IRB.

Having said all of this. I have to say that our IRB is WONDERFUL! They work 
actively with researchers when they see something problematic and take the 
approach that their "job" is to teach researchers, as much as to oversee the 
protection of human subjects. Our turn-around times are phenomenally 
fast--sometimes less than 24 hours for expedited and exempt reviews. But, on 
the other hand, as you can see from the above, they do play by the rules.

Annette

Annette Kujawski Taylor, Ph. D.
Professor, Psychological Sciences
University of San Diego
5998 Alcala Park
San Diego, CA 92110
tay...@sandiego.edu
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