At times principal investigators will plan research projects that will eventually lead to the submission of grant applications where human subjects use are planned in future but have not been finalized, or when a PI received a "just-in-time" notice from a granting agency and is requesting documentation of IRB approval.
An investigator may request review of a project for a planning only and that a submission of an IRB application for the complete study is required prior to initiating the research.
The IRB has issued guidance to address this topic.