No. As noted in the All of Us Responsible Conduct of Research training, the Researcher Workbench employs a data passport model, through which authorized users do not need IRB review for each research project. Most authorized users will not be conducting human subjects research with All of Us data for two reasons: (1) The research will not directly involve participants, only their data; and (2) the data available in the Researcher Workbench has been carefully checked and altered to remove identifying information while preserving its scientific utility. Nevertheless, we encourage anyone using All of Us data to apply the ethical principles of research with human participants to their work.
You can read more in the letter confirming the All of Us Institutional Review Board’s regulatory opinion. For more information about the All of Us dataset, including how to access it, please see here.