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Events that require reporting
Per the IU HRPP Policy on Reportable Events, investigators must report to the IRB particular events that occur during the conduct of their research. Events that may impact subject safety, confidentiality, information security, or privacy, or conduct of human subjects research without IRB approval require prompt reporting, while other less serious issues may require reporting to the IRB at the next Renewal.
If investigators need guidance determining what category an event should be reported under, whether the event should be reported promptly, or if other IU institutional policies may apply, please contact the Human Subjects Office (HSO).
When the HSO receives a reportable event submission, staff will verify whether the information meets prompt reporting criteria.
- For items classified as noncompliance, the HRPP Director, a HSO Associate Director, or a HSO Senior Research Compliance Consultant will further review the item to determine if the report may constitute serious or continuing noncompliance. If the item is determined not to meet the prompt reporting criteria or is determined to be not apparent serious or continuing noncompliance, HSO staff will communicate this to the study team and withdraw the item from further review. The study team should report the event at time of next renewal, if applicable, or study closure.
- If the item does require prompt reporting, HSO staff will prepare the information for review by the convened IRB (unless expedited review is permitted by the VA regulations as described below).
The following events must be reported to the IRB within five (5) business days of the study team becoming aware of the event, regardless of the level of review of the study (i.e., Full Board, Expedited, Exempt):
- Conduct of human subjects research without IRB approval, including:
- Conduct of research without submitting for IRB review.
- Conduct of research prior to receiving IRB notification of final approval.
- Initiation of substantive changes (i.e., changes that would affect the subjects' willingness to participate, such as changes to study procedures, risks and/or benefits) to the research protocol without prior IRB approval, including changes necessary to eliminate apparent immediate hazards to the subject.
NOTE: “IRB-approved protocol” refers to all study information, including that contained in the KC IRB Questionnaires, formal protocol document, consents, etc.
- Inclusion of vulnerable subject populations without specific IRB approval.
- Conduct of research when IRB approval has expired or been suspended or terminated.
NOTE: Expiration of IRB approval in itself is not promptly reportable, but conduct of research activities after expiration is reportable.
- Subject interactions or review of identifiable research data by individuals who have not completed appropriate investigator requirements (e.g., COI disclosure and CITI training).
- Adverse event (either locally or at an external site) assessed by the principal investigator (PI) as (1) unexpected, (2) related or possibly related to study participation, AND (3) suggests that the research places subject(s) or others at greater risk of harm than was previously known.
- Unanticipated adverse device effects.
- Major protocol deviations/protocol noncompliance that occurred and may, in the opinion of the PI, (1) impact subject safety and/or (2) affect the integrity of the data, such as:
- Dosing errors.
- Enrolling a subject who does not meet eligibility criteria.
- Study visits outside of the protocol-specified timeframe or missed study visits.
NOTE: Study visit deviations that do not meet either criteria 1 or 2 above should be reported with the next Renewal submission, if the study requires renewal.
- Consent and/or authorization issues, including:
- Failure to obtain consent and/or authorization from subjects, including obtaining consent from someone who cannot legally consent for the subject.
- Failure to obtain the subject's signature on the informed consent and/or authorization (unless a waiver of documentation of consent has been granted) prior to subjects' starting study procedures.
- Enrolling subjects using a consent which does not include all known risks, or continuation of subject participation without notification of newly identified risks.
- Other major deficiencies in informed consent or HIPAA authorization process or documentation, such as:
- Use of an outdated informed consent or HIPAA authorization which is missing substantive content (e.g. information on procedures or risks) that may affect subjects' willingness to participate.
- Minor deficiencies in informed consent or HIPAA authorization process or documentation, occurring within a one year period and affecting ten (10) or more subjects (e.g., outdated informed consent or HIPAA content that is not substantive, such as change in number of subjects to be enrolled, or lack of signature of individual obtaining consent).
NOTE: Generally, the IRB would not expect subjects to be re-consented for minor deficiencies in informed consent or HIPAA authorization process.
- Subject complaints that indicate an unexpected risk and/or that affect the rights and welfare of human subjects.
- Study suspensions or holds related to risk, safety or compliance issues.
- Incidents that may compromise information security, subject privacy, and/or confidentiality (e.g., subject data breach). These incidents should also be reported to the applicable Information Policy Office and/or HIPAA Privacy Office. IU researchers can report this information at Protect IU.
- Results of local audit reports (i.e., Human Subjects/QIO audits, VA audits).
- Failure to submit amendments which update risks, benefits, or procedures within 60 days of receipt or promptly report events when required per IU HRPP Policies.
NOTE: Receipt of an external auditing/monitoring report, such as an FDA Form 483, in itself does not require prompt reporting. However, the study team must evaluate each finding in any such report and assess whether the event(s) meet prompt reporting criteria.
For VA studies, additional reporting requirements apply. Investigators conducting VA research must also promptly report the following to the IRB:
- Local research deaths which are unanticipated and related to the research.
NOTE: The IRB must be immediately verbally notified, with written report submitted within 5 business days.
- Local serious adverse events (SAEs) or serious problems which are unanticipated and related to the research.
- Any event constituting apparent serious or continuing noncompliance (see ORO Guidance document “Examples and a Brief guide for Reporting Apparently Serious or Apparently Continuing Noncompliance in Human Research That May Be Reportable to ORO under VHA Handbook 1058.01” for a comprehensive list of reportable events).
- Any suspension or termination of VA research by, or at the direction of, any entity external to the facility.
For studies that require annual renewal, events that do not meet the criteria for prompt reporting or which are determined by HSO staff to be not apparent serious or continuing noncompliance must be reported at the time of next study renewal to ensure the IRB has a full understanding of the conduct of the research. Events that must be reported at time of next renewal include:
- Adverse events which were not previously promptly reported and occurred at a greater frequency and/or severity than was previously expected based on the current protocol, informed consent document, and/or investigator's brochure.
- Protocol deviations/minor noncompliance not previously reported to the IRB, such as:
- Use of a consent form that is not the most recently-approved version when the content is not substantively different from the current IRB approved consent.
- Use of an unstamped consent form when the content is the same as the stamped IRB approved version.
- Enrolling more subjects than approved by the IU IRB, provided the total study-wide approved enrollment was not exceeded.
NOTE: Exceeding the study-wide enrollment number would typically be considered to require prompt reporting.
- Conduct of research by individuals not listed as research personnel who have completed appropriate investigator requirements (e.g. COI disclosure and CITI training).
- Implementing minor wording changes to IRB study documents without prior IRB approval.
- Failure to appropriately document consent and/or authorization, if the missing information can be clearly corroborated by other documentation (e.g., research notes).
- missing demographic information on Authorization form
- missing or incorrect dates
- missing signature of person obtaining consent/authorization
NOTE: Informed consent and/or authorization documents that are missing the subject's signature are NOT considered minor noncompliance and should be reported promptly.
NOTE: Generally the IRB would not expect subjects to be re-consented for events that do not meet prompt reporting criteria.
Studies that do not require renewal are not expected to report events that do not meet the criteria for prompt reporting. However, cumulative minor protocol deviation or non-compliance instances require prompt reporting if they affect 10 or more subjects within a one year period.
If the event meets the reporting criteria and would have been required to be reported promptly while the study was open, it should be reported even after the study is closed, regardless of the length of time since study closure. Investigators can use the Notify IRB action in KC IRB to submit such reports.
If the event does not meet the prompt reporting criteria, investigators do not need to submit a report.
For VA studies, certain events requiring prompt reporting must be reviewed within five (5) business days of receipt by the IRB Chair or qualified IRB member-reviewer in accordance with VHA policies. If such reviewer determines the event is NOT serious and unanticipated and related to the research, further review by the convened IRB is not required. However, the reviewer may determine that a report should be reviewed by the convened IRB at their discretion.