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Graduate Program in Public Health / Reportable Events
For more information please contact the IRB at 718-613-8480 or .
Items in RED text in the table below are required by Government Regulations.
Items in BLUE text in the table below are required by Downstate policy; however, this items may also overlap with items in RED if the event also meets the definition of an item that needs reporting by the Federal Regulations, as determined by the IRB. For definitions of each event, please see the IRB Guidance: “Acronyms and Definitions”.
Yellow Highlight items in the table below require external reporting to the Sponsor or Government Federal Agency, by the Institutional Official.
Green Highlighted items in the table below may require additional reporting to the FDA from the sponsor or sponsor-investigator.
· The PI must comply with the FDA Investigator’s Responsibilities for INDs
· For investigator-initiated IND studies, the PI must comply with FDA Investigator Responsibilities for Investigator-Initiated IND Applications, including any reporting to the FDA.
· Sponsors, investigators, and monitors must comply with the FDA reporting requirements for IDE responsibilities.
Note: The table below does not include all of the required reporting of the PI to the Sponsor or for the Sponsor to the FDA. Please consult with your sponsor or FDA for requirements.
Contents
Table of Reporting Requirements 3
References 7
Author 7
Review and Approval History 7
Table of Reporting Requirements
Event Type(*= Requires Full Board Review or SAE Subcommittee Review)
See definitions in IRB guidance documents for a description of each event. / Deadline from when the investigator first learns of an internal event for reporting to IRB for an internal event (e.g., those that occurred with within the DMC IRB’s jurisdiction) / Comments
*Government inspection (or audit) / Report findings within 24 hours, if any serious or continuing non-compliance was found or proposed; otherwise within 5 days. / The study team should alert the IRB when the inspection is scheduled or if an inspector arrives unannounced, so the IRB may help as needed.
*Privacy Violation (or Breach). / Immediately report this to IRB and Privacy Officer
*Information (Data) Security Violation (or Breach). / Immediately report this to IRB and Data Security Officer
Incarceration of a research participant. / Immediately, if participant is actively incarcerated; otherwise within 5 days
Any FDA Actions or changes to a HUD. / Immediate
Serious Adverse Event.
An AE or SAE may also meet the definition of an UPIRPO, UAE, or UADE, as described below. / 24 hours, if in Clinical Trial when the AE meets all of the following criteria:
· serious (SAE) or alarming, AND
· unanticipated, AND
· definitely, probably, or possibly related to the investigational agent.
For more information, see FDA Guidance on AE reporting to the IRB. / When reporting a death, please include the date of death, if known.
Investigators are required to report promptly “to the sponsor any adverse effect that may reasonably be regarded as caused by, or probably caused by, the drug. If the adverse effect is alarming, the investigator shall report the adverse effect immediately’”. Consult with the Sponsor or FDA for additional guidance.
The term “alarming” is not defined by the FDA, so it is up to the PI’s or Sponsor’s discretion on how to interpret this term.
*Research related injury involving provision of healthcare. / 24 hours, if serious.
Report within the current approval period, if minor. / The PI or IRB may consult with general counsel regarding recommended action.
*Apparent Non-Compliance. / 24 hours, if serious or continuing
Report within the current approval period, if minor (e.g., protocol deviation) / Any employee or agent is expected to report any apparent non-compliance to the IRB or to the Compliance Hot Line at 877-349-SUNY (7869) or via the Web-based Reporting Compliance Line. You may make an anonymous report using the web based system, if desired.
New Information that Indicates a Change to the Risks or Potential Benefits of the Project. / 24 hours if serious; otherwise within 5 days
Significant New Finding. / If serious, notify the IRB within 24 hours; otherwise, submit to the IRB within 30 days of notice / During the course of research, significant new knowledge or findings about the medication or test article and/or the condition under study may develop. The PI should report any significant new findings to the IRB and the IRB will review them with regard to the impact on the research participants’ rights and welfare. Since the new knowledge or findings may affect the risks or benefits to research participants’ willingness to continue in the research, the IRB may require, during the ongoing review process, that the PI contact the currently enrolled research participants to inform them of the new information. If the change to the risk/benefits ratio is adverse, the informed consent should be amended and submitted to IRB for approval. The informed consent should be updated and the IRB may require that the currently enrolled research participants be re-consented, acknowledging receipt of this new information and for affirming their continued participation.
Changes Initiated to Eliminate an Apparent Immediate Hazard days. / 5 days / Include an amendment, to propose any additional or permanent changes.
Expanded Access, Emergency Use, or Compassionate Use of an Unapproved Drug, Unapproved Biologic, or Unapproved Device. / Notify IRB Chair as soon as possible.
Notify the IRB within 5 days of drug administration or device use / Requires approval of the Department Chair and Medical Director before administration.
May require IND or IDE from FDA.
Protocol Deviations (including minor modifications made without IRB approval), Violations, or Complaints.
*Must be reported to the full board if the event meets the requirements to be reported within 5 days. / 5 days, if it adversely affects: the rights, safety, or welfare of the research participant; or the research participant’s willingness to continue participation; or the integrity of the research data, including information security requirements.
Otherwise report to IRB before continuing review or project closure. / Include an amendment, to propose any additional or permanent changes, as a corrective action.
Any complaints involving translations or interpretations must also be reported to patient relations.
*Termination or *Suspensions of research, Administrative Hold, FDA Clinical Hold, Enrollment Hold. / 5 days / The IRB may also elect to terminate or suspend IRB approval or place enrollment on hold, and all such actions require reporting to OHRP, and to FDA and sponsor when applicable, by the IO.
All Local Unanticipated Problems Involving Risks to Participants or Others (UPIRPO).
*Must be reported to the full board if the event meets the requirements to be reported within 5 days.
See also SAE. / 5 days, if serious; otherwise, within 30 days / If the IRB concurs or determines that an event is an UPIRPO, it requires reporting by the IO to the OHRP, and to FDA when applicable.
Unexpected AE (UAE).
See also SAE and UPIRPO. / 5 days, if serious; otherwise, within 30 days / If the IRB concurs or determines that this event is also an UPIRPO, it requires reporting by the IO to the OHRP, and to FDA when applicable.
*Audit or *Monitoring Activities.
*Must be reported to the full board if the event meets the requirements to be reported within 5 days. / 5 days if findings identify apparent serious or continuing noncompliance; otherwise at continuing review or study closure.
Unanticipated Adverse Device Effect (UADE).
See also SAE and UPIRPO. / As soon as possible, but no later than 10 days / Report to sponsor within 10 days.
If the IRB concurs or determines that this event is also an UPIRPO, it requires reporting by the IO to the OHRP, and to FDA when applicable.
Interim Analysis Reports, Data Monitoring Committee Data and Safety Monitoring Board (DSMB) reports. / Submit to the IRB within 30 days of notice
External reportable events (e.g., those that occurred with participants that were enrolled outside of the local site of the IRB jurisdiction). / N/A / Report to IRB, if required by the Sponsor, but no later than the time of continuing review during the approval period for which the event occurred.
Sponsored required reporting. / N/A / Deadline is determined by sponsor
References
· 21 CFR 50, 56, 312, & 812
· 45 CFR 46
· FDA Investigator Responsibilities for Investigator-Initiated IND Applications
· FDA Investigator’s Responsibilities for INDs
· IDE responsibilities
· IRB-01 policy
· OHRP Compliance and Reporting
Author
Kevin L. Nellis, MS, CIP
Review and Approval History
Original Issue Date: 03.16.2017
Revision Date: N/A
DateReviewed & Approved / Revision Required / Responsible Staff Name and Title
Yes / No
03.16.2017 / X / Kevin L. Nellis, MS, CIP, Executive Director, Human Research Protections and Quality Improvement
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