What to do if something goes wrong – Reporting Requirements

What if I don’t follow my approved IRB application/protocol?

If you have found that you did not follow the approved IRB protocol, you should complete a protocol deviation report in iRIS. Step-by-step instructions on completing the form are available online.

The protocol deviation application should include information on the specific incident and how it was handled. If any changes to the consent form, application, or protocol need to be made as a result of the protocol deviation, an amendment should be submitted.

For more information, please see section 20.7 of the IRB Manual.

Some examples of times when the protocol deviation form should be completed:

  • You enroll more participants than were approved in the application
  • You find that one participant was out of the age range approved by the IRB
  • There was a discrepancy in the informed consent process
  • An unapproved recruitment method is inadvertently used

What should I do if something unexpected happens with a subject?

If something bad occurs unexpectedly with a participant, the unanticipated/adverse event form should be completed in iRIS. The application should include a detailed account of the occurence and the outcome. If any new risks are revealed by the event, research should stop until it can be reviewed by the IRB. If the event highlights any changes that need to be made to the consent form, application, or protocol, an amendment should be submitted.

Please see section 20 of the IRB Manual for more information.

Examples of times when an unanticipated/adverse event form should be submitted:

  • A participant becomes very upset during an interview
  • A participant becomes angry or unruly during the research
  • A participant becomes injured or gets sick during the research
  • A breach of confidentiality occurs such as a lost laptop or thumb drive
  • A participant dies or becomes incarcerated

If the IRB determines that the event is an unanticipated event involving risks to subjects and/or others, the Institutional Official will review the report and forward (or return it to the Office of Research Integrity/IRB compliance staff for forwarding) it as appropriate to the regulatory agency or agencies. The maximum time allowed between the recognition of a reportable event and fulfilling reporting requirements is 30 days.

How long do I have to report an incident?

Within seven business days of knowledge of the deviation or unanticipated events, the Principal Investigator (PI) is asked to submit the Unanticipated Event Form to the IRB Compliance Office. Anticipated events (anticipated events described in the risks section of the consent form) are to be reported in the annual continuing review application.

What are some of the consequences of reporting an incident?

The consequences will vary greatly based on the severity of the event and how it is handled. Some examples of possible actions by the IRB for unanticipated events are below.

  1. Accept the actions taken by the PI to report and resolve the incident
  2. Notify and re-consent current participants when information about the unanticipated problem might affect their willingness to continue to take part in the research
  3. Alter the continuing review schedule
  4. Peer review monitoring
  5. Approve with explicit changes, such as notification of previous subjects or modification of consent and/or protocol
  6. Suspension of some or all research activities
  7. Terminate the study for cause

Some examples of possible actions by the IRB for non-compliance are below:

  1. informal counseling
  2. action plan for resolving non-compliance
  3. audit(s) of active protocols
  4. subjects previously enrolled in the study contacted and provided with additional information and/or re-consented
  5. frequent review of compliance
  6. suspension of research protocol
  7. termination of research protocol
  8. letter(s) of reprimand
  9. suspension of sponsored research grant account
  10. notification of current participants when such information might relate to participants’ willingness to continue to take part in the research
  11. prohibit collected data from being used for publication
  12. report of non-compliance to Vice President for Research and other University administrators, the sponsor, and/or government agencies
  13. disqualification of Principal Investigator from conducting research involving human subjects at the University
  14. embargo of publications
  15. referral of the Claim to the Vice President for Research for investigation