Modifications to Currently Approved
Research (Addendum):
All modifications to currently approved research are required
to have HSPC review and approval prior to implementation. Minor
changes that do not increase the risk to research subjects may
receive an expedited review. Modifications to approved protocols
that may affect the risk to subjects are forwarded to the full
Committee for review. (Please see Chapter
3, "The HSPC Review Process" for information
regarding expedited review.) Please include the HS Form 1, a cover letter
explaining the requested modifications, and any modified items
such as consent forms, protocols, investigator brochures, study
instruments, recruitment tools, etc., with the application.
An addendum may require full Committee review if the
modification is significant and impacts the risks and benefits to
subjects in the research. Changes in the risks or benefits to
subjects may require modifications to the consent form and
re-consenting of subjects.
The HSPCs may only approve modifications submitted during a
current approval year to the end of that period. For example, if
the new, renewal, or continuing approval is issued on January 1,
1997 it will have an expiration date of December 31, 1997. If an
addendum is approved during this time, the approval still lasts
only until December 31, 1997. Please incorporate all
modifications and addendums into the continuation application,
protocol, and when applicable the informed consent forms for HSPC
consideration during the annual review.
Changing
Investigators:
When changing investigators, please include an HS Form 1, and a letter from the
principal investigator indicating the change in responsibility
and a letter from the new investigator accepting responsibility
for the research. Changes in investigators usually qualify for
expedited review.
Continuation
Review:
The federal regulations do not allow an HSPC to approve a
study for more than one year. For multi-year research, the
principal investigator is responsible for submitting a
continuation application prior to the expiration of the current
HSPC approval. The OPRS mails a continuation application to
investigators 90 and 60 days prior to the expiration of the
current HSPC approval. If the approval expires prior to
submission of the continuation application, the investigator is
required to suspend subject contact and data collection until the
continuation is approved by the HSPC. For therapeutic studies
where subject safety is a concern, the FDA allows some
flexibility towards the continued treatment for currently
enrolled subjects. However, no new subjects may be contacted,
recruited, or enrolled until the investigator obtains current
HSPC approval.
The continuation application should incorporate all of the
addenda and modifications submitted to and approved by the HSPC
during the previous approval periods. Please include a cover
letter indicating the modifications to the study during the
previous approval period.
Continuing review and approval is necessary if recruitment of
subjects stops but previously enrolled subjects continue to
participate in the research or the study is in data analysis at
UCLA.
Renewal:
Many studies undergo numerous modifications during the first
four years of research. As a result, the HSPCs require a renewal
application or the equivalent of a new application at the fifth
year of any continuing research.
Completion/Termination:
In order to formally complete a study file, the HSPCs request
that investigators officially notify the OPRS when a study is
terminated or completed or after data analysis is complete and
submit the HS-8, Final Report Form when
closing out a study.
Training
Grants, Program Projects/Multiple Project Grants, Center Grants:
The federal regulations require that the Committees or their
designee certify that human subject related research funded by an
"overall" grant such as a training grant, program
project, multiple project grant or center grant have current HSPC
approval. Please submit one copy of the following:
- applicable sections of the Form HS-1;
- the grant application;
- a cover letter indicating that no funds will be
transmitted to the individually supported sub-projects
proposing to conduct research with human subjects until
the sub-projects have received current approval from the
HSPC; and
- a list of all the human subject related projects
supported by the grant. The list should include the
following:
- The name of the principal investigator(s);
- The HSPC numbers of the project(s);
- The title of the project(s);
- The current approval periods for the project(s).
The HSPCs have delegated certification authority to the OPRS.
As a result, the OPRS will certify whether the human subject
related projects under the "overall" grant have current
approval and perform an administrative approval of the funding
submission. BECAUSE THE "OVERALL" GRANT IS INTENDED TO
FUND THE SUB-PROJECTS, NO HUMAN SUBJECTS CAN BE ENROLLED IN THE
"OVERALL" GRANT. (Please see Chapter
12, "Application Forms: Form HS-1, Application to Involve
Human Subjects in Research, Section II(4)" for the
appropriate application materials.)
Contact OPRS
October 29, 2004
Contact Webmaster
|