how to request irb approval for patient case report

by Zora Barrows 6 min read

Case Report Publication Guidance: IRB Review and …

12 hours ago Investigators who wish to publish case report data with HIPAA identifiers will need to obtain from the patient a signed HIPAA compliant authorization. This authorization does not need to be submitted to the IRB for review. The appropriate authorization form for use with a single case report may be found on the HIPAA web site HERE. >> Go To The Portal


NOTE: Investigators asked by a journal to provide documentation of IRB approval prior to publication for a case report of three (3) or less patients must submit a written request to the IRB describing the case report to be published. Upon receipt and review of the request the OIRB will issue a formal letter regarding the UAB policy.

Full Answer

Do you need an IRB approval to publish a case report?

Many journals now require a letter, or other acknowledgement, from an IRB prior to publication of a case report. Specifically, they wish to know whether IRB approval was obtained or was not required for the described case. The JHM IRBs have adopted a policy to address the following question and answers.

How do I get IRB approval for a Clinical Investigation?

An investigator should be able to obtain IRB review by submitting the research proposal to a community hospital, a university/medical school, an independent IRB, a local or state government health agency or other organizations. 55. Does a clinical investigation involving a marketed product require IRB review and approval?

Can the IRB observe the consent process and research?

However, 21 CFR 56.109 (f) gives the IRB the authority to observe, or have a third party observe, the consent process and the research.

How detailed should IRB written procedures be?

IRB written procedures should be sufficiently detailed so that IRB members and administrative staff understand how to carry out their duties consistently and effectively in ways that ensure that the rights and welfare of subjects are protected, and that the IRB operates in compliance with the regulations.

image

Is IRB approval required for case reports?

Yes. Under HIPAA, a case report is an activity to develop information to be shared for medical/educational purposes. Although the use of protected health information to prepare the paper does not require IRB review, the author of a case report must comply with HIPAA.

How do I request IRB approval?

Apply for IRB ReviewStep 1: Determine if your project requires IRB approval. ... Step 2: Complete the Mandatory Online Certification for Researchers. ... Step 3: Complete the IRB Research Project Application. ... Step 4: Prepare the Informed Consent Document(s) ... Step 5: Submit Proposal Form.More items...•

Are case studies exempt from IRB review?

As a result, case studies generally qualify for exempt review by the IRB provided that the study (a) does not involve a sensitive topic, (b) is conducted in a manner that protects subjects' identity, and (c) does not involve at-risk or special populations.

What documents would an IRB need to approve?

IRB Submission ChecklistApplication.Consent Document(s)Recruitment Materials.Study Instrument(s)Permission Letters (if applicable)Certificate of Education (if not already on file)Grant proposal narrative (if applicable)The application materials have been made into one PDF.More items...

How do I write an IRB proposal?

TemplateOverview and procedure. A brief paragraph clearly and succinctly explaining what the participant will do and/or experience during the research project. ... Risks and benefits. All reasonable risks must be revealed to participants. ... Confidentiality. ... Compensation. ... Your rights. ... Contact information.

What is IRB approval process?

The IRB office utilizes an initial pre-review screening process, during which an IRB analyst reviews each submission for completeness and compliance. The analyst may ask the PI to make changes to the submission before it is reviewed by the IRB (pre-review).

What is the difference between case study and case report?

Case studies are widely used in psychology to provide insight into unusual conditions. A case study, also known as a case report, is an in depth or intensive study of a single individual or specific group, while a case series is a grouping of similar case studies / case reports together.

Does case report count as research?

The case report is a research design where an unexpected or novel occurrence is described in a detailed report of findings, clinical course, and prognosis of an individual patient, which might be, but not mandatory, accompanied by a review of the literature of other reported cases.

Which type of research does not need to get an IRB approval?

Publicly available data do not require IRB review. Examples: census data, labor statistics. Note: Investigators should contact the IRB if they are uncertain as to whether the data qualifies as “publicly available.”

What are the two conditions that require you get IRB approval for a project?

IRB review and approval is required for projects that:Meet the definition of research.Involve human subjects and.Include any interaction or intervention with human subjects or involve access to identifiable private information.

How do I submit documents to IRB?

Part I – Sign up with the IRB for accessGo to the IRB's online web-form.​Select your region. ... Enter your first name, last name and email address.Click "Submit".The IRB will send you an email invitation to join a secure conversation on epost Connect.

Which of the following studies need to obtain an Institutional Review Board IRB approval for research on human subjects?

In general, the research team must seek an IRB approval for all studies that interact with human subjects, and collect (or use) personally identifiable information about individuals.

What is the purpose of an IRB review?

The fundamental purpose of IRB review of informed consent is to assure that the rights and welfare of subjects are protected. A signed informed consent document is evidence that the document has been provided to a prospective subject (and presumably, explained) and that the subject has agreed to participate in the research. IRB review of informed consent documents also ensures that the institution has complied with applicable regulations.

How often should IRB review be performed?

When an IRB approves a study, continuing review should be performed at least annually. All of the records listed in 21 CFR 56.115 (a) (1) - (4) are required to be maintained. The clock starts on the date of approval, whether or not subjects have been enrolled. Written progress reports should be received from the clinical investigator for all studies that are in approved status prior to the date of expiration of IRB approval. If subjects were never enrolled, the clinical investigator's progress report would be brief. Such studies may receive continuing IRB review using expedited procedures. If the study is finally canceled without subject enrollment, records should be maintained for at least three years after cancellation [21 CFR 56.115 (b)].

What is Institutional Policy, not FDA regulation, determines?

Institutional policy, not FDA regulation, determines whether compensation and medical treatment (s) will be offered and the conditions that might be placed on subject eligibility for compensation or treatment (s). The FDA informed consent regulation on compensation [21 CFR 50.25 (a) (6)] requires that, for research involving more than minimal risk, the subject must be told whether any compensation and any medical treatment (s) are available if injury occurs and, if so, what they are, or where further information may be obtained. Any statement that compensation is not offered must avoid waiving or appearing to waive any of the subject's rights or releasing or appearing to release the investigator, sponsor, or institution from liability for negligence [21 CFR 50.20].

What is the requirement for an IRB?

21 CFR 56.107 (c) requires at least one member of the IRB to have primary concerns in the scientific area and at least one to have primary concerns in the non-scientific area. Most IRBs include physicians and Ph.D. level physical or biological scientists. Such members satisfy the requirement for at least one scientist. When an IRB encounters studies involving science beyond the expertise of the members, the IRB may use a consultant to assist in the review, as provided by 21 CFR 56.107 (f).

What is the IRB system?

The IRB system was designed to foster open discussion and debate at convened meetings of the full IRB membership. While it is preferable for every IRB member to have personal copies of all study materials, each member must be provided with sufficient information to be able to actively and constructively participate. Some institutions have developed a "primary reviewer" system to promote a thorough review. Under this system, studies are assigned to one or more IRB members for a full review of all materials. Then, at the convened IRB meeting the study is presented by the primary reviewer (s) and, after discussion by IRB members, a vote for an action is taken.

What is the role of an IRB?

In accordance with FDA regulations, an IRB has the authority to approve, require modifications in (to secure approval), or disapprove research. This group review serves an important role in the protection of the rights and welfare of human research subjects.

What is an IRB?

What is an Institutional Review Board (IRB)? Under FDA regulations, an IRB is an appropriately constituted group that has been formally designated to review and monitor biomedical research involving human subjects. In accordance with FDA regulations, an IRB has the authority to approve, require modifications in (to secure approval), ...

What is the IRB written procedure checklist?

The IRB Written Procedures Checklist included below identifies the HHS and FDA regulatory requirements and recommendations for IRB written procedures. The regulatory requirements are denoted in the Checklist as headers to sections I, II, III and IV. The Checklist also includes recommendations on topics to cover in written procedures to ensure an adequate description of IRB functions and operations. For example, if an IRB reviews studies involving children as subjects, the IRB should have written procedures that describe how the IRB ensures the review of such research is in accordance with the regulatory requirements for the additional protections for children (45 CFR Part 46 Subpart D, or 21 CFR Part 50 Subpart D). For this reason, the Checklist also includes footnotes that cross-reference relevant regulations, which we recommend IRBs consider addressing in written procedures.

What is the scope of the IRB written procedures?

The scope of the IRB written procedures (e.g., who the written procedures apply to, what happens if the written procedures are not followed, who is responsible for preparation and maintenance , including who writes, revises, and approves the written procedures, and how often written procedures are reviewed and updated).

What is OHRP guidance?

This draft guidance, when finalized, will represent the Office for Human Research Protections’ (OHRP’s) and the Food and Drug Administration’s (FDA’s) current thinking on this topic. This guidance does not create or confer any rights for or on any person and does not operate to bind OHRP, FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. If you want to discuss an alternative approach, contact the appropriate OHRP or FDA staff responsible for implementing this guidance. If you cannot identify the appropriate OHRP or FDA staff, call the appropriate number listed on the second title page of this guidance.

What does "should" mean in OHRP?

The use of the word should in OHRP and FDA guidance documents means that something is suggested or recommended, but not required. II. BACKGROUND. OHRP and FDA frequently receive requests for clarification regarding the scope and content of IRB written procedures.

When to implement changes to approved research?

If you have a study that offers direct therapeutic benefit and/or stopping the procedures would cause harm to study subjects , researchers may implement changes to approved research prior to IRB review and approval, if the changes are necessary to eliminate apparent immediate hazards to the subject.

What is a public health and clinical activity?

Public Health and Clinical Activities. Actions taken for public health or clinical purposes, and not for research purposes, are not research procedures and do not require IRB approval before being implemented. For example, if a research study implements mandatory clinical screening procedures related to COVID-19 for all people who come ...

Does a pause need to be reported to the IRB?

For example, all Harvard research studies that involved direct contact with study subjects have been paused. This pause was not required to be reported to the IRB.

Do IRBs need to be reviewed?

Further, as these activities are not research procedures, the research team does not need IRB review in order to share the screening results with a public health authority or the research subjects, although other permissions or notice may be necessary under applicable law or policy.

What is a single case report?

A single, retrospective case report is an activity intended to develop information to be shared for medical and educational purposes. Under JHM policy, a “single case report” is a retrospective analysis of one, two, or three clinical cases but is not research that must be approved by the IRB. (If more than three cases are involved in ...

Where to find HIPAA authorization form?

The HIPAA authorization form used to obtain a patient’s authorization to use and disclose PHI for a single case report may be found at the JH Privacy Office website at: Use of Protected Health Information in a Case Report (A.2.1.v)

Do I need IRB approval for PHI?

Although IRB approval is not required, certain HIPAA Privacy Rule requirements apply to the use and disclosure of PHI for a single case report: Investigators who remove HIPAA identifiers from the case report data prior to disclosure of the data (e.g., prior to submission of the case report to a journal) do not need to obtain a signed privacy ...

Do you have to submit a HIPAA authorization to the IRB?

It is not necessary to submit this authorization form to the IRB for review.

image

I. IRB Organization

  • 1. What is an Institutional Review Board (IRB)? Under FDA regulations, an IRB is an appropriately constituted group that has been formally designated to review and monitor biomedical research involving human subjects. In accordance with FDA regulations, an IRB has the authority to approve, require modifications in (to secure approval), or disapprov...
See more on fda.gov

II. IRB Membership

  • 12. May a clinical investigator be an IRB member? Yes, however, the IRB regulations [21 CFR 56.107(e)] prohibit any member from participating in the IRB's initial or continuing review of any study in which the member has a conflicting interest, except to provide information requested by the IRB. When selecting IRB members, the potential for conflicts of interest should be considere…
See more on fda.gov

III. IRB Procedures

  • 18. The FDA regulations [21 CFR 56.104(c)] exempt an emergency use of a test article from prospective IRB review, however, "... any subsequent use of the test article at the institution is subject to IRB review." What does the phrase "subsequent use" mean? FDA regulations allow for one emergency use of a test article in an institution without prospective IRB review, provided tha…
See more on fda.gov

IV. IRB Records

  • 31. Are annual IRB reviews required when all studies are reviewed by the IRB each quarter? The IRB records for each study's initial and continuing review should note the frequency (not to exceed one year) for the next continuing review in either months or other conditions, such as after a particular number of subjects are enrolled. An IRB may decide, to review all studies on a quarterl…
See more on fda.gov

v. Informed Consent Process

  • 34. Is getting the subject to sign a consent document all that is required by the regulations? No. The consent document is a written summary of the information that should be provided to the subject. Many clinical investigators use the consent document as a guide for the verbal explanation of the study. The subject's signature provides documentation of agreement to partic…
See more on fda.gov

VI. Informed Consent Document Content

  • 46. May an IRB require that the sponsor of the study and/or the clinical investigator be identified on the study's consent document? Yes. The FDA requirements for informed consent are the minimum basic elements of informed consent that must be presented to a research subject [21 CFR 50.25]. An IRB may require inclusion of any additional information which it considers import…
See more on fda.gov

VII. Clinical Investigations

  • 54. Does a physician, in private practice, conducting research with an FDA regulated product, need to obtain IRB approval? Yes. The FDA regulations require IRB review and approval of regulated clinical investigations, whether or not the study involves institutionalized subjects. FDA has included non-institutionalized subjects because it is inappropriate to apply a double standard fo…
See more on fda.gov

VIII. General Questions

  • 56. Which FDA office may an IRB contact to determine whether an investigational new drug application (IND) or investigational device exemption (IDE) is required for a study of a test article? For drugs, the IRB may contact the Center for Drug Evaluation and Research (CDER), Office of Communications, Division of Drug Information at (301) 796-3400. For biological products, conta…
See more on fda.gov