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Welcome to the IRB Homepage. Please note that the news posted here is always the most recent, but there are more news items on the News page that may be important to you.

 

PLEASE NOTE: Beginning Monday, 3/16 the IRB Office will be physically closed to the research community with IRB staff working remotely. IRB staff will be available during this time by phone and email. Please reference the staff directory. 

 

WHO SHOULD I CONTACT DURING THE COVID-19 PANDEMIC? 

Questions about Exempt or Expedited Research 

SBS Researchers 

• Primary Contact: Candace Adams 
• Secondary Contact: Patrick Stanko

Biomedical Researchers

• Primary Contact: Stephanie Lesage
• Secondary Contact: Patrick Landis

Questions about Greater than Minimal Risk Convened Research

• The Board Administrator / Coordinator for the Board to which the study is assigned. Refer to the directory. 

 

SUBMISSION PROCESSING UPDATE DURING THE COVID-19 PANDEMIC

• Electronic Submissions: The IRB staff is working remotely, and we are still available to review electronic submissions made via HSERA. Please submit all electronic submissions for review as usual.
• Paper Submissions: Because the IRB office is closed until further notice, please submit scanned versions of all relevant study documents for paper submissions to PROVOST-IRB@pobox.upenn.edu so that submissions may be reviewed electronically. 

NOTE:

• All continuing review submissions will continue to be processed normally. 
• All minimal risk, expedited and exempt research will continue to be processed normally.

 

Review and Processing of Biomedical Research Requiring Review by the Convened Board

The IRB staff will be screening all greater than minimal risk biomedical submissions that require convened review by clinician IRB members in light the following: 

1. Is the protocol ‘essential research’ that must continue during this pandemic? Please see the IRB home page for the definition of essential research under  3/17/2020: Important: Message from Emma Meagher, MD - Clinical Research Update #3
2. If a modification submission: the IRB staff will assess whether the change is critical to the safety and well-being of participants. 

If a shortage of clinician IRB members occurs during this time, the IRB will prioritize all COVID-19 research as well as submissions for essential research so that clinician IRB members may primarily focus on patient care during this time. Non-essential research that requires convened review may be submitted, but may be held by the IRB office until there is availability to review. 

IRB Approval vs. Authorization to Initiate/Continue Research 

While the IRB is permitting and processing submissions, approval by the IRB at this time DOES NOT constitute authorization to initiate a protocol, protocol amendment, or continue research procedures (as applicable). 

Penn Medicine

Clinical Trials: During the COVID-19 Pandemic, permitted clinical trial activity is limited to essential clinical trials. Essential clinical trials are those that enroll or follow patients with life threatening or serious conditions for which participation in the clinical trial holds out the clear prospect of the patient directly benefiting. Patients already enrolled into clinical trials who are undergoing safety assessments fall into this definition. Please review the Message from Emma Meagher, MD - Clinical Research Update #3 on the IRB website here for further details: https://irb.upenn.edu. Please consult with Emma Meagher at emma@upenn.edu for non-oncology trials or Bob Vonderheide at rhv@upenn.edu for oncology trials for guidance if you wish to open a new trial, or if you are unclear whether your protocol constitutes essential research.

Research studies with procedures that may be conducted remotely or virtually (e.g., electronic survey research, record reviews, secondary data analysis) may be conducted at this time, as long as their conduct does not interfere with clinician duties and patient care during the pandemic.  Please consult with OCR for authorization to conduct such research. Please ensure that you have adequate study staff and resources.

Other Schools

Only research studies with procedures that may be conducted remotely or virtually may be conducted at this time (e.g., electronic survey research, record reviews, secondary data analysis).  Please also refer to any guidance provided by your school.

 

3/23/2020: COVID-19 FDA GUIDANCE ON CLINICAL TRIALS & NIH FUNDING INFORMATION DURING COVID19 PANDEMIC 

• The Food & Drug Administration (FDA) has issued guidance relating to Conduct of Clinical Trials of Medical Products during the COVID-19 Pandemic for March. Please see the linked guidance document for details on this update. 
• The National Institue of Health (NIH) has issued information for NIH applicants and recipients of NIH funding. Please see the linked website for further details on NIH funding. 

 

3/17/2020: IMPORTANT IRB UPDATES

Protocol Changes Related to COVID-19

The IRB continues to receive questions about what changes require IRB review and approval related to mitigating risk to participants during the pandemic. 

If you are changing the protocol procedures temporarily, to eliminate immediate hazards to subject safety due to the pandemic, there is no need to wait for IRB approval. However, the IRB would ask that you submit documentation of the changes in HSERA within a reasonable timeframe, so the IRB is aware of the changes. The IRB is not providing a specific timeline because patient care should be prioritized during this time and the situation changes daily. 

NOTE: Any changes or deviations that may increase risk of harm to participants or adversely affect the scientific integrity of the data should wait for IRB review. 

• E.g., A total suspension of a therapeutic trial would have to be reported to the IRB if participants are enrolled and may be at risk due to the discontinuance of study procedures, with a plan for managing those risks.  
• E.g., If individuals are not able to travel for an in-person visit because of concerns related to COVID-19, AND it adversely impacts the risk to the participant.

Remote Visits to Substitute for In-Office/Hospital/Clinic visits

Remote visits via telephone, tele-medicine, or other appropriate virtual communication may be substituted for a visit to an office, hospital or clinic. The above note applies in terms of risk to participants and effect on scientific integrity and whether this needs to wait for IRB review. We recommend that participants be advised of any related changes.

Re-consent Guidance

1. Re-consent is not necessary unless the changes to the research are such that the original consent is no longer valid. 
2. Participants may be verbally apprised of risks related to COVID-19 if in-person contact is still necessary in some fashion. 
3. Subjects may also be notified of changes to the research via a letter or other form of communication. This does not require submission to the IRB.

Permanent changes should be submitted via an amendment. Temporary changes should be submitted via exception request. Deviations identified after the fact should be submitted per usual IRB policy. The IRB will be flexible with submission timelines given the circumstances. 

Guidance on Remote Consent Procedures

In the event of a health pandemic (i.e. COVID-19 declared on March 11, 2020) documenting consent from subjects utilizing methods other than pen and paper will be permitted. The IRB has collaborated with the PSOM Office of Clinical Research to develop a guidance on Remote Consent Procedures during the current pandemic. This document contains guidance on documentation and consent discussions. The guidance applies to Penn Medicine as well as non-Penn Medicine schools. Please review the attached guidance document for more information.

Guidance on Emergency Use/Compassionate Use of Drugs/Devices

Guidance and submission instructions related to the Emergency Use/Compassionate use of investigational drugs/devices is available online here: https://irb.upenn.edu/how-submit-penn-irb/expanded-access

If consent cannot be obtained due to both incapacity of the patient and unavailability of an LAR, an exception from prospective informed consent requirements may be appropriate.

Exception from Informed Consent Requirements [21 CFR 50.23(a)]

• The subject is confronted by a life-threatening situation necessitating the use of the product,
• Informed consent cannot be obtained because of an inability to communicate with, or obtain legally effective consent from, the subject,
• Time is not sufficient to obtain consent from the subject's legal representative, AND
• No alternative method of approved or generally recognized therapy is available that provides an equal or greater likelihood of saving the subject's life.

Note: Exception from informed consent requires an independent assessment from an uninvolved physician prior to or within 5 working days of the use of the article.

A plan should be in place to consent the individual /LAR as applicable after the fact, when they are available to provide informed consent. An enrollment note should document the situation and be filed with the signed ICF. 

 

 3/17/2020: Important: Message from Emma Meagher, MD - Clinical Research Update#3

The requirements regarding the execution of clinical research will apply until further notice.

Please consult with Emma Meagher at emma@upenn.edu for non-oncology trials or Bob Vonderheide at rhv@upenn.edu for oncology trials for guidance if you wish to open a new trial.   

• Permitted clinical trial activity is limited to essential clinical trials. Essential clinical trials are those that enroll or follow patients with life threatening or serious conditions for which participation in the clinical trial holds out the clear prospect of the patient directly benefiting. Patients already enrolled into clinical trials who are undergoing safety assessments fall into this definition.
• No new clinical trials may be initiated at this time unless it meets the definition of an essential clinical trial. Please consult with me (Emma Meagher) for non-oncology trials or Bob Vonderheide for oncology trials for guidance if you wish to open a new trial. 
• No new enrollment of research participants into existing clinical trials may occur unless it meets the definition of an essential clinical trial. Please consult with me (Emma Meagher) for non-oncology trials, or Bob Vonderheide for oncology trials for guidance if you wish to enroll new participants. 
• In-person research visits should continue for participants already enrolled in essential clinical trials if it is essential for patient safety and/or the participation in the clinical trial is an integral part of the patient’s treatment plan. The study physician, in consultation with the study team, the patient’s physician, the patient, and the patient’s family should carefully assess the necessity and risks of an in-person visit. All other in-person clinical research visits must be postponed.
• Research staff should make efforts to use alternative methods to conduct research visits or perform testing such as check-ins with participants by phone and/or performing research-related lab testing at lab testing centers, where feasible.
• Research staff should work remotely, unless their presence is required for the safe conduct of the trial.
• Principal Investigators should let commercial sponsors know that opening new ‘non-essential’ clinical trials and enrollment into ongoing ‘non-essential’ clinical trials is temporarily postponed.

 

3/13/2020 Penn Medicine Updated Clinical Research Guidance in relation to COVID-19 (Corona Virus)

Note: Although the below guidance applies to Penn Medicine, we recommend that non-Penn Medicine researchers review the guidance for any procedures that may be prudent or necessary to ensure the safety of participants and research staff.

Based on the March 13th, 2020 communication from Penn Medicine we are updating the guidance regarding the execution of clinical research. 

This will apply for a minimum period of 14 days. 

• Non-essential ‘in-person’ clinical research appointments and procedures for research participants should be canceled.
• Research staff should make efforts to use alternative methods to conduct research visits or perform testing such as check-in with participants by phone and/or performing research-related lab testing at lab testing centers, where feasible.
• Research visits that are directly linked to treatment and/or essential for the clinical care of existing research participants should continue to take place. 
• Monitoring and auditing of research studies should be conducted remotely. 
• New clinical research studies and trials that involve utilization of Penn Medicine facilities should not be initiated during this time. COVID 19 related studies are exempt from this requirement. 
• New participant enrollment onto existing studies should only proceed if the principal investigator believes it is in the best interest of the research participant.
• Principal Investigators should let commercial sponsors know that enrollment into ongoing trials is temporarily postponed. 
• As a reminder, when working remotely with PHI, you should only use approved and compliant options, such as Secure Share, PennBox, or other Penn-managed shared drives. 

If you have questions about this guidance, please send inquiries to:

• IRB related inquiries: PROVOST-IRB@pobox.upenn.edu
• Other research related inquiries: psom-ocr@pobox.upenn.edu

 

3/10/2020 Penn Medicine Guidance on Human Subjects Protections Considerations Related to COVID-19

Penn Medicine has instituted mandatory COVID19 travel-screening questions for all patients who are seen at Penn Medicine. Because many patients are also research participants, the Penn IRB and OCR are providing the following clarifications to the Penn Clinical Research Community.

• COVID-19 Mandatory Screening in the Health System: Mandatory PennChart screening procedures/questionnaires are not considered part of the “IRB-approved procedures” for your protocol, and therefore do not trigger the need for an amendment to the protocol. These screening procedures do not constitute a change in IRB-approved research procedures unless you choose to incorporate the data collected under the mandatory screening into your research plan. If you do wish to include data obtained from health system-required screening procedures, an amendment or new protocol should be submitted to the IRB to use that data.

• Changes to IRB-Approved Protocols: According to IRB policy, any changes in IRB-approved research procedures must be reported to the IRB and may not be implemented prior to review and approval by the IRB, except when necessary to eliminate apparent immediate hazards to the subject. This is permitted by both the Common Rule (38 CFR §16.108(a)(3)(iii)) and by FDA regulations (21 CFR §56.108(a)(4)). Beyond the regulation, Penn Medicine also has a responsibility to ensure the safety of its employees. As such, interim measures to reduce immediate hazards to research participants and staff – which may involve deviating from IRB-approved study procedures prior to securing IRB approval – may be warranted to relieve an immediate hazard and to ensure consistency with Penn Medicine polices during this time.

 

Examples include considering approaches that would reduce the need for “at risk” research participants to visit Penn Medicine facilities such as:

• Conducting  phone visits in lieu of in-person visits
• Research procedures that might be completed without requiring that participants travel to Penn Medicine (surveys, imaging procedures/ lab testing be done at other sites)
• Permitting “out of window” visits and/or canceling nonessential research participant visits
• Please note that the IDS will ship investigational medication to participants’ homes if requested.

Examples include considering approaches that would reduce the number of external vendors visiting Penn Medicine facilities, such as:

• Conducting remote monitoring visits
• Conducting remote site initiation visits or other sponsor visits/meetings
• PI and/or sponsor temporarily stopping recruitment or placing the study on a temporary hold

For all of the examples above, and any other protocol modifications, research teams should work with their funding and regulatory sponsors to develop plans for research participants and research procedures, in light of the current circumstances.

•  Research Staff Prepare to Work Remotely: Privacy and confidentiality provisions remain of paramount importance at all times. Consistent with University and Penn Medicine communications, clinical research staff should prepare for the possibility of working remotely.

1. Research teams should maintain secure contact information for research participants should they need to reach out to them. This should be stored on Penn-managed shared drives or PennBox for remote access. As an alternative, teams can use MyPennMedicine to reach out to research subjects.
2. Ensure that access to PHI and other protected clinical research information is enabled with all required securities in place.
3. Do not use personal email to conduct clinical research activities or communicate with patients.

If apparent immediate hazards will be sustained for a duration that would practicably allow for an amendment to cover such changes to be developed by an investigator and reviewed and approved, as appropriate, by the IRB, then approval of a protocol amendment must be sought.

If you have questions about this guidance, please send inquiries to:

• IRB related inquiries: PROVOST-IRB@pobox.upenn.edu
• Other research related inquiries: psom-ocr@pobox.upenn.edu

 

2/3/2020 - PRINCIPAL INVESTIGATOR COMPLIANCE ASSESSMENT (PICA) UPDATE (and correction):