Submitting an individual exception request requires use of the most recent version of the Exception Request Form (Click here to download)
What is an Exception Request?
An exception request is a prospective, one time, intentional action or process that departs from the IRB approved study protocol, intended for a single occurrence. In essence, an exception request is a prospective deviation.
Prospective- This means that the study team plans to perform study activity outside of the parameters and procedures set forth in the IRB-approved protocol. If an exception is submitted to the IRB for approval after it has already taken place, it is then considered a deviation regardless of whether sponsor or other monitoring approvals were obtained in advance.
Intentional- An exception request will not be approved if it was unintentional. For example, if a subject is enrolled and later it is discovered that they met an exclusion criteria but will be allowed to continue on the study- this should be submitted as a deviation NOT an exception as this was not planned prospectively and was unintentional. Retrospectively submitting a deviation as an exception request will not be approved.
One-time request intended for a single occurrence- Each time an exception is to be implemented separate IRB approval must be obtained. If the same exception request is submitted multiple times for the same study, the IRB may suggest or require a change to the protocol to eliminate the need for repeat or common exceptions.
Penn Medicine researchers conducting clinical research should also review the Office of Clinical Research Guidance entitled: Recording, Assessment, and Reporting of Deviations Guidance to Investigators Participating in Clinical Research
Steps to Submit an Exception Request in HSERA or for Paper study
Step 1. Log into In HS ERA.
Step 2. Under “My Submissions” in the blue column on the left side of the screen choose “Create”.
Step 3. On the next page select “Exception”.
Step 4. On the next page Search for and select the relevant protocol.
Step 5. Complete all text box fields on page 1 with "See attached Form" then click "Next" at the bottom of the page (the application will eventually be updated to remove these fields and replace them with an area to attach your completed form)
Step 6. Attach the completed exception request form and any related documents by clicking the green "attach form" button. After all your documentataion has been attached, click the blue "I accept" button.
Step 7. After clicking "I Accept" the application will be sent to the Pi for approval (if the PI was not the person who created it) Once the PI approves the submission it will be received by the IRB for review.
Paper Submission- If your study is older than the HSERA system and is documented on paper, start by downloading and completing the exception request form.Once complete the exception request form and all supporting Documentaion can be mailed to the address noted at the top of our submission forms or sent via University Intramural mail service to mailing code 6009.
How to request rush review of an Exception
E-mail Submission for RUSH Approval-Start by downloading and completing the exception request form. If time is of the essence and you need a rush exception (approval in less than 24 hours), the completed exception request form should be emailed along with all supporting documentation.The Emailed materials should include a sound rationale that clearly describes why the request requires rush approval.
In the case of rush exceptions it may not be feasible to obtain PI signature on the form. In these situations please include an email from the PI approving the exception request as a supporting document. Please be sure to CC the PI on your exception request email to the IRB. When submitting via email for a study registered through HS ERA, a formal submission of the exception through HS ERA will still be required after the exception request has been processed. When submitting via email a signature on the form may be required if the PI is not going to be the one sending the email submission.
All Rush Exception requests should be emailed to the following group:
What information must be included with the exception request submission?
For review of exception requests the IRB requires the following information:
- Documented approval from the study sponsor, medical monitor and other oversight entities as applicable
- A description of the exception including references to the current protocol, proposed date, rationale, clarification as to why the action is one time, and any plans for communicating the exception to subject
- Assessment of increased risk involved in the exception
- Assessment of subject benefit from the exception
- Assessment of impact of the exception on data integrity
- Declaration of time sensitivity and applicable rationale
How does the IRB review exception requests?
Rush exception requests received via email are assigned for immediate processing.
For exception requests that are not time-sensitive, IRB review and screening of the submission will occur in alignment with standard IRB processing. Upon receipt of an exception request, the action will be assigned to the appropriate IRB administrator and for screening and an assessment of the level of IRB review required.
The level of review required for exception requests (expedited or convened) is dependent upon the following factors:
- The time sensitivity of the request
- The level of risk involved in both the study itself and the planned alteration.
- Whether the exception request is thought to be in the best interest of the subject
- Whether the exception request holds out the prospect of direct benefit to the subject
- Whether the risk/benefit ratio specifically related to the exception request is favorable
- submission of revised consent or addendum to the consent
- plans to modify the protocol permanently
Expedited Review: Exceptions with potential safety implications require review by an IRB Chair or appropriate IRB physician scientist member. The following exceptions are eligible for expedited review:
- Exception requests where the planned exception poses no more than minimal risk to the subject
- Exception requests where the planned exception may pose greater than minimal risk to the subject but the request is time sensitive and
- The exception is in the best interest of the subject and/or the prospect of direct benefit exists
- The risk/benefit ratio for the proposed exception request is favorable
Convened Review: Review will be conducted by the full Board at the next planned meeting.
- Exception requests where the planned exception may pose greater than minimal risk to the subject and any of the following apply:
- It is unclear whether the exception is in the subject's best interest or whether there is the prospect of direct benefit to the subject
- It is unclear whether the risk/benefit ratio is favorable
- The request is not time sensitive and there is sufficient time to allow convened IRB review to occur
Enrolling Participants with Limited English Proficiency or Non-English Speaking Participants
Guidance on the incidental inclusion of participants who are not fluent in English is online here: https://irb.upenn.edu/mission-institutional-review-board-irb/guidance/recruitment-and-consent under Incidental Inclusion of Subjects not Fluent in the English Language & IRB Consent Short Form Translations.
Please review this guidance prior to submitting an exception request to enroll a participant with limited English proficiency or non-English speaking participants.