Yale University Institutional Review Boards 100 CH.10 IRB Renewal Regulatory Review Checklist Protocol # Principal Investigator: Date Submitted: Reapproval w/ amend? YES Review Date: Staff reviewer_________ Approval Expiration Date: _______________ NO If yes, see change section Full Comm. Meeting Date: _____________ Expedited Review category: General Information PI Affiliation and Title: Note: Is special permission required to serve as PI? YES NO Human Subject Protection Training? YES NO HIPAA Training? YES NO YES NO Faculty Advisor: Names of those requiring HSPT or HIPAA Training: Signatures received? NA Conflict Of Interest completed? YES NO If No, who? _________________________ Transactional Review __________________ SFI ________________________________ IP _________________ No Protocol Related COI Disclosure in Consent? YES NO NA Funding Source Active? YES NO Source(s)________________________________ Expiration date(s)_______________________ _ (If DoD, Dept of Defense, DARPA, Dept of the Army, Navy or Air Force, DoD Supplement form is required) Sponsor protocol version # and date**: _______________________________________ C/M/grant number for federal funding: Are all active grants congruent? YES NO Study Status No enrollment to date Active open to Enrollment Enrollment progressing as planned Is enrollment within target range (N) for the study? YES NO Slower than planned, which will require study extension or reduction of planned number of subjects Enrollment closed Date enrollment closed: Participants still completing research interventions Follow up only (describe nature of follow-up) Data analysis only Secondary Data Analysis only Still in proposal stage 100 CH.10 – renewal Review Comments: IND** or IDE** YES NO NA Number: _____________ Name:______________________ Holder:*__________________ *If holder is PI, has the FDA requested changes? If so, we must obtain a copy of the request.** Required for INDs and IDEs: Investigator’s Brochure: Version/Date:_________________________ Noncompliance, Adverse Events , Deviations and Unanticipated Problems Have any noncompliance, serious, unanticipated adverse events or unanticipated problems, deviations or increased frequency of these events been reported? YES NO Are they on file? YES NO (Describe the issue and action taken, if any) Has the protocol lapsed? YES NO (If so, complete lapsed procedure.) Should any reports on file be considered by the full Committee? YES NO (If so, confer with Chair) Is there a valid Certificate of Confidentiality? Needs one? If Yes, Expiration Date (_____________) YES YES NO NO N/A Approval Criteria (45 CFR 46.111) Since the last review has anything occurred or is there any new information which may affect the risk/benefit ratio, either from the literature or from the Principal Investigator’s findings? YES NO If yes, please explain: Research Design remains sound YES NO (No new information that affects study hypothesis or risk/benefit assessment or acceptability of continuing study) Risks to subjects are minimized YES NO (Risks are well described; risks are reasonable in relation to potential benefits to subjects, or to the importance of knowledge that may result from the research) Risk assessment: Study qualifies as minimal risk Study is greater than minimal risk Potential for direct benefit? YES NO Subject selection remains equitable YES NO (Inclusion/exclusion criteria are appropriate; recruitment methods and materials are appropriate; rationale for number of subjects is justified; screening procedures are acceptable) Choose all that apply: Children* permission of one parent sufficient? YES Decisionally impaired* Economically Disadvantaged Employees* Females of childbearing potential(biomedical studies) Fetal material, placenta, or dead fetus ** Cite in letter/minutes Page 2 of 6 NO Non-English Speaking Is a translator needed? YES NO Pregnant women and/or fetuses* Prisoners* Students*, Psychology Pool Wards of the state 100 CH.10 – renewal Review If vulnerable populations - are appropriate provisions made? YES NO Recommended findings citing DHHS regulations and FDA regulations: **:_____________ If no, explain: Informed consent will be sought from each prospective subject or the subject's legally authorized representative. Does the consent process/form continue to be appropriate and adequate for the research? YES NO Consent continues to be obtained. Consent waived under 45 CFR 46.116(d). Not applicable to FDA research. All four criteria must be met: (1) The research involves no more than minimal risk to the subjects; (2) The waiver or alteration will not adversely affect the rights and welfare of the subjects; (3) The research could not practicably be carried out without the waiver or alteration; and (4) Whenever appropriate, the subjects will be provided with additional pertinent information after participation. Informed consent will be appropriately documented. Standard written consent form will be used. Short form consent will be used. Qualifies for waiver of documentation of consent under (45 CFR 46.117(c)(1) or (2)). Either criterion may be used. Does not waive the consent process. A HIPAA waiver is still required if applicable. Not applicable to FDA research. The consent document is the only record linking participant to research and the principal risk of the research is potential harm resulting from breach of confidentiality. If so, the participant must be asked whether s/he wants documentation linking him/her with the research and the participant’s wishes will govern. The research presents no more than minimal risk and involves no procedures for which written consent is normally required outside the research context. Information sheet will be used (no signature required) The research plan makes adequate provisions for monitoring the data collected to ensure the safety of participants. (Data and Safety Monitoring Plan is appropriate to level of risk; Data security plan is appropriate- this does not need to be one of the “formal” plans if study is minimal risk) YES NO There are adequate provisions to protect the privacy of subjects and to maintain the confidentiality of data. N/A Examples – anonymous data YES NO NA Consent Form(s): Indicate number of forms submitted. If reapproval, check file history for number of forms previously submitted. Note discrepancy. ___Adult (__Cases __Controls) ___Parental Permission ___Adolescent Assent ___Child Assent ___Non-English ___Compound Authorization ___ Information Sheet ___Other:________________________ Consent Requirements Yes Exculpatory language is excluded Includes statement that the study involves research The purpose and duration of participation for the study is described Procedures/experimental procedures are adequately described Risks and Anticipated benefits adequately described Description of alternative procedures or treatments Confidentiality provisions for identified data described ** Cite in letter/minutes Page 3 of 6 No n/a Comments/Concerns 100 CH.10 – renewal Review Consent Requirements Yes No n/a Comments/Concerns Yes No n/a Comments/Concerns Yes No n/a Comments/Concerns Description of compensation for injury, if any, if greater than minimal risk Description of availability of and information on how to obtain medical treatment, if any, if greater than minimal risk, including who to contact for research related injury Contact for questions about the research and rights as research participant research (including a local contact for international studies) Statement that participation is voluntary and that they may withdraw participation at anytime Statement that refusal to participate will not lead to penalty or loss of benefits Other Consent Considerations as applicable If the study involves the psychology subject pool, statement on other options to meet course requirements and pool contact information. FDA ClinicalTrials.gov language GINA language in the consent form Explanation of CoC protections Statement regarding potential for currently unforeseeable risks Circumstances where participation could be terminated by PI Potential costs to participants Consequences of withdrawal and any requirements for orderly withdrawal Provision of significant new findings Number of participant to be enrolled. Option that the sample or data be destroyed when they withdraw their participation from the study, if a subject withdraws his/her participation. Explanation that the samples or data will be anonymized and that sample or data destruction is not possible, if a subject withdraws his/her participation. Explanation about future banking and whether the subject can opt out of the future banking and still participate in the main study. A plan to re-contact minors providing assent for biological samples/data when they reach the age of majority. HIPAA Authorization Requirements List specific types of PHI that may be used or disclosed Description of foreseeable research uses and disclosures of PHI Identity or class of persons that are authorized to request use of or disclose the PHI? Identity or class of persons from whom the investigator may request PHI use or disclosure? Statement that the information may be redisclosed if individuals aren’t covered by HIPAA Statement of when the request for use or disclosure of his/her PHI will expire Statement of when PHI or other identifiable research materials will be destroyed, or not Statement of right to revoke authorization and exceptions to the right to revoke ** Cite in letter/minutes Page 4 of 6 100 CH.10 – renewal Review Changes Yes PI Check COI information. Personnel Check HRPP and HIPAA training. Check Yale affiliation. No Comments COI: YES NO Names of those requiring HSPT or HIPAA training: Funding Source Does it need congruency review? Congruency done: YES NO NA Expiration date of grant:__________________________ Population Is new population appropriate and does it now include a new vulnerable group? If so, which one(s)? Vulnerable group: YES NO If Yes, findings: ____________ Location Note: If country is Iran, Cuba, North Korea, Sudan, Syria, or Burma/Myanmar, advise PI to contact Don Deyo from G&C and copy Don and Jan on email to PI** (See http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/Programs.aspx) Are these locations considered ‘engaged’ in research? If so, has the other IRB approval been submitted? If not, remind Investigator in approval/SMR letter that this would be required prior to initiation of study activities at those locations. Embargoed country: YES NO Site IRB approval received: YES NO Collaborators/Affiliates Note new collaborator(s) affiliate(s), confirm appropriate FWA status. Risk Assessment If the amendment changes the risk assessment, note the new risk determination. New risk assessment: Revised DSMP: YES NO NA Has the data and safety monitoring plan been modified accordingly (if risk is increased)? Note: for changes to greater than minimal risk, In Case of Injury section in the application and consent document(s) may be required. Protocol procedures/ Protocol Updated: YES Has the protocol been updated? Measures, questions, interview prompts, focus group prompts, etc. Do the new questions change the assessment of risk for the study?: YES NO Consent form(s)/RAF/Waiver RAF/Waiver If yes, have all changes been incorporated? Changes incorporated: YES NO If there are subjects already enrolled, is reconsent recommended to inform previouslyenrolled subjects of new information (risks, etc.)? Reconsent necessary: YES NO ** Cite in letter/minutes Page 5 of 6 NO Consent 100 CH.10 – renewal Review Will re-consent be achieved verbally or via consent addendum? Consent waiver required for verbal re-consent. Does the amendment require changes to the RAF or waiver? Consent addendum: YES Certificate of Confidentiality Does the amendment require a CoC? YES NO NO **All asterisked items that relate to this protocol MUST be mentioned in the letter and meeting minutes (if full Committee). Check all that apply: Conflict of Interest Human Subject Protections or HIPAA Training Sponsor Protocol/Version/Date Grant Congruency (grant number and title) Vulnerable Population findings (also include FDA minors findings if applicable) External IRB approvals (or letters of support if applicable) International research site on embargoed list IND/IDE number or exemption granted FDA correspondence required or received/acknowledged Other Committee approvals Deception Third-party subjects Risk Assessment Waiver of Informed Consent or Waiver of Signed Consent (indicate if the waiver is for pre-screening activities, recruitment, and/ or the entire study) Waiver of HIPAA research authorization (distinguish between pre-screening waiver vs. recruitment waiver: waiver should be appropriately requested in the IRB application.). Amendment REQUIRED Coeus data entry at approval action: Risk Level CONFIRMATION of Required Coeus data entry after approval action (check all that apply and make necessary updates): Billable Personnel updates Area(s) of Research Funding Source(s) Special Review Categories (e.g., congruency, C-o-C, consent and/or HIPAA waivers, external IRB or other Committee approvals, prisoner category, etc.) NOTES/COMMENTS: ** Cite in letter/minutes Page 6 of 6