Modification Requests

If you have an approved E-IRB application, please see the E-IRB Video Tutorial on how to "Create a Modification Request".

 

For Exemption Applications approved external to E-IRB, Modifications and Other Reviews (Unanticipated Problem, Protocol Violation, Deviation/Exception), should still be submitted electronically in PDF format to IRBSubmission@uky.edu

Instructions for submitting via e-mail

All IRB forms and study documents should be submitted as one PDF that is readable, searchable, and contains standardized bookmarks. E-mail completed PDF submissions to the Office of Research Integrity at irbsubmission@uky.edu. You will receive an automated notification of receipt. 

  • Only have Adobe Reader? To perform OCR and bookmark, download Adobe Pro.
    • Step-by-step instructions on how to prepare your MR [PDF]

Policies/Guidance

  • Modification - IRB Review of Changes SOP (Revised 3/15/19) [PDF]
  • Guidance on Expedited Review of Minor Changes in Previously Approved Research [PDF]
  • IRBs may utilize expedited procedures to review a proposed change to previously approved research if it represents a minor change. 

Definitions

Consent/Assent

If the proposed changes necessitate a change in the consent/assent form(s), then a revised consent/assent document in which the changes are underlined should be submitted. Also include a clean copy of the revised consent document(s) without underlining. If approved, the clean copy of the revised consent document(s) with the valid "IRB Approval" stamp will accompany the approval letter. If you have an E-IRB approved application, please see the E-IRB Video Tutorial "Create a Modification Request" and "Add Informed Consent Section Attachments".

If requesting either a waiver from the requirement for the informed consent process, or a waiver from the requirement for obtaining documentation of the informed consent process, complete the corresponding form and submit it with the modification request materials (see "old" Form E [PDF] or Form F [PDF] if not in E-IRB yet).

Deviation

A one-time departure from the current IRB approved protocol once a subject has actually been enrolled is considered a protocol deviation.  Examples: drawing a 13th tube of blood from a subject where the protocol specifies that 12 samples will be collected for the study; or, instituting a procedure on one or more enrolled subjects that is not specified in the protocol.

Exception

A one-time enrollment of a research subject in a protocol that fails to meet current IRB approved protocol inclusion criteria, or falls under protocol exclusion criteria, is considered a protocol exception. Examples: enrollment of a 70 year old patient when the inclusion criteria specifies 25-65 years of age; or, enrollment of a patient with a serious disease that is precluded from participation in the protocol exclusion criteria.

It is IRB policy that deviations and/or exceptions to IRB approved protocols be reviewed and approved prior to their implementation. Most sponsors also require approval prior to implementation of any deviations from the protocol. You may use the IRB's Modification Request Form [Word] [PDF] to submit a request to the IRB for a deviation or exception to a currently approved protocol or if you have an approved E-IRB application, please see the E-IRB Video Tutorial "Create a Modification Request" and follow the instructions.

Please note, a deviation and/or exception should be a one-time event and IRB approval for its implementation does not change the entire protocol.

Extension of Project End Date

If the research study is expected to extend beyond the estimated project end date initially approved by the IRB, then the investigator should submit a request for an extension of time to the Office of Research Integrity.

Modification of a Currently Approved Protocol

A modification is defined as any change to a protocol from what was previously approved during the period for which approval was given. Changes in research procedures, the informed consent process, and/or the consent/assent document cannot be initiated by the investigator without IRB review and approval, except where necessary to eliminate apparent immediate hazards to the subject.  Should protocol changes be made without prior IRB approval to eliminate apparent hazards to the subject(s), submit a memorandum immediately to the IRB addressing the nature of the change, why it was necessary, and the outcome.  

Information relating to protocol modifications should be relayed to subjects when such information might relate to the subject’s willingness to continue to take part in the research. How this information will be relayed to the subject (e.g., through a re-consent process using a modified consent form, or a letter sent to the subject) should be included in a modification request, and IRB approval obtained prior to implementation. 

Discontinuing a study (e.g., PI leaves UK) or completion of a study is considered a change in the protocol’s status and therefore the IRB should be promptly notified in writing. See the Continuation Review SOP [PDF] and the Study Closure SOP [PDF] for procedures on reporting an activity status change to the IRB.  If the investigator fails to notify the IRB about discontinuation or completion of a study, then he/she will continue to be responsible for completing the Continuation Review report requests.

If your currently approved application has not yet been established in E-IRB and a modification request needs to be approved, email a completed Modification Request Form [Word] [PDF] with related materials to the Office of Research Integrity.  If you have an approved E-IRB application, please see the E-IRB Video Tutorial on how to "Create a Modification Request" and follow the instructions.

Approval of the modification request is on the advice of the IRB chairperson or a designated representative unless the nature of the proposed changes warrants review by the full IRB. The IRB may determine the modification relates to subjects’ willingness to continue to participate in the research, and request that the PI relay pertinent information to subjects. The investigator is notified in writing of the IRB’s decision. 

Protocol Violation

If either a protocol deviation or protocol exception occurs without prior IRB review and approval, the Principal Investigator is responsible for completing a Protocol Violation Report Form and submitting to the IRB for review within 14 days of the occurrence. If applicable, the Principal Investigator is responsible for reporting protocol violations to the sponsor, and/or FDA.

Recruitment Materials

If the modification request involves the addition or revision of recruitment materials such as advertisements, the IRB reviews the recruiting materials to assure that it is not unduly coercive and does not promise a certainty of cure beyond what is outlined in the consent and the protocol. In addition, print and media advertisements to the public are required to be reviewed by UK Public Relations (PR) for compliance. The Center for Clinical and Translational Science) collaborates with the Office of Research Integrity (ORI) and Public Relations (PR), to streamline both the PR and IRB approval processes by incorporating a number of checks and balances to promote compliant advertisement development, preferably at the beginning. Visit CCTS's web page for more details and contact information. 

Sponsor Initiated Changes

The IRB is responsible for assessing additional risks or benefits when conducting review of proposed changes. Please understand it is difficult to make these assessments based upon detailed, lengthy summaries of the amendments from the sponsor without a short summary from the investigator. All amendments should be submitted using the Modification Request Form, and include a short letter signed by the principal investigator, summarizing the key changes in the amendment that will affect the study procedures for the subjects and, thus, may alter the risk-benefit ratio. If the proposed changes necessitate a change in the consent/assent form, then a revised consent/assent form in which the revisions are underlined should be submitted. Also, one clean copy of the revised form without underlining should be submitted.

Study Personnel/PI

If the modification request for a study not yet established in E-IRB involves updating study personnel, use the Study Personnel List Template [WORD] [PDF] (or the General Information Sheet in the IRB Initial Review application) to list all study personnel (SP) who should be approved by the IRB (including SP previously approved who continue to hold responsibilities with the study). The list of all SP should accompany the completed Modification Request Form. Changes from the previously approved study personnel list should be described in the space provided on the Modification Request Form, or attachment(s).  Please confirm new SP have completed the mandatory human subject protections training and all existing SP are up-to-date on training BEFORE you submit your modification request to ORI. See the Human Subject Protection Training FAQs webpage for frequently asked questions on training requirements.  If study personnel changes are needed on a study established in E-IRB, review the E-IRB Video Tutorial on how to create a Modification Request and then follow the instructions on the Study Personnel section page.

Note that a change in the principal investigator (PI) for studies not yet established in E-IRB should be reported to the Office of Research Integrity and an updated GENERAL INFORMATION SHEET submitted. If the address or contact person to whom correspondence should be sent has changed, notify the Office of Research Integrity in writing with a memorandum signed by the principal investigator.  If the PI is leaving the University, and research activities are to be continued at the University under the direction of another investigator who is affiliated with these institutions, then a request for approval of a change in investigator must be submitted to the IRB by the current PI. The new PI should include a completed Signature Assurance Sheet (Form Z) with the request.  If a PI change is needed for a study established in E-IRB, review the E-IRB Video Tutorial on how to create a Modification Request and how to Change Principal Investigator and follow the instructions.

Vulnerable Populations

If the modification request for a study not yet established in E-IRB involves adding a vulnerable population (e.g., children, pregnant women, decisionally impaired, prisoners), complete the corresponding form (see Form T, or "old" U [WORD], V [WORD], or W [WORD]) and include it with your modification request submission. If changes to the subject population is needed for a study established in E-IRB, review the E-IRB Video Tutorial on how to create a Modification Request and follow the instructions on the Subject Demographic section page.

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