Adverse Events (AEs), Other Reportable Information and Occurrences (ORIOs), & Other Required Reporting

• Unanticipated Problems Guidance
• UM Adverse Events Reporting Timetable
• External Adverse Events Timetable
• Humanitarian Use Device (HUD) Reporting for HUDs under a Humanitarian Device Exemption (HDE)
• Other Reportable Information and Occurrences Timetable and Guidance

Please note that this guidance is for reporting to the IRBMED only and does not satisfy required reporting by an investigator to other internal or external oversight agencies or departments (e.g., the FDA, UMHS Compliance Office, DSMB, or Privacy Offices). Additional information regarding reporting responsibilities is found in the UM Human Research Protection Program Operations Manual, part 12.

IRBs are charged by Federal regulations, the Dean of the Medical School, and the University’s Vice President for Research with the oversight of human subjects research conducted by faculty, students, or staff of the University, the Medical School, and the University of Michigan Health System. This is a cooperative mission carried out through a relationship between the IRBs and investigators.

Human subjects research may include interactions and/or interventions directly with subjects or involve the collection or analysis of information created or received by the Health System in caring for its patients or from other private or public sources.

An essential element of human subjects protection is identifying, analyzing the causes of, and responding appropriately to expected and unexpected adverse events, as well as unanticipated problems involving risks to subjects or others. Investigators are required to identify and help analyze the events and to formulate responses.

The IRB is required to make independent judgments concerning the significance of events and information in the context of the research project and the need for changes to the study protocol and/or informed consent process to protect research subjects.

Adverse Events (AEs) are events that involve physiological, social, economic, or psychological harm to subjects. These adverse events may also indicate risks of harm to additional subjects or others. AEs include expected and unexpected harmful effects, and unexpected harms of an interaction or an intervention.

Instead of using the U-M Standard Timetable, investigators can propose a plan designed for their study. A study-specific plan is encouraged for minimal to moderate risk studies that are not under FDA oversight. Many sponsored studies include an AE reporting plan. Know your options! For more information, view the Study-Specific Adverse Event (AE) Reporting Plans guidance.

• the test article or test procedure
• other aspects of the interaction or intervention
• the subject’s underlying condition
• the subject’s concurrent standard treatment
• research information that is disclosed inappropriately.

AEs may be definitely related, probably related, possibly related, unlikely to be related, or definitely not related to the research. To be considered “related” to the research does not simply mean caused by a test agent like a survey, an investigational drug or device, but encompasses all procedures that are done solely for research purposes (i.e. they would not have taken place had the subject not been in the study).

AEs may be observed in the specified project or in other research settings similar to that of the specified project, or in projects involving a similar intervention.

Regulations require investigators to report information and events beyond adverse events. Events in which no one suffered an adverse event (i.e. actual harm) but indicate risk(s) of potential adverse events must be reported. The IRB must be apprised of reports from other oversight entities that are received by an investigator such as a report from the FDA, DSMB, or an analysis from the sponsor. Also, any event or information that may increase risks, may alter the risk-benefit assessment, may affect subjects’ willingness to participate in the research, or may represent a departure from applicable human subject protection regulations or policies. Investigators must also report any/all changes in research, including closure of accrual or completion of a study.

Please see the ORIO page for more details.

Some AEs and ORIOs require special attention by investigators and IRBs when they meet the criteria of constituting a Unanticipated Problem. Unanticipated Problems meet all of the following criteria:

1.  Unexpected (in terms of nature, severity, or frequency);

2.  Related or possibly related to participation in the research; and

3.  Suggests that the research places subjects or others at a greater risk of harm than was previously known or recognized.

See the Unanticipated Problems Involving Risks to Subjects or Others page and U-M HRPP Operations Manual Part 12.III.B.1.a for more details.