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How and When a Principal Investigator Should Report Death of a JHM Research Participant

August 2010

The Organization has a policy requiring prompt reporting of the death of a JHM participant when a JHM participant dies within 30 days of receiving a study intervention (Policy 103.6(b)(i)).

What does “JHM participant” mean?

A “JHM participant” is defined as an individual enrolled in a research study either that is conducted at a Hopkins’ facility or conducted off-site under the direct supervision of a Hopkins’ principal investigator at a non-Hopkins site.

What does “unexpected” and “expected” death mean?

  1. An “unexpected” death is defined as the death of a participant that was not related to a risk of participation that was listed in the protocol or consent document, and was more likely than not caused by the research procedures and/or study interventions (possibly, probably, or definitely).
  2. An “expected” death is defined as the death of a participant due to the nature of the participant’s underlying disease or condition, or identified as caused by a possible risk of the study procedure as described in the protocol and consent form

What does “prompt reporting” mean in the case of the death of a JHM participant?

  1. Unexpected Death of a JHM participant:  Prompt reporting for a death of a JHM participant at any JHM site which was unexpected must be reported to the IRB no later than 3 working days of when the PI receives the report of death.
  2. Expected Death of a JHM participant:  Prompt reporting for a death of a JHM participant which was expected must be reported to the IRB as soon as possible after the PI learns of the event, but in all cases no later than 10 working days. 

Reports of death of a JHM participant must be submitted to, and reviewed by, the JHM IRBs.  In eIRB, the PI must submit a Further Study Action, and use the Problem/Event activity.  For paper studies, the PI must submit form R.F. 2:  Report of Death of a JHM Research Participant. 

What are the exceptions to “prompt reporting”?

  1. When a JHM participant dies more than 30 days after she/he has stopped or completed all of the study procedures, interventions, and/or required follow-up the PI does not have to report the death promptly when the PI learns of the event.  In this situation, the death may be reported as part of the next Continuing Review application for IRB review.   
  2. If the PI receives information of the death of a JHM former participant who did not complete the protocol for whatever reason (including voluntary withdrawal or removal by the PI) the PI is to report to the IRB the former participant’s death as part of the next Continuing Review application for IRB review.
  3. PIs of protocols that do not include a research intervention and are only tracking outcomes in an observational study design do not have to promptly report deaths of JHM participants.  These deaths may be reported to the IRB in the Continuing Review application.

What is a study intervention?

A study intervention may include any of the following items: 

  • Drugs, devices, biologics, dietary supplements, complementary and alternative medicines (CAMs), or physical procedures that are specified by the protocol; or
  • Behavioral interventions (examples could include drug or alcohol counseling, delivery of mental health services, or psychiatric non-pharmacological interventions) that are specified by the protocol.  The Organization recognizes that participants enrolled in research projects that include behavioral interventions often withdraw completely from a study and may not complete all study follow-up procedures.  For such research projects, the PI should report promptly the death of a research participant for whom the behavioral interventions: a) have not been completed   and/or b) the participant is still within the time period between the start of the study and the proposed last follow-up.  

What should an investigator do if a sponsor’s requirement for reporting deaths of participants differs from the JHM requirement?

Sponsors (both federal and commercial) may have different reporting requirements when a participant dies.  The PI is responsible for meeting both the sponsor’s requirements and the JHM requirements.  Check with the sponsor to assure all reports are submitted in compliance with the sponsor’s requirements. 




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