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Clinical Trial Type | Applicable Clinical Trial (FDAAA 801; 42 CFR 11) | NIH Funded | International Committee of Medical Journal Editors (ICMJE)/ SJEG Member Journal |
Timeframe for Registration on ClinicalTrials.gov | Within 21 days after enrollment of first subject | Within 21 days after enrollment of first subject | Prior to first subject enrollment |
Timeframe for Results Submissions to ClinicalTrials.gov | Within 12 months after the primary completion date | Within 12 months after the primary completion date | Not mandated in policy, but must meet the requirements of FDAAA 801 |
Potential Consequences of Noncompliance | - Identifying clinical trial record as non-compliant in ClinicalTrials.gov
- For federally funded trials, grant funding can be withheld if required reporting cannot be verified.
- Civil monetary penalties of up to $13,237 per study. Initial penalty has 30 days to resolve issue.
- Additional $13,237 per study, per day until resolved if unresolved at 30 days
| - May lead to suspension or termination of grant or contract funding.
- Can be considered in future funding decisions.
- Identifying clinical trial record as non-compliant in ClinicalTrials.gov
| - Inability to publish in ICMJE or affiliated journal
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Temple is committed to full compliance with registration requirements. If you are noncompliant, the Office of Clinical Research and/or the LKSOM CRORA will contact you and potentially your department or research chair. University officials may administratively suspend your study, hold new IRB submissions or take additional actions.
Important Reminders
As a reminder, the NIH has enhanced its monitoring and oversight of the electronic Research Administration (eRA) Research Performance Progress Report (RPPR) system to ensure that NIH grant and cooperative agreement recipients conducting clinical trials are complying with their clinical trial registration and results reporting requirements as per 42 CFR Part 11 and NIHGPS section 4.1.3.1 - NIH Policy on the Dissemination of NIH-Funded Clinical Trial Information.
Investigators submitting a RPPR will receive registration and/or results reporting errors that will prevent RPPR submission if their clinicaltirials.gov registration is incomplete or if results are due. To resolve registration errors, the recipient will be required to either provide the NCT number issued by ClinicalTrials.gov, or provide the ClinicalTrials.gov registration receipt that is received upon submission of the trial registration information to ClinicalTrials.gov. To address delinquent clinical trial results reporting errors, the recipient will need to submit the trial results information to clinicaltrials.gov.