Modifications to Previously Approved Research

Investigators are required to submit proposed changes to IRB-approved or exempt certified studies prior to implementing any changes. The Modification Submission electronic form in Cayuse Human Ethics is used to propose changes to an existing study. 

The only exception to this requirement is when a change is necessary to eliminate apparent immediate hazards to subjects. In such a case, a Modification Submission should be submitted promptly following its implementation and so that the change can be reviewed by the IRB/ORCA to determine that it is consistent with ensuring the subjects’ continued welfare.

The UC Santa Cruz Institutional Review Board (UCSC IRB) Chair and/or IRB Chair’s designee(s) is responsible for reviewing and determining whether the proposed changes are minor or substantive in nature. This determination will dictate the level of review required. When a change is substantive - that is, it increases risks to subjects beyond minimal risk, or is a significant change in the study design - the change may need to be reviewed by the full IRB.

What are considered changes that need review?

The regulations and UCSC IRB policies require that anything outside of typographical errors or reordering of questions be reviewed and approved by the IRB/ORCA as a modification. This includes, but is not limited to, the addition of study team members, changes to study procedures or instruments (questionnaires, consent documents, recruitment materials, etc.), changes to subject populations or study locations, changes in recruitment/consenting procedures, changes in funding support, etc.

Creating a Modification Submission

  • Log in to Cayuse Human Ethics
  • Find your study on the dashboard in “Approved Studies” and select it. 
  • In the top right corner select the “+ New Submission” button.
  • Choose “Modification.”
    • If “Modification” is not shown as an option, contact ORCA.
  • Select the “Complete Submission” link and follow the instructions to fill out the submission.
  • When completing the submission:
    • Use language that could be understood by a layperson. Avoid jargon, and when unavoidable provide explanations.
    • Be sure the descriptions of human subjects research activities are consistent with the information provided in any related grant or contract applications.
  • When the submission is complete, follow the instructions for submitting.
  • The PI and the Co-PI (if applicable) will be sent emails with instructions for certifying the submission in Cayuse. Once all certifications are entered, the submission will be routed to ORCA.
  • Once ORCA has received the submission, you will receive an acknowledgment email.
  • If a RUSH review is necessary for a study, e.g., to meet a funding award deadline, forward the Submission Received email to orca@ucsc.edu adding “RUSH Review Request” to the beginning of the email subject line and including a clear justification for the request in the body of the email. ORCA will review the request and may reach out to the Primary Contact/PI for additional information in order to determine if a rush review is warranted.