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NHLBI Adverse Event and Unanticipated Problem Reporting Policy


The purpose is to describe the National Heart, Lung, and Blood Institute (NHLBI) extramural programs’ policy and procedures for adverse event (AE) and unanticipated problem (UP) reporting.


This policy applies to all human subjects research funded in whole or in part by NHLBI extramural programs.


Sponsor: The Food and Drug Administration (FDA) regulations define the sponsor of a clinical trial (21 CFR 50.3) as the person or entity who initiated the trial. NIH guidance elaborates on the definition and provides examples.

Refer to NHLBI Clinical Research Guide Glossary for additional terms not identified.


4.1 Policy

All human subjects research supported by NHLBI must include procedures for identifying, monitoring, and reporting all AEs, including both serious (SAE) and non-serious events, and UPs. All NHLBI human subjects research will follow a uniform policy, which is based on the FDA/Office for Human Research Protections (OHRP) regulations and guidance including definitions and timelines, as outlined in Sections 4.2 and 4.3.

4.2 Reporting Procedures and Requirements

Procedures for identifying, monitoring, and reporting AEs and UPs must be described in the study's Institutional Review Board (IRB)-approved data and safety monitoring (DSM) plan that is submitted to the NHLBI (see NHLBI Data and Safety Monitoring Policy). AE and UP reporting should include at a minimum:

  • Expedited reporting of serious and unexpected, suspected adverse reactions to the NHLBI based on the definitions and timelines in FDA regulations and/or OHRP guidance. For multi-center studies, this includes procedures for notifying all participating IRBs through the local investigator.
  • For all AEs and UPs, individual and summary reporting to local IRBs on a schedule consistent with IRB-written procedures and consistent with FDA/OHRP regulations and guidance.

A monitoring person or body, such as a Data and Safety Monitoring Board (DSMB), may require additional expedited reporting. The program official will confirm with the principal investigator that any UP has been reported to the appropriate IRBs and that all corrective action/preventative action plans have been adequately implemented.

4.3 Reporting Timelines and Guidance

  • Refer to the table below for SAE and UP safety reporting requirements and timelines for clinical research funded in whole or in part by NHLBI extramural programs.
    • Note that in some cases, more than one set of regulations/guidance may apply to a specific event. For example, in a study with FDA-regulated products, an UP that is also an SAE would require compliance with both FDA regulations and OHRP guidance.
    • Reporting timelines for all non-serious AEs should follow the IRB-approved Data and Safety Monitoring Plan for the study.

SAE and UP Event Reporting Timelines

What Event is Reported

When is Event Reported

By Whom is Event Reported

To Whom is Event Reported

Fatal or life-threatening unexpected, suspected serious adverse reactions

Within 7 calendar days of initial receipt of information


  • Local/internal IRBs
  • NHLBI and/or Data Coordinating Center (DCC)

Sponsor or designee1

  • FDA (if IND study)

Non-fatal, non-life-threatening unexpected, suspected serious adverse reactions

Within 15 calendar days of initial receipt of information


  • Local/internal IRBs/Institutional Officials
  • NHLBI and/or DCC

Sponsor or designee

  • FDA (IND/Marketed Products)
  • All participating investigators

Unanticipated adverse device effects

Within 10 working days of investigator first learning of effect


  • Local/internal IRBs
  • NHLBI and/or DCC

Sponsor or designee

  • FDA (if IDE study)

Unanticipated Problem that is not an SAE

Within 14 days of the investigator becoming aware of the problem


  • Local/internal IRBs/Institutional Officials,
  • NHLBI and/or DCC

All Unanticipated Problems2

Within 30 days of the IRB’s receipt of the report of the UP from the investigator.


  • OHRP


  • External IRBs

1. Designee is appointed by the sponsor; for example, DCC, CRO.
2. Per OHRP guidance: only when a particular AE or series of AEs is determined to meet the criteria for an UP should a report of the AE(s) be submitted to the IRB at each institution under the HHS regulations at 45 CFR part 46. Typically, such reports to the IRBs are submitted by investigators.
3. Investigators should also take into account local IRB guidance if reporting timelines for UPs are shorter than OHRP guidance


Revision Record

Preceding Policies Date Issue

Adverse Event Tracking in NHLBI-Supported Clinical Research Studies

April 2004

Policy for Reporting Clinical Study Serious Adverse Events

May 2002


For additional information contact the NHLBI Program or Program Official associated with your study. Questions and comments regarding this policy may be directed to Katharine Cooper-Arnold, Office of Clinical Research, NHLBI.

For questions and/or concerns regarding the content of this page, please contact the
Clinical Research Policy Manager


Last Updated: November 2013

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