MSU HRPP Manual Section 7-9-C
ClinicalTrials.gov Requirements: Required Updates under 42 CFR 11
This section provides requirements for updates to clinical trial information by the Responsible Party on ClinicalTrials.gov when complying with 42 CFR 11, which implements section 402(j) of the Public Health Service Act (42 U.S.C. 282(j)).
These requirements apply to Michigan State University (MSU) individuals who are designated as the Responsible Party for an Applicable Clinical Trial (ACT) or a clinical trial that was voluntarily registered under 42 CFR 11.
See HRPP Manual Section 7 for ClinicalTrials.gov regulatory requirements and MSU processes and requirements for ClinicalTrials.gov.
Updates to Required Registration Information
What updates are needed to required registration information depend on when the clinical trial was initiated. The following sections describe what updates are required for clinical trials initiated before January 18, 2017 or on or after January 18, 2017.
1. ACTs Initiated Before January 18, 2017
If registration information was required to be submitted and the ACT was initiated before January 18, 2017, the following updates must be submitted by the Responsible Party in the specified timeline:
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ACTs Initiated Before January 18, 2017 |
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Time frame |
Change |
Data Element Update |
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Not later than 30 calendar days after: |
Change in overall recruitment status |
Overall Recruitment Status |
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Clinical trial reaches its actual primary completion date |
Primary Completion Date |
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Not less than once every twelve months: |
Changes to the registration information that was required at the time of submission |
Registration data elements that were required at the time of submission (specified in 402(j)(2)(A)(ii) of the Public Health Service Act (42 U.S.C. 282(j)(2)(A)(ii)) |
2. ACT or Voluntary Clinical Trial Initiated On or After January 18, 2017
If registration information was required or voluntarily submitted and the clinical trial was initiated on or after January 18, 2017, the following updates must be submitted by the Responsible Party in the specified timeline:
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ACT or Voluntary Clinical Trial Initiated On or After January 18, 2017 |
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Time frame |
Change |
Data Element Update |
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Not later than 15 calendar days after: |
Change in device approval or clearance status has occurred |
Device Product Not Approved or Cleared by U.S. FDA |
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Not later than 30 calendar days after: |
First human subject is enrolled (if the first human subject was not enrolled in the clinical trial at the time of registration) |
Study Start Date |
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A non-proprietary name is established for any intervention included in the Intervention Name(s) data element |
Intervention Name(s) |
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Any change in overall recruitment status |
Overall Recruitment Status |
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Overall Recruitment Status is changed to “suspended,” “terminated,” or “withdrawn,” |
Why Study Stopped |
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Change in status for any individual site |
Individual Site Status |
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Change in status for human subjects protection review board |
Human Subjects Protection Review Board Status |
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Clinical trial reaches its actual primary completion date |
Primary Completion Date |
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Primary completion data changed to “actual” |
Enrollment data element specifying the actual number of participants enrolled |
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Clinical trial reaches its actual study completion date |
Study Completion Date |
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Change in the Responsible Party or the official title of the Responsible Party |
Responsible Party, by Official Title |
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Change in the Responsible Party or the contact information for the Responsible Party |
Responsible Party Contact Information |
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Protocol is amended in such a manner that changes are communicated to human subjects in the clinical trial and the protocol amendment is approved by a human subjects protection review board |
Updates to any relevant clinical trial registration information data elements |
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Not less than every 12 months: |
Changes to clinical trial registration information |
Registration data elements that were required at the time of submission (specified in 42 CFR 11.28) |
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Not less than every 12 months, or any time the Responsible Party reviews the complete set of submitted clinical trial information for accuracy: |
Any time the Responsible Party reviews the complete set of submitted clinical trial information for accuracy, even if no other updated information is submitted at that time |
Record Verification Date |
3. Expanded Access
The following updates related to expanded access must be submitted by the Responsible Party in the specified timeline:
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Expanded Access |
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Time frame |
Change |
Data Element Update |
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Not later than 30 calendar days after: |
Expanded access becomes available, if expanded access to an investigational drug product (including a biological product) becomes available after an applicable clinical trial of that product has been registered, the Responsible Party, if both the manufacturer of the investigational drug product (including a biological product) and the sponsor of the applicable clinical trial |
Availability of Expanded Access data element for that applicable clinical trial and, unless an expanded access record has already been created as required by § 11.28(a)(2)(ii)(H), submit the data elements in accordance with § 11.28(c) to create an expanded access record |
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Date on which the Responsible Party receives an NCT number for an expanded access record (created as required by 42 CFR 11.28(a)(2)(ii)(H)) |
Availability of Expanded Access data element by entering the NCT number in the clinical trial record for the applicable clinical trial |
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Change in the availability of expanded access to an investigational drug product (including a biological product) under section 561 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360bbb) |
Expanded Access Status, under § 11.28(c)(2)(iv) (Expanded Access Record) |
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Change in the type(s) of expanded access available for an investigational drug product (including a biological product) under section 561 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360bbb). |
Expanded Access Type, under § 11.28(c)(1)(x) (Expanded Access Record) |
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When Results Information Initially Submitted |
Clinical trials registration information |
If the clinical trial was initiated on or after January 18, 2017, update clinical trial registration information in accordance with 42 CFR 11.64(a)(1)(ii)If the clinical trials was initiated before January 18, 2017, update linical trial registration information in accordance with 42 CFR 11.64(a)(1)i) |
Results Updates
Results must be updated by the Responsible Party for the clinical trials that have a primary completion date on or after January 18, 2017 and are:
- An ACT
- Another clinical trial for which results information was voluntarily submitted (42 CFR 11.60(b), 42 CFR 11.60(c))
1. Results Updates
The following updates must be submitted by the Responsible Party in the specified timeline:
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Results |
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Time frame |
Change |
Data Element Update |
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Not less than once every 12 months. |
Changes to required clinical trial results information, other than:·
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Required results data elements |
2. Applicable Device Clinical Trials of Unapproved or Uncleared Medical Products
The following updates related to applicable device clinical trials of unapproved or uncleared medical products must be submitted by the Responsible Party in the specified timeline:
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Applicable Device Trials of Unapproved or Uncleared Medical Products |
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Time frame |
Change |
Data Element Update |
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Not later than 30 calendar days after: |
A non-proprietary name is established for any intervention included in the Intervention Name(s) data element. |
Intervention Name(s) Intervention name must be updated to a non-proprietary name |
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Clinical trial reaches its actual primary completion date |
Primary Completion Date At the time the date is changed to “actual,” the Enrollment data element specifying the actual number of participants enrolled must be submitted |
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Clinical trial reaches its actual study completion date |
Study Completion Date |
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Any change in overall recruitment status |
Overall Recruitment Status If, at any time, Overall Recruitment Status is changed to “suspended,” “terminated,” or “withdrawn,” the Responsible Party must also submit the Why Study Stopped data element. |
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Not less than every 12 months, or any time the Responsible Party reviews the complete set of submitted clinical trial information for accuracy: |
Any time the Responsible Party reviews the complete set of submitted clinical trial information for accuracy and not less than every 12 months, even if no other updated information is submitted at that time |
Record Verification Date |
Quality Control by ClinicalTrials.Gov or Other Corrections
After clinical trial registration or results information has been submitted, electronic notification will be provided to the Responsible Party by ClinicalTrials.Gov of apparent errors, deficiencies, and/or inconsistencies in the submitted information identified during procedures for quality control. A Responsible Party may also become aware of errors, other than those provided through the ClincialTrials.Gov quality control process, in any clinical trial information.
The Responsible Party must correct or address all apparent errors, deficiencies, and/or inconsistencies identified in the notification in the time frame provided below:
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Results |
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Time frame |
Change |
Data Element Update |
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Not later than 15 calendar days after: |
Notification by ClinicalTrials.Gov of all apparent errors, deficiencies, and/or inconsistencies identified in the notification for clinical trial registration information |
Registration information |
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A Responsible Party who becomes aware of errors, other than those provided through the ClincialTrials.Gov quality control process, in any clinical trial registration information |
Registration information |
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Not later than 25 calendar days after: |
Notification by ClinicalTrials.Gov of all apparent errors, deficiencies, and/or inconsistencies identified in the notification for clinical trial results information |
Results information |
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A Responsible Party who becomes aware of errors, other than those provided through the ClincialTrials.Gov quality control process, in any clinical trial results information |
Results information |
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When Responsible Party's Obligation to Submit Updates or Correct Errors Ends
If Results Required
A Responsible Party's obligation to submit updates or correct or address errors ends on the date on which all required clinical trial results information has been submitted as specified in sections 402(j)(3)(C) and 402(j)(3)(I) of the Public Health Service Act (42 U.S.C. 282(j)(3)(C)) and 42 U.S.C. 282(j)(3)(I)) or as specified in 42 CFR 11.48, as applicable, and corrections have been made or addressed in response to any electronic notice received through the ClinicalTrials.Gov quality control process.
If No Results Required
If no clinical trial results information is required to be submitted, a Responsible Party's obligation to submit updates or to correct or address errors to clinical trial registration information ends on the date on which all required clinical trial registration information has been submitted as specified in section 402(j)(2)(A)(ii) of the Public Health Service Act (42 U.S.C. 282(j)(2)(A)(ii) or 42 CFR 11.28, as applicable, and corrections have been made or addressed in response to any electronic notice received through the ClinicalTrials.Gov quality control process.
Approved By
Vice President for Research and Innovation on 4-30-2025.
This policy and procedure supersedes those previously drafted.