Because data reviews are retrospective and largely observational in nature and, in general, exempt research studies are not controlled clinical trials, nor involving an FDA-regulated intervention, they would not need to be registered or reported on ClinicalTrials.gov.
However, the ICJME may have a different opinion if exempt research involves any of the following:
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Drugs;
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surgical procedures;
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devices;
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behavioral treatments;
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dietary interventions;
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process-of-care change.
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biomedical or health-related measures including pharmacokinetic measures and adverse events.