The Clinical Research Center Research Practice Manual. Guideline for Study Document and Data Handling RPG-08. Guideline. Purpose.

Similar documents
Good Documentation Practices. Human Subject Research. for

HIC Standard Operating Procedure. For-Cause Audits of Human Research Studies

Checklist prior to recruiting first patient

Regulatory Binder Checklist for FDA-Regulated Sponsor/Sponsor-Investigator Studies

VCU Clinical Research Quality Assurance Assessment

Research Audits PGR. Effective: 12/04/2013 Reviewed: 12/04/2015. Name of Associated Policy: Palmetto Health Administrative Research Review

Standard Operating Procedure (SOP) Research and Development Office

Trial set-up, conduct and Trial Master File for HEY-sponsored CTIMPs

Trial Management: Trial Master Files and Investigator Site Files

Hertfordshire Hospitals R&D Consortium Incorporating West Herts Hospitals NHS Trust and East & North Herts NHS Trust

Standard Operating Procedures

The GCP Perspective on Study Monitoring

CLOSE OUT VISIT REPORT (NO CRF TO MONITOR)

STANDARD OPERATING PROCEDURE SOP 710. Good Clinical Practice AUDIT AND INSPECTION. NNUH UEA Joint Research Office. Acting Research Services Manager

Good Clinical Practice: A Ground Level View

Unofficial copy not valid

GCP: Investigator Responsibilities. Susan Tebbs Nicola Kaganson

Document Title: Study Data SOP (CRFs and Source Data)

I2S2 TRAINING Good Clinical Practice tips. Deirdre Thom Neonatal Nurse Coordinator

Investigator Site File Standard Operating Procedure (SOP)

Self-Monitoring Tool

Study Management PP STANDARD OPERATING PROCEDURE FOR Safeguarding Protected Health Information

ACTIONS/PSOP/001 Version 1.0 Page 2 of 6

GCP INSPECTION CHECKLIST

Standard Operating Procedure. Essential Documents: Setting Up a Trial Master File. SOP effective: 19 February 2016 Review date: 19 February 2018

Research & Development. Case Report Form SOP. J H Pacynko and J Illingworth. Research, pharmacy and R&D staff

Documenting the Story of a Clinical Trial: Concept to CAPA. Lori T. Gilmartin Gilmartin Consulting LLC

SOP: New Revised Reviewed Effective Date: 08 October Approved by : Supervisor/Manager Risk/Ethics Sr. Mgmt Committees Board/Councils

STANDARD OPERATING PROCEDURE SOP 325

1. INTRODUCTION 2. SCOPE 3. PROCESS

11/18/2016. UC Irvine s Clinical Research Coordinator Certification Preparation Series PI Roles and Responsibilities SESSION 4

4.2. Clinical Trial Monitor (or Monitor): The person responsible for monitoring the data on behalf of the sponsor or contract research organization.

AN OVERVIEW OF CLINICAL STUDY TASKS AND ACTIVITIES

QUALITY ASSURANCE PROGRAM

Clinical Trial Quality Assurance Common Findings

FDA Medical Device Regulations vs. ISO 14155

LOUIS STOKES CLEVELAND VA MEDICAL CENTER RESEARCH SERVICE Human Subject Protection Standard Operating Procedure (SOP)

WIRBinar. How to Survive an FDA Inspection. Upcoming Trainings: Contact Us: (360)

The Clinical Investigation Policy and Procedure Manual Document: CIPP

NN SS 401 NEURONEXT NETWORK STANDARD OPERATING PROCEDURE FOR SITE SELECTION AND QUALIFICATION

SARASOTA MEMORIAL HOSPITAL CANCER RESEARCH PROGRAM POLICY

Effective Date: 11/09 Policy Chronicle:

Study Start-Up SS STANDARD OPERATING PROCEDURE FOR PRE-STUDY SITE VISIT (PSSV)

Effective Date: April 2014 Revision: September 29, Executive Chair, Co-Chairs, NSHA REB Members, REB Office Personnel, Researchers.

Dr. R. Sathianathan. Role & Responsibilities of Principal Investigators in Clinical Trials. 18 August 2015

managing or activities.

Document Title: Informed Consent for Research Studies

Office of the Vice Chancellor for Research Supervisory Responsibilities of Clinical Investigators

Tomoko OSAWA, Ph.D. Director for GCP Inspection Office of Conformity Audit PMDA, Japan

STH Researcher. Recording of research information in patient case notes

Loyola University Chicago Health Sciences Division Maywood, IL. Human Subject Research Project Start-Up Guide

General Administration GA STANDARD OPERATING PROCEDURE FOR Sponsor Responsibility and Delegation of Responsibility

Essential Documents It s Not Just a Binder!

EMA Inspection Site perspective

QUALITY TIPS FOR CLINICAL SITES. Athena Thomas-Visel. Clinical Quality Consultant QUALITY TIPS FOR CLINICAL SITES

Local VA VA ORD CSP Other VA ORD. IRB of Record Registration Number: IRB Operated by: Local VA Non-local VA Academic Affiliate VHA Central IRB

Successful FDA Inspections at Investigative Sites for Clinical Trials of Drugs and Biologics

Site Closedown Checklist for UoL Sponsored CTIMP Studies

STANDARD OPERATING PROCEDURE SOP 715. Principles of Clinical Research Laboratory Practice

Overview ICH GCP E6(R2) Integrated Addendum

General Administration GA STANDARD OPERATING PROCEDURE FOR Document Development and Change Control

Mastering Clinical Research April 19, :30 am

20 STEPS FROM STUDY IDEA INCEPTION TO PUBLISHING RESEARCH/ Evidence-Based Practice

GCP Inspection by PMDA

Roles & Responsibilities of Investigator & IRB

SOP16: Standard Operating Procedure for Establishing Sites and Centres - Site Setup

Subject Research Records. Essential Regulatory and Source Documents. Subject Research Records. Regulatory Files

Storage and Archiving of Research Documents SOP 6

Investigator-Initiated Studies: When you re the Sponsor. Cheri Robert & Tammy Mah-Fraser

Introduction to the United States Food and Drug Administration (FDA) and FDA Inspection Process VOICE

Project Expense Considerations. Study Budgeting Considerations Research Staff and Trainees Expense Projected Expense Estimated Cost & Notes

Auditing of Clinical Trials

FDA Inspection Readiness

Standard Operating Procedures

INSPIRing Changes to the IRB Process: New templates and more

STUDY INFORMATION POST-IRB APPROVAL FDA DEVICE (IDE) SPONSOR AND INVESTIGATOR RESPONSIBILITY (21 CFR 812)

Training, Site Selection and Human Subject Protection: Factors to Consider When Developing a Monitoring Plan

Site Qualification and Training (SQT) INFORMATION AND GUIDANCE SHEET FOR SITE SIGNATURE AND DELEGATION OF RESPONSIBILITIES LOG

Joint R&D Support Office SOP S-2011 UHL

BIMO SITE AUDIT CHECKLIST

STANDARD OPERATING PROCEDURE

Document Title: Investigator Site File. Document Number: 019

Preliminary Questionnaire

Clinical Trial Readiness Checklist October 2014

INFORMED CONSENT TO PARTICIPATE IN A DIABETES RESEARCH REGISTRY

EMA & FDA Inspections: Site perspective. Shandukani Research Centre

Initially Submitted on 11/24/2009 Final Submission By Test6 CA on 11/24/2009 1:51 PM Approval By student13 student13 on 11/24/2009 1:52 PM Attendees

Colorado Board of Pharmacy Rules pertaining to Collaborative Practice Agreements

Risk Assessment and Monitoring

Record or Document Type Retention Period Relevant Legal Citation(s) IRB Records: Training Records;

Standard Operating Procedure Research Governance

Prepared by the American College of Radiology Imaging Network Protocol Development and Regulatory Compliance Department

Quality Assurance and Site Monitoring Visits. Introduction. Training Outline

Study Monitoring Plan Template

RITAZAREM CRF Completion Guidelines

STUDY TEAM RESPONSIBILITIES ORIENTATION FOR NEW CLINICAL RESEARCH PERSONNEL MODULE 2

STANDARD OPERATING PROCEDURE 24. Training Records

Theradex Audit 2013: Findings & Corrective Action

MHRA Findings Dissemination Joint Office Launch Jan Presented by: Carolyn Maloney UHL R&D Manager

Conducting Monitoring Visits for Investigator-Initiated Trials (IITs)

Transcription:

The Clinical Research Center Research Practice Manual Guideline for Study Document and Data Handling RPG-08 Purpose Guideline This Guideline provides functional definitions for common data management terms; guidance on the maintenance of study files, regulatory files and source documentation; and links to additional resources for obtaining information on documentation and data handling requirements within Children s Hospital Boston and various federal agencies. Definitions Case Report Form (CRF) a printed, optical or electronic document designed to record all of the protocol-required information to be reported to the sponsor on each trial subject. (ICH GCP 1.11) Regulatory Binder (or Files) - is the source that provides a complete and thorough history of the research study from protocol development to study completion. The binders or files include all study-specific information and regulatory documentation including IRB approved protocols, amendments, informed consent, case report forms, FDA 1571 and 1572 if applicable and recruitment materials. Source Data information contained within source documents that represent the original documentation of findings and observations of subjects participating in clinical research studies (ICH GCP 1.51) Source Documents original documents, data and records such as medical records, laboratory results, x-rays, pharmacy records and subject diaries. (ICH GCP 1.52) Procedure Research Study Files Prior to the start of the study, study staff should prepare a secure location for the storage of study data and supporting documentation. Research records should be locked when not in use and access should be restricted to authorized staff only. Security of research data may include maintaining a locked cabinet within an office, or storage within an office in a clinic that is locked when not in use. The following subsections describe research study files maintained for most clinical research studies. Investigators should refer to sponsor-specific requirements for study specific procedures.

Regulatory Binder/Files The regulatory binders or files include all regulatory documentation necessary for the conduct of the study. The Principal Investigator should designate a study staff member to assume primary responsibility for maintaining the regulatory files including all regulatory correspondence with the IRB, the study sponsor; and the FDA if applicable; the IRB approved protocols and amendments; the IRB approved informed consents, recruitment materials and other necessary regulatory documents. The organization and sequence of sections of the regulatory files may vary depending on the type of the study and is at the discretion of the Principal Investigator or study sponsor. The CHB Education Quality Improvement Program (EQuIP) provides guidance for constructing a study Regulatory Binder. Contact the EQuIP staff and/or visit the EQuIP web page for more information. http://www.childrenshospital.org/cfapps/research/data_admin/site2207/mainpages2207p0.ht ml Subject Files: The subject files contain all completed case report forms for the study subjects. CRFs that will be used as source documents should be signed and dated by the person completing the form. Typically, source documents and subject research data files are stored separately to maintain subject confidentiality. In the case that is necessary to store source documents with subject research data files, all subject identifiers and protected health information (PHI) must be removed or blacked out from the source document. Subject files are generally maintained in chronological order by Study ID number and by study visit within the unique subject folders; but document filing may differ by protocol and is at the discretion of the Principal Investigator. Paper and electronic CRFs Hard copy CRFs should be filed and stored electronically using systems that mimic procedures used to store hard copy files. Electronic CRFs require the installation of an electronic system that is validated within the infrastructure of the clinical research unit, ensuring its reliability and precision, as well as its expected performance. (ICH 5.5.3a. and FDA Guidance for Industry: Computerized System used in Clinical Trials.) Best practice methods for paper CRF management also apply to electronic CRF management, i.e. procedures are required for data collection, document protection, error detection and correction, electronic signature, audit trails, etc. Please refer to CRC Research Practice Guideline for Data Collection for specifics on how CRFs should be used for data collection. Study ID Assignment Log: The study ID assignment Log is an essential study document; it serves as the primary source for linking the subjects unique study identification numbers to the subjects identifiable, protected health information (PHI) such as name and medical record number. No two subjects should ever be assigned the same ID number, even if the original subject who was first assigned the ID number drops out or withdraws from the study. The Study ID Assignment Log might also be called the study Enrollment Log or Subject ID Log. The procedure of assigning a study ID to a subject may take many forms. One typical scenario is as follows: A potential subject is approached for entry in a research study. Informed consent is obtained and criteria necessary for enrollment are reviewed. The

subject is determined to be eligible. The study coordinator retrieves the study ID Assignments of study IDs occur in chronological order. As subjects are enrolled, they are assigned the very next available ID number on the log. See the Sample Study ID log below: ID name Name of Birth dd/yy) ct MRN 2 99 03 Enrolled dd/yy) Available ID as 5 67 03 0 88 03 Screening Log Some studies require extensive screening procedures to determine subject eligibility. For these studies, the Principal Investigator might choose to use a Screening Log in addition to the Study ID Log. When a Screening Log is used, potential subjects are initially assigned a screening ID number to be used when collecting screening data to determine eligibility or during the screening phase of the study. The screening log contains limited information about all potential subjects approached for enrollment in the study and will likely include reasons for ineligibility. Only those subjects that meet eligibility requirements and consent to participate will be enrolled in the study and only these subjects will be entered on the Study ID Assignment Log and assigned a final study ID. (See the at the end of this document). Source Documents: Source documents are often reviewed by study monitors and auditors to verify that study subjects exist, that study events actually occurred, and that data recorded on CRFs are accurate and complete. As such, source documentation provides physical evidence that allows for reconstruction and evaluation of a study. The Principal Investigator must establish source documentation requirements prior to the start of the study for each data element collected.

Typical examples of source documents include the subject s medical record, laboratory reports, radiology reports, subject diaries, research surveys, and questionnaires, pharmacy dispensing records, etc. For some studies, some or all of the data forms might also serve as the source documents. If a data form represents the document in which an observation is first recorded, it is considered the source document for those data, e.g. a research interview form including date of form completion and ID or signature of the person conducting the interview. It is often helpful to create a list or log of the sources from which data are to be obtained for each data form and to maintain instructions for form completion in the study Manual of Operations (MOO). For more guidance on development of the MOO, refer to CRC Research Practice Guideline for Developing a Manual of Operations. Shadow Files: Shadow files typically refer to copies of some or all of a subject s medical record that is maintained by study staff to verify data recorded on study CRFs. The shadow file generally contains only the pertinent clinical information related to the subjects care during the research protocol and additional research records that may not be filed in the subjects medical record. The documents contained in the shadow file are NOT considered original source documents, as they are copies. Monitors and FDA auditors will require access to the original source documents or certified copies of the original source documents during site monitoring visits or inspections. Research Data and Medical Records: A patient s medical records represent a permanent and legal record of all clinical information pertaining to a patient. As such, once entered, information cannot be deleted from a medical record. Thus, it is important for investigators to consider what information, if any, obtained for the specific research study should be documented in a subject s medical record. The CHB Office of Clinical Investigations has developed guidelines to assist investigators in determining what research information, if any, should be stored in a subject s medical record. Included in the guidance document are informed consent statements with suggested wording for informing subjects of information that will be included in their medical records.

Sample Study ID Log Related Content Contact the CRC for assistance with creating your Study ID logs and creating study ID numbers. For more examples of logs refer to the EQuIP website: http://www.childrenshospital.org/cfapps/research/data_admin/site2207/mainpages2207p0.ht ml Study Title Study ID Assignment Log To be maintained by the Principal Investigator or Study Coordinator. For subject confidentiality, this should be kept locked in a secure location at all times. These data should not be entered in the Study Data Management System. Study ID# 001-7 002-1 003-9 004-2 005-8 006-4 007-6 008-4 009-1 010-0 011-3 012-5 013-6 014-3 015-6 Last Name First Name Date of Birth MR# Date of Enrollment 016-7 017-1

Sample Screening Log Study Title Screening Log To be maintained by the Principal Investigator or Study Coordinator. For subject confidentiality, this should be kept locked in a secure location at all times. These data should not be entered in the Data Management System. Screening Date Eligible Reason if not Enrolled Date of Name, last, first MR# Birth ID# Screened Y/N Eligible Y/N 001 Yes No Yes No 002 Yes No Yes No 003 Yes No Yes No 004 Yes No Yes No 005 Yes No Yes No 006 Yes No Yes No 007 Yes No Yes No 008 Yes No Yes No 009 Yes No Yes No 010 Yes No Yes No 011 Yes No Yes No 012 Yes No Yes No 013 Yes No Yes No 014 Yes No Yes No Reason if not Enrolled

References Document Attributes Title Guideline for Study Document and Data Handling RPG-08 Author Mark Berry Date of Origin Aug 2008 Reviewed/ Revised by Mark Berry Dates Reviewed/Revised 08/28/13 Copyright Boston Children s Hospital, 2013 Last Modified 08/28/2013 Approved SIGNATURE ON FILE Stavroula Osganian, MD, ScD, MPH Co-Chief, Clinical Research Center SIGNATURE ON FILE Ellis Neufeld, MD, PhD Associate Chief, Division of Hematology/Oncology Fonds de la recherche en santé du Québec, 2006. SOP 24 Clinical Data Management, Paper or Electronic Format. [Online] 8 April 2009. http://www.frsq.gouv.qc.ca/en/sop/procedures/sop_24.pdf. Acknowledgement: The following CHB staff made substantive contributions to the development of this Guideline: Handan Titiz, Qiaoli Chen, Rajna Filip-Dhima, Jui Haker, and Sarah Krathwohl. Disclaimer: Should Hospital and CRC policies conflict, Hospital policy will supersede CRC policy in all cases.