RECORD RETENTION: Imaging Data Longevity

Similar documents
A self-assessment for GxP and HIPAA concerns

LifeBridge Health HIPAA Policy 4. Uses of Protected Health Information for Research

CLOSE OUT VISIT REPORT (NO CRF TO MONITOR)

Good Clinical Practice: A Ground Level View

FDA Medical Device Regulations vs. ISO 14155

Advanced HIPAA Communications and University Relations

AN OVERVIEW OF CLINICAL STUDY TASKS AND ACTIVITIES

The future of patient care. 6 ways workflow automation will transform the healthcare experience

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

Privacy Rule Overview

10/4/12. Controlled Substances Dispensing Issues and Solutions. Objectives. Financial Disclosure

Updated FY15 Dignity Health General Compliance Education for Staff Module 2

Changes to the Common Rule

20% Funding Program Policy & Procedure

TOWN OF GREENWICH Annual Department Operational Plan (FY )

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

Innovation and Science

Research Compliance Oversight in the Department of Veterans Affairs

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

CCF RESEARCH GRANT APPLICATION 2017 REQUIREMENTS & GUIDELINES

Financial Conflict of Interest: Investigator Procedures. Office of Research, Innovation, and Economic Development Research Integrity and Compliance

WARNING LETTER VIA FEDERAL EXPRES S

The Queen s Medical Center HIPAA Training Packet for Researchers

Standard Operating Procedures (SOP) Research and Development Office

Uniform Guidance Subpart D Administrative Requirements

Medical Records Ch. 13. Dr. Thorson

DEPARTMENT OF DEFENSE AGENCY-WIDE FINANCIAL STATEMENTS AUDIT OPINION

IMDRF FINAL DOCUMENT. Title: Strategic Assessment of Electronic Submission Messaging Formats

Office of Human Research Office of Human Research Policy and Procedure Manual. Version: 4/4/18

PRIVACY IMPACT ASSESSMENT (PIA) For the

Memorial Hermann Information Exchange. MHiE POLICIES & PROCEDURES MANUAL

Implementing the Revised Common Rule Exemptions with Limited IRB Review

Vertical Market Information Center Healthcare Market Toshiba America Business Solutions, Inc. Training and Dealer Development Group

REGULATORY AND FUNDING CHANGES FOR HUMAN SUBJECTS RESEARCH

Texas Medicaid. Provider Procedures Manual. Provider Handbooks. Telecommunication Services Handbook

Minimum Business Requirements To Administer the CAHPS Hospice Survey

PRIVACY IMPACT ASSESSMENT (PIA) For the

Roles & Responsibilities of Investigator & IRB

ONADE s Data Quality Review

Retrospective Chart Review Studies

Harrison Clinical Research. Monitoring of Clinical Trials - Quality Management from a CRO s Perspective

Office of Academic Grants and Sponsored Research Financial Conflict of Interest Disclosure, Review, and Management Procedures

MSCRF Discovery Program

HAZARD COMMUNICATION PROGRAM. For CRAFTON HILLS COLLEGE

Vertical Market Information Center Healthcare Market Toshiba America Business Solutions, Inc. Training and Dealer Development Group

Standard Operating Procedures

The Section on Cardiology & Cardiac Surgery PEDIATRIC CARDIOMYOPATHY EARLY CAREER RESEARCH GRANT APPLICATION 2018 REQUIREMENTS & GUIDELINES

Building Quality into Clinical Trials. Amy C. Hoeper, MSN, RN, CCRC, Quality Manager Cincinnati Children s Gamble Program for Clinical Studies

Yorkshire and Humber ERDF Programme Document Retention Records to Keep

Uniform Guidance Subpart D Administrative Requirements. Why This Session Is Needed. Lesson Overview & Module Objectives

PATIENT RIGHTS TO ACCESS PERSONAL MEDICAL RECORDS California Health & Safety Code Section

Workplace Safety and Health Management System Administration

Use And Disclosure Of Protected Health Information (PHI) For Research

Financial Conflict of Interest Policy

Good Documentation Practices. Human Subject Research. for

FAFSA Completion Initiative Participation Agreement

GCP INSPECTION CHECKLIST

RESEARCH POLICY MANUAL

Healthcare Privacy Officer on Evaluating Breach Incidents A look at tools and processes for monitoring compliance and preserving your reputation

In the entire Finland: Juha Tuominen, Chief Medical Officer Suomen Terveystalo Oy, Group Administration

Golden Valley Historical Society Request for Proposal (RFP) Museum Interpretive Exhibit Curatorial Work, Design, Fabrication, & Installation

Contains Nonbinding Recommendations. Draft Not for Implementation

Measuring the Information Society Report Executive summary

Current and future standardization issues in the e Health domain: Achieving interoperability. Executive Summary

The EU GDPR: Implications for U.S. Universities and Academic Medical Centers

Section 1 Conflicts of Interest Introduction

IRB 101. Rachel Langhofer Joan Rankin Shapiro Research Administration UA College of Medicine - Phoenix

Request for Information NJ Health Information Network. State of New Jersey. New Jersey HIT Coordinators Office. Request for Information

FDA Office of Acquisitions and Grants Services Overview

SOUTH DAKOTA STATE UNIVERSITY

Bad Data s Effect on Population Health Performance

How an ACO Provides and Arranges for the Best Patient Care Using Clinical and Operational Analytics

Compliance Program, Code of Conduct, and HIPAA

WEST VIRGINIA HIGHER EDUCATION POLICY COMMISSION REQUEST FOR PROPOSALS VERIFICATION AND DOCUMENT MANAGEMENT SERVICES RFP #19007.

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

NHS WOLVERHAMPTON CLINICAL COMMISSIONING GROUP CONSTITUTION

Report of the Information & Privacy Commissioner/Ontario. Review of Cancer Care Ontario:

Patient Safety It All Starts with Positive Patient Identity APRIL 14, 2016

Chapter 9 Legal Aspects of Health Information Management

The Changing Role CUSTOM MEDIA

INSTITUTIONAL REVIEW BOARD Investigator Guidance Series HIPAA PRIVACY RULE & AUTHORIZATION THE UNIVERSITY OF UTAH. Definitions.

BASIC EDUCATION FOR ADULTS LEADERSHIP BLOCK GRANT

Measuring Digital Maturity. John Rayner Regional Director 8 th June 2016 Amsterdam

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

UNIVERSITY LIBRARIES

Are you participating in any other research studies? Yes No

PRIVACY IMPACT ASSESSMENT (PIA) For the

Emergency Medical Services Division Policies Procedures Protocols

UConn Health Office of Clinical & Translational Research Standard Operating Procedures

How can oncology practices deliver better care? It starts with staying connected.

The Conference of Radiation Control Program Directors (CRCPD) A Model for Networking, Cooperation, Information Exchange and Regulation Harmonization

PFF Patient Registry Protocol Version 1.0 date 21 Jan 2016

Abstract submission regulations and instructions

Briefing note for members of the Federation for the Humanities and Social Sciences

FISCAL YEAR FAMILY SELF-SUFFICIENCY PROGRAM GRANT AGREEMENT (Attachment to Form HUD-1044) ARTICLE I: BASIC GRANT INFORMATION AND REQUIREMENTS


ETHICAL AND REGULATORY CONSIDERATIONS

AirStrip ONE Cardiology

Criteria for Adjudication of Echocardiography Facilities May 2018

RISK MANAGEMENT BULLETIN

Transcription:

WHITE PAPER RECORD RETENTION: Imaging Data Longevity MDDX Research & Informatics 580 California St, Floor 16 San Francisco, California 94104 T (800) 441-MDDX F (866) 382-4696 info@mddx.com www.mddx.com

2 RECORD RETENTION: Imaging Data Longevity A common line of questions posed in vendor audits focus on the record retention policy for records generated during a clinical trial. Most research group policies cover standard data, validation records, and other text-based data. However, when it comes to the retention of medical images acquired during the trial, the long-term storage becomes more challenging and therefore overlooked, and often not in concordance with the group s own stated record retention policy. Historically, long-term storage of clinical trial image data has been hampered by several distinct factors: Image files are large and most were sent on CDs or DVDs, requiring large storage facilities for physical storage of the discs. Issues with Long Term Storage When stored on hard drives, the potential for damage or corruption increases as the hard drives age. Finally, incomplete or improper de identification of Protected Health Information (PHI) on images greatly increases the potential for unauthorized use or disclosure. With the increase in regulations, fines, monitoring, and enforcement, this creates a significant liability for research groups seeking to comply with retention periods. The indexing, management, and retrieval of data stored on thousands of discs was a job of a daunting task.

3 WHY RETAIN DATA The two key reasons for retaining clinical trial data are: use (current and future), and to satisfy health authority regulations. In larger institutions and companies, there are usually dedicated compliance officers monitoring current legislation and best practices to ensure that their organizations are satisfying the regulations. However, in small to mid-sized companies as well as academic/non-profit research institutions, the steadfast adherence to changing policy is not as commonly emphasized. While achieving regulatory compliance is the primary reason most cited for data retention, a more meaningful purpose also exists: Images which are indexed and then stored properly, protecting data integrity and privacy, become a lucrative asset fueling future discoveries, confirmatory research and novel inventions. This is especially true for organizations actively performing research and development: the retention of records builds an inventory of collective knowledge creating longevity to the research being invested in today. With many discoveries resulting as a side-effect or offshoot of another main area of research, creating this virtual knowledge vault enables rapid data harvesting, meta-analyses and data licensing opportunities. We went through litigation that required us to retrieve data from 1986 through 1988. It was quite helpful for us to have a system where we had ready access to the data. Senior Executive at Bayer

4 Regulations Record retention requirements under the law vary widely. Even within a single country, there exists a great deal of variability in the rules. The factors that determine the germane minimal retention period are the type of trial, funding origins of the trial, individual institution s policies, and sponsor s policies, the regulations can even vary within regulatory authorities themselves. One of the reasons for the variability is that the governance of clinical trial data falls into many of the following categories: business records, policies and procedures, disclosure records, research records, medical device records, and the Trial Master File. It is not surprising that the current regulations create confusion in determining the right retention time, as they range from: 2 to 25 years. Further confusing the issue, the retention clocks starts ticking at significantly differing time points: from date of creation to the end of the trial, to the date of the last disclosure. Current retention periods in North America and Europe are detailed below: CANADA Guidance for Records Related to Clinical Trials (GUI-0068): 25 years from original date of data creation. UNITED STATES: EUROPEAN UNION Regulation (EU) No 536/2014*, Article 58: The content of the clinical trial master file must be retained for at least 25 years after the end of the clinical trial. Medical device records must be maintained for inspection by the Competent Authorities for the useful life of the product or 5 years from date of manufacture, whichever is greater. Minimum 15 years after Clinical Trial discontinuation if data is used to support a marketing application * Effective 28 may 2016 45 CFR 164.530: Maintain Policies & Procedures records for 6 years after last use. 45 CFR 164.528: Accounting of certain disclosures of identifiable health information for a period dating six years from the date of the last covered disclosure: 45 CFR 46.1115(b): Research records retained for at least 3 years after completion of the research. 21 CFR 312.62: For IND research records and reports required for 2 years after a marketing application is approved for the drug; or if not approved, 2 years after shipment and delivery of the drug for investigational use is discontinued and the FDA so notified. 21 CFR 812.140(d): For IDE research records: 2 years after the latter of the following two dates: The date on which the investigation is terminated of completed, or the date that the records are no longer required for purposes of supporting a premarket approval application or a notice of completion of a product development protocol. NIH: The National Institutes of Health require that grant recipients keep all data for three years beyond the time that the final expenditure report of the grant is reported.

5 CASE STUDY In a recent project MDDX performed for a cardiac device manufacturer, our team was asked to collect and de-identify over 21,000 legacy DI- COM datasets stored on CD/DVDs, hard drives, and servers at multiple imaging core labs. This imaging asset comprised the key image data supporting two landmark trials for this multi-billion dollar company. Our analysis discovered that approximately 4% of the images had been corrupted during storage, and were unusable. More troubling was the discovery that only 19 of the DI- COM datasets (<0.01%) were properly de-identified. Therefore, rather than creating an easy-to-access resource of medical images, both the sponsor and the core labs were sitting on a large potential liability of hard to retrieve images locked in back closets. MDDX reduced their PHI risk and increased the value of their data asset by retrospectively de-identifying all viable DICOM and indexing them in our secured Image Repository which provides immediate online access for authorized sponsor staff. Their locked away liability was transformed into an easily accessible and robust asset. With the wide international variability in record retention periods, the conservative approach is to implement a simplified record retention period equal to the maximum period of any one Health Authority regulation. By instituting a 25-year policy, the majority of organizations will safely be within the current regulatory requirements while also providing ample time for any secondary discoveries or data harvesting to occur. IMAGE REPOSITORIES Researchers who have conducted clinical trials involving imaging endpoints understand the challenges that come with collecting high quality medical image data. Variations in acquisition techniques, non-adherence to the protocol, noncompliance to DICOM standards, improper DICOM handling and unavoidable image quality issues combine to make imaging a complicated and expensive endpoint for any trial. Building a long-term de-identified image repository has many benefits. At a minimum, the repository allows sponsors to satisfy all health authority regulations regarding record retention. For forward-thinking companies, the repository has expansive potential to elicit a multitude of benefits including: Range finding of imaging end points for future trials Determining performance metrics of your research sites for future trial selection or risk-based monitoring Use of the images for marketing or for training clinical specialists and physicians Use of the images in aiding the development of softwarebased visualization and/or diagnosis of the condition Initiating new sub-studies or exploratory investigations not in the original scope (these sub-studies could commence next year or 10 years from now)

6 MEDICAL IMAGES AS SOURCE DATA The core elements of clinical trial regulations are record keeping and audit trails. Therefore the growing best practice is for all data to be retained. All records created, generated, or referenced can and should be retained. These records range from policies and procedures, to staff records, validation records and all clinical activities. The majority of this information is defined as either source data or electronic source data. Table 1: Definition of source data Source data Electronic source data All information in original records and certified copies of original records of clinical findings, observations, or other activities in a clinical investigation used for reconstructing and evaluating the investigation. Data initially recorded in electronic format. They can include information in original records and certified copies of original records of clinical findings, observations, or other activities captured prior to or during a clinical investigation used for reconstructing and evaluating the investigation. Medical images in the DICOM format are inherently electronic source data. Due to the fact that medical images can be accidently truncated, corrupted, over de-identified or intentionally manipulated, the ability to trace the authenticity of a medical image to its source is a critical factor in record retention. Additionally, medical images must carry a measure of data integrity as they moves from research site to imaging core lab and finally to the image archive. SUMMARY AND RECOMMENDATIONS The combination of industry trends, regulatory requirements, good laboratory practices, and prospective business possibilities point firmly towards creating and implementing long-term record retention solutions. Several universities and institutions have begun leading the charge, encouraging both long-term storage and de-identification, recognizing the opportunities for future research and findings between departments and even between institutions. This two-pronged approach of storage and de-identification meets the best practice standards for international trials while also laying the groundwork for future breakthroughs, discoveries, and growth.