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Partners Human Research Quality Improvement Program QUICK BITE Series. More Work is Less Worry. Guidance to Lessen Regulatory Concern. Sarah White,QI/QA Specialist [email protected] March 10, 2005. More Work is Less Worry. To work, or not to work What are we worrying about?

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Partners human research quality improvement program quick bite series

Partners Human Research Quality Improvement Program

QUICK BITE Series

More Work is Less Worry

Guidance to Lessen Regulatory Concern

Sarah White,QI/QA Specialist

[email protected]

March 10, 2005


More work is less worry

More Work is Less Worry

  • To work, or not to work

  • What are we worrying about?

  • Systems are the “work”

  • Practical Tips/Systems

  • Questions & Discussion


To work or not to work

To work, or not to work

Site A has worked hard to put systems in place to manage their hefty research study load

* Versus *

Site B jumped right into their research studies and took on the attitude of handling things as they come up

**Both sites are very successful at enrolling and completing their subjects.


To work or not to work1

To work, or not to work

Both Sites A and B are called by the FDA and told they will be audited. The FDA auditors will arrive at their offices at 9 a.m. the following day. Of particular interest, the FDA would like to see subject enrollment records and drug accountability records.


To work or not to work2

To work, or not to work

Site A

  • PI and Study Coordinator review both the master enrollment log and drug accountability log

  • The site also plans to provide FDA with a delegation of responsibility log to inform FDA of study staff responsibilities


To work or not to work3

To work, or not to work

Site B

  • Has not been maintaining an enrollment log

  • Progress notes within the subject binders track the quantity of investigational drug and date given to subject

Site B is in for a long day (and night) creating an enrollment log and accounting for drug disposition of their 237 subjects!


What are we worrying about

What Are We Worrying About?

  • Notification of audit

  • Audit findings

  • IRB continuing review

  • Protocol noncompliance

Up all night cleaning up files

FDA warning letter

Study deferral and/or expiration

Violations/deviations

subject safety/data integrity


Systems are the work

Systems Are the “Work”

Systems should be:

  • In place before the study starts

  • Simple, standardized, and well understood by their users

  • Consistent

  • Documented


Examples of good systems

Examples of Good Systems

  • Collective Filings

  • Logs

  • Checklists

  • Monitoring Plan

  • System to Reporting AEs and Violations

  • Outlook Calendar

  • Site Guidelines


Collective filings

Collective Filings

  • CVs need to be signed and dated and kept up-to-date

  • For those sites with large numbers of investigators and study staff:

    • Keep CVs in a central location

    • Select a ‘renewal’ date for all CVs

    • Mark it on your Outlook calendar


Study logs

Study Logs

  • Logs that are unique to your study will help you track it’s progress

  • Delegation of Responsibility Log

  • Enrollment Log

  • Drug/Device Accountability Log

  • Adverse Event Log

  • Violation/Deviation Log


Checklist for each study visit

Checklist for Each Study Visit

  • Prevent missing procedures

  • A checklist for each study visit or telephone call will help you manage the visit, so you know

  • All procedures have been completed

  • Which procedures have not been completed

  • If any violations need to be reported


Monitoring plan

Monitoring Plan

  • Ensure your data is trouble free on a regular basis

  • Be realistic about your monitoring plan

  • Follow monitoring plan timelines

  • Recruit outside help


Adverse event reporting

Adverse Event Reporting

  • Having an AE reporting plan can take the worry off meeting reporting requirements

  • Who do you report event to?

  • What are the reporting timelines?

  • What information is required?

  • Are you responsible for follow up?


Violation deviation reporting

Violation/Deviation Reporting

  • Violations do occur.

  • How do you deal with them?

  • Major vs. minor (PI determines)

  • Know what information is required for reporting

  • System to track all violations

  • System to prompt amending the protocol

  • Summarize minor violations at Continuing Review


Valid consent forms

Valid Consent Forms

There will be unexpected consent form changes during the course of the study

  • Create a log that tracks consent from changes

  • Check in with protocol administrator for approximate review date

  • Dispose of all outdated consent forms as soon as new consent form has been approved


Continuing review preparation

Continuing Review Preparation

  • Make the continuing review process prospective, not retrospective

  • Know what information is required for continuing review application

  • Track form specific information throughout the year (can be incorporated into your enrollment log)

    • # found ineligible

    • # lost to follow-up

    • # terminated due to adverse events

  • Mark Continuing Review dates on Outlook and set the ‘reminder’ to remind yourself


  • Use your outlook calendar

    Use Your Outlook Calendar

    Don’t dismiss reminder!

    • Mark due dates for continuing reviews (i.e., 90, 60, 45 day reminders)

    • Mark deadlines for AE reporting and follow-up

    • Mark anticipated review/approval of amendments

    • Mark when consent forms expire


    Study site guidelines

    Study Site Guidelines

    • Develop study site specific guidelines and tools

    • Who is responsible for what?

    • Where are study medications, questionnaires, subject binders, IRB documentation stored?

    • What are the expectations for documentation?


    Who should be aware of the work

    Who should be aware of the ‘work’

    • Principal Investigators

    • Co-Investigators

    • Study Staff

    • Other Individuals involved (e.g. open communication with Sponsor)


    Utilize your resources

    Utilize Your Resources

    • Partners HRC website

      http://healthcare.partners.org/phsirb/

    • CCI for BWH

    • www.brighamandwomens.org/cci/

    • CRP for MGH

    • www.mgh.harvard.edu/depts/crp/

    • QI Program

    • http://www.partners.org/phsqi/


    Questions systems to share

    Questions? *** Systems to Share?


    Upcoming qi quick bite lecture

    Upcoming QI QUICK BITE Lecture

    “Share Our Stories – Case Studies from the Field”

    Do you have a case study or story that you’d like to share? The QI Program is welcoming case studies to include in our next lecture. Please contact Sarah White ([email protected] / 617-424-4137) if you have a case study that will help others in the research community learn!


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