Electronic Health Records for Clinical Research EHR Compliant to Clinical Trial Requirements EuroRec Conference 2009 Richard Perkins President, eClinical Forum Overview… 1. About the eCF To understand the rationale, objectives, status… 2. Why EHRCR 3. Approach 4. Status 5. Summary 2 About the eClinical Forum… • Not-for-profit and non-commercial association • 55 companies from Pharma R&D, service industries, academia, EHR • Trans-Atlantic • Activities cover electronic data acquisition, processing and use for clinical research • Share experiences, develop public domain deliverables and to shape the future of the clinical research environment Surveys … Industry status and trends, performance metrics, investigator attitudes, auditing experiences, system capabilities Reports … Business value of EDC; eSource, Connecting Healthcare & Research Tools … RFI development; Technology scale up Knowledge … eHealth terminology; Mobile data collection 3 The eSource Issue… … you use an electronic medical record (EMR) system to maintain medical and other clinical data for your patients, including study subjects … data obtained during study visits are entered directly into the EMR, and no paper records are used. requirements that must be met … – documentation of the validation of your EMR system to ensure accuracy, reliability, and the ability to detect invalid or altered records; – documentation of the ability to generate accurate and complete copies of records suitable for inspection, review, and copying by the agency; – documentation of a secure, computer-generated, time-stamped audit trail … 4 Growth of EHRs… EU Hospital EHR (2004) EU GPs (2008) 50% 67-92% 12% (now 20-25%) US Adoption of EHR (2005) 5 eHealth World… Multiple stages of EHR Components & integration Driven by the Need to… Possibly disparate systems for: •Pt Visit Records Other data •Pharmacy Coding •Labs •OR, etc. Local Labs EHR Data: Varying degrees of unstructured or non-digital information Various levels of standards, computer system validation and systems integration depending on country, region, institution. Entry of Patient’s Clinical Data – Enhance patient safety – Improve quality of healthcare – Reduce healthcare costs Physician / Investigator 6 eClinical Research World… Driven by the Need to… – Provide reliable data to support safety and efficacy Sponsor Clinical Research System Other data Clinical Research has moved from capturing data on paper to electronic data capture Entry of at the site Patient’s Systems used for clinical research have to fulfill strong regulatory requirements Coding Clinical Data SAE EDC Physician / Investigator Systems validated & compliant to Industry & Regulatory standards & policies e.g. 21 CFR Part 11, CSUCI & ICH GCP Central Labs 7 The Problem… Multiple stages of EHR Components & integration Source data held in EHR may not be appropriate as source for regulated clinical studies Sponsor Clinical Research System Data entry is duplicated causing additional effort for physicians Entry of Patient’s Clinical Data Physician / Investigator 8 A Different Future… We Need… a common understanding and approach We Need… to connect Healthcare and Research 9 A Different Future… Imagine… Patient Data Exchange Between Healthcare and Clinical Trial Systems Emerging and Future EHR-Research Connectivity and Complexity Integrated Future Current Divided Interoperable Ideal Healthcare System Clinical Trial System Current Divided (Core EHRCR Scenario) • EHR systems holding source for data used in clinical trials may not meet essential regulatory requirements • Clinical care data required for clinical trials is entered into EHR and into clinical trial systems • Research holds source data not part of normal clinical care • Redundant data entry, transcription errors and source issues cost healthcare and industry time and money. Interoperable Ideal Integrated Future • Healthcare data can be used to automatically identify suitable candidates for clinical trials • Clinical care data is entered once into EHR • Relevant data from EHR are seamlessly transferred to clinical trial systems so that no data transcription occurs for a significant proportion of clinical trial data held as source within EHR. • Research holds very little ‘source’ data and clinical trial data not collected at the site is transferred to EHR from clinical trial information systems • Queries can be handled electronically. • The EHR system functions as the patient data repository • EHR and research systems work seamlessly together so that groups benefit from data access and mining capabilities across healthcare and research data sets • Research systems and healthcare systems sit on the same spine • Systems conform to the same data exchange standards 10 A Different Future…The Benefits… Healthcare Identification of target population Reduced effort for data provision leaves more time for patient care Simplified safety reporting and management Potential to conduct more research Familiarity of one interface Authorities Patient Higher quality, reliable data from validated sources under investigator control New therapies available faster Higher quality data provides greater safety Real-time identification of safety issues and prediction of trends Lower cost and faster approval of new therapies Mining of data Research Pre-flight of trial criteria improves trial success Access to healthcare data to improved patient recruitment Early identification of safety issues and trial termination improves patient safety Data handling efficiencies 11 Making It Happen… Bridging the Gap Needs Technical, Political & Cultural Solutions EHRCR 1. Technical 2. Political/Legal Remove legal obstacles Link stakeholders Drive need for change HL7 Functional Model Standards EuroRec Repository Systems Common data Reliable, standards allow validated movement of systems meet Future data between Connected healthcare and healthcare and Healthcare & research research Research requirements 3. Cultural Work with stakeholders and partners to change perceptions and build consensus Build the business case for change Process Controlled process for release and transfer of data meets bioethical requirements 12 Making It Happen…EHRCR Electronic Health Records for Clinical Research Launched by eCF December 2006 at the invitation of HL7 and EuroRec to address the SYSTEM challenge for CORE Emerging and Future EHR-Research Connectivity and Complexity Systems Standards Reliable, Common data validated standards allow systems meet movement of healthcare and data between Future healthcare and research Connected requirements research Integrated Future Interoperable Ideal Current Divided Healthcare System Clinical Trial System Healthcare & Research Process Controlled process for release and transfer of data meets bio-ethical requirements Core (Current Divided) Ensure reliability and traceability of electronic source data used for CR by… Proposing profiles of criteria for what determines a ‘reliable’ data source when the source of patient data is electronic within the healthcare environment Defining a process to encourage incorporation of the functions necessary to utilize the Electronic Health Records as the direct data source for clinical studies 13 www.ehrcr.org Rationale… It is an important project to: – Remove risk of clinical trial data rejection because of unreliable source data (e.g. FDA warning letter 2006) – Provide EHR system developers with the business case and the clinical research functionality to be incorporated into their systems – Help healthcare system implementers understand the operational functionality required for regulated clinical research – Provide sponsors and certification bodies with the basis for evaluating EHR systems as source data repositories – Prepare for future connectivity 14 Stakeholder Participation… Pharma, EHR, Healthcare, eClinical services, regulators, associations Co-ordinating Partners: Technical Partners: EDC/eSource Taskforce Gold Level Partners: Global Participants: • Aris Global • Astellas • Bayer • Boehringer Ingelheim • Bristol Myers Squib • Cerner Corporation • • • • • • • Eli Lilly and Company FDA Glaxo SmithKline Hoffman La Roche Lundbeck Medidata Solutions Millennium • • • • • • NIH: National Cancer Institute Northrop Grumman Novartis Perceptive Pfizer Procter & Gamble 15 Approach… Global CR User Requirements… User Requirement International International Regs Regs (ICH GCP, CSUCI, Part 11, Data protection…) Tier 1 (Core) Relevance System and Data Security Requirements System shall have an audit trail to include recording date/time/author of any data creation, change, or deletion Essential (Now) Optional (future) … and reason … Regulatory Link CSUCI: D2b, D2c, D2f, D2g Part 11: 11.10 e ICH GCP: 4.9.3, 5.5.4 21 CFR: 312.62 …Mapped to Existing Criteria HL7 Functional Model Conformance Criteria Conformance Criteria HL7 Shall have…… Should have… May have… …New Criteria Needed to Meet CR Needs… …Clinical Research Profiles EuroRec Repository of Criteria EuroRec GS002183.02 The audit log contains create/edit/ deleted events. GS002188.01 Audit log records include date and time of recordable events. 16 Approach… By mapping HL7 and EuroRec criteria to a common set of Clinical Research requirements we end up with a globally consistent profile expressed in the ’local language’ Clinical Research Requirement Regulatory Source HL7 ‘Language’ EuroRec ‘Language’ 17 Status… 1. Clinical Research requirements mapped to regulations (Nov 07) 2. Assessment against Cerner’s Millennium system (Jun 08) Met must have criteria - 99.7% (outright 79.4%, via process and/or acceptable risk 20.3%) 3. Profile of HL7 criteria passed HL7 ballot (Jan 09) 4. Profile of EuroRec criteria submitted to EuroRec (Apr 09) 5. Practical guide for sites on implementation (Jun 09) 6. Profile of HL7 criteria accepted as ANSI standard (Jul 09) 7. Added to CCHIT roadmap for 2010 18 Next Steps… Mock Assessments EuroRec EuroRec Repository Repository EHRCR EHRCR Profiles Profiles EHRCR User Requirements CEN Standard EHRCR FP ??? Practical guide for sites Implementation support HL7 ANSI Standard EHRCR Profile EHRCR Profile EU Certification of EHRs for Clinical Research??? CCHIT Certification of EHRs for Clinical Research Mock Assessments 19 A Recap… 1. eSource is a growing issue and today’s solutions will not fit future needs 2. Work by HL7 and EuroRec on EHR functional criteria have presented an opportunity to address the reliability of eSource today 3. The EHRCR project is presenting proposals for profiles and a process for their implementation – Generic user requirements have been localised by mapping to HL7 or EuroRec. – Focus is on EHR system as clinical trial systems must already meet the minimum requirements. – Future “connected” systems will require new criteria for research and healthcare systems 20 A Recap… 4. The criteria for the vendor technology 'what's in the box' will be different to the criteria for the 'system' in its operational environment (which will include technology, process and people) 5. We need to define how best to manage the implementation process – Organic growth… – Pharma evaluation with shared results… – Self or formal certification… 21 For more information … www.ehrcr.org richard.perkins@con7.com 22