Coordinated System for gaining NHS Permission Streamlining the NHS Permissions process The National Institute for Health Research (NIHR) Coordinated System for gaining NHS Permission (CSP) standardises and streamlines the process of gaining NHS Permission (also known as R&D approval) for commercial and non-commercial research in England, which is required before any clinical research in the NHS can commence. CSP is the NIHR Clinical Research Network’s recommended route for commercial clinical research studies in England to gain their NHS Permission(s). CSP is accessible via the Integrated Research Application System (IRAS), the system used to apply for the permission and approvals for a research study. IRAS enables information to be entered once into an integrated data set, which then populates the separate application forms. CSP is designed to run in parallel to your applications made through IRAS to other regulatory bodies such as the NHS Research Ethics Committee (REC), and provides an efficient process for gaining NHS Permission to make setting up commercial research in the NHS faster and easier. Current CSP target timelines are: • 80% of studies obtaining NHS Permission through CSP within 40 calendar days from receipt of a valid R&D application In addition, local sites have internal process improvement targets of: • • 15 calendar days from receipt of a valid R&D submission to completion of study-wide review 15 calendar days from receipt of a valid SSI submission to NHS Permission issued at an NHS organisation It is important to note that the use of CSP relates solely to the processing of information for R&D office purposes. It does not replace the Sponsor’s responsibility to provide the current versions of documents to research teams. Using CSP to apply for NHS Permission The steps to gain NHS Permission using CSP are summarised in the flowchart overleaf and detailed further below: STEP 1 - PAF SUBMISSION The first step in the CSP process is to complete a Portfolio Application Form (PAF) to enable your study to be registered for Network support even if your study has already been deemed eligible for the Portfolio. A PAF is generated in the Project Forms section of IRAS when question 5b in the Project Filter is answered with ‘yes’. The PAF is completed and electronically submitted through IRAS to CSP. Selecting your Lead CLRN When submitting your PAF, you will be asked to select a Lead Comprehensive Local Research Network (CLRN) for your study, which will act as the main point of contact in England for your study. This is usually determined by the location of the lead NHS R&D office, which may also be the location of the Chief Investigator (CI). However, it may be more appropriate to choose a Lead CLRN where the Study Coordinator is located, for example. STEP 2 - R&D SUBMISSION Once the PAF has been validated you will receive an email requesting the electronic submission of your R&D application. Documents to support this application should be attached to the IRAS R&D Form Checklist for your study, and these will be submitted electronically to CSP along with the form. This R&D Checklist also includes documents required for a submission to NHS REC; this ensures consistency between information reviewed by both the NHS REC and R&D departments. When submitting your initial R&D application through IRAS to CSP you may not have all of the documents detailed at the end of the R&D Checklist, such as the NHS REC Favourable Opinion letter. Once you have received these documents they should be attached to the R&D Checklist in IRAS and submitted to CSP as a document only submission. If any documents forming part of the initial submission package are not applicable, please provide a comment on the R&D Checklist. Following NHS REC approval, any new versions of documents should be supplied and must match the version numbers listed in the NHS REC Favourable Opinion letter. Receipt of your R&D application will enable the Lead CLRN to begin the study-wide governance review. STEP 3 - SSI SUBMISSION Once the R&D application has been validated you will be asked to electronically submit your Site Specific Information (SSI) application(s), which are submitted by the Principal Investigator (PI)/Study Coordinator for each NHS organisation participating in the study. A valid application consists of the form and associated documents required for the submission as detailed within the IRAS SSI Form Checklist. The application will be validated by the CLRN Research Management & Governance staff at each NHS organisation, who will then commence the local governance review and work with the PI and/or research team to resolve any issues that may arise. STEP 4 - NHS PERMISSION LETTER ISSUED When your study has been deemed eligible for the Clinical Research Network Portfolio, the study-wide governance review has been completed and the NHS organisation has completed its local governance review, a Governance Report is generated. This provides the evidence that all governance criteria have been reviewed and is used to highlight any identified risks or issues. The NHS organisation will then issue an NHS Permission Letter to the PI, copied to the Chief Investigator/Study Coordinator. It is only upon receipt of this permission letter that the study can begin at that NHS organisation. Gaining NHS Permission for commercial studies using NIHR CSP For general process advice contact the Industry Information Centre Team. IRAS www.myresearchproject.org.uk Contact: IRAS Helpdesk helpdesk@infonetica.net or CSP Helpdesk crncc.csp@nihr.ac.uk CREATE PROJECT DATASET 1. Submit Portfolio Application Form dl CA Erm Fv w v f G u U m m oN hm y P E j qx h d Gb K rt z t S y I l w d Submit required forms to regulatory bodies such as MHRA and NHS REC 2. Submit R&D Application A B C Network eligibility ideally should be initiated before IRAS submission 3. Submit SSI Application Regulatory bodies grant approvals Submit to Network: Coordinated System for gaining NHS Permission (CSP) 1. Portfolio Application Form Upon receipt of valid form, confirmation will be provided that the R&D application can be submitted. • • 2. R&D Application Upon receipt of valid R&D Form, Checklist and documents, Lead CLRN will undertake study-wide governance review and share across all participating sites. 3. SSI Application Upon receipt of valid SSI Form and documents, participating CLRN(s) will undertake local governance review. Study protocol Industry submission Negotiate and agree contract and costs with support from Network Draft relevant: For each participating site: once the study-wide and local governance reviews are complete and Portfolio eligibility has been confirmed, the NHS organisation will issue an NHS permission letter. • • Industry Costing Template Model agreement Research can start at a participating site upon receipt of the NHS permission letter from that NHS organisation. www.crncc.nihr.ac.uk/csp Submitting an amendment The Lead CLRN is available to offer advice on preparing an amendment and the associated documents, prior to it being submitted. Amendment documents should be uploaded the Amendment section of the IRAS R&D Form and submitted to the Lead CLRN as either a document only submission or a full R&D submission if changes to the R&D form have been made. You should submit your amendment to CSP in parallel to any regulatory bodies so that the 35 day period to confirm continuation of NHS Permission, if applicable for the amendment type, does not delay the implementation of the amendment. The amendments will be categorised upon receipt by the Lead CLRN as either: a) notifiable - those that require a 35 day period during which an objection can be raised and therefore need to be notified to all participating sites; or b) non-notifiable - those that may be implemented by the Sponsor without waiting for the 35 days to elapse. Participating sites have no action to take when the amendment is non-notifiable. Examples of substantial and non-substantial amendments can be found on the NRES website at http://www.nres.nhs.uk/applications/after-ethical-review/notification-of-amendments/examples-ofsubstantial-and-non-substantial-amendments/. For all studies, responsibility for determining whether an amendment is substantial or non-substantial lies with the Sponsor. UK wide studies For studies involving more than one of the devolved administrations (England, Northern Ireland, Scotland and Wales) IRAS requires the selection of a Lead Administration. This is usually determined by location of the lead NHS R&D office, which may also be the location of the CI. If the study is led from England, it will be possible to electronically submit your applications via IRAS to CSP. Where another UK nation is leading the study, electronic submissions are currently not enabled. In these circumstances, the R&D application should be emailed to the Lead Administration’s coordinating centre. The Lead Administration takes responsibility for notifying the other administrations participating in the study so that they can manually commence their national approval processes (eg CSP for England). This avoids multiple submissions to each devolved administration by the Sponsor. Contact us You can access CSP specific information and support online at: w: www.crncc.nihr.ac.uk/csp t: 0113 343 2314 e: crncc.csp@nihr.ac.uk The Industry pages of our website provides information on other Clinical Research Network support offerings: w: www.supportmystudy.nihr.ac.uk If you have any questions or require further information, please contact our Industry Information Centre: t: 0113 34 34 555 e: supportmystudy@nihr.ac.uk