Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials Title Policy for CIRB Process for the NCI National Clinical Trials Network (NCTN) Departmental Policy Number 120 Purpose The purpose of this policy is to outline roles, responsibilities, and expectations related to the acceptance, study start-up, maintenance and closure processes of CIRB NCTN trials. Definitions/Abbreviations CAM- CIRB Acknowledgement Memo CCRRC – Cancer Clinical Research Review Committee CIRB – NCI’s Central Institutional Review Board CRMO – Clinical Research Management Office CTOC – Clinical Trial Oversight Committee HM – Hematological Malignancies ICF – Informed Consent Form IRB – Institutional Review Board JKCCN – Jefferson Kimmel Cancer Center Network KCC – Kimmel Cancer Center MDG – Multi-disciplinary Group MCSF- Masters Submission Committee Form NCI –National Cancer Institute NCTN- National Clinical Trials Network PI – Principal Investigator RA – Regulatory Affairs ROPG – Radiation Oncology Protocol Group Approved Date: Effective date: Version 3.0_ April 16, 2014 1 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials SOC – Standard of Care STO – Solid Tumor Oncology TJU – Thomas Jefferson University Policy Statement The Kimmel Cancer Center is an NCI designated cancer center. The NCI requires that we evolve as a cancer center and make every effort to increase accrual in our clinical trials targeting cancer. As an NCI designated cancer center we are mandated to make appropriate clinical trials available to the community in which we serve. To ensure that our clinical trial portfolio fits our patient population and their needs, while supporting faculty research interests, a specific process must be followed to determine that pursuing a clinical trial is appropriate. This process is a two-fold one in which potential clinical trials are reviewed and vetted by the relevant MDG and then approved by the Director of Solid Tumor Oncology or the Director of Hematological Malignancies. As an NCI designated cancer center we must also ensure that new trials are opened and activated in a timely manner. To do that a streamlined process has been developed and implemented for NCI NCTN Trials for which TJU accepts CIRB review by a “facilitated review” process. Scope This SOP describes the processes for the internal management of the CIRB independent model trials at TJU: Initiating a new CIRB-approved protocol Amendments both internal and external (NCTN) Continuing Reviews Study closure This policy is applicable to the following studies: Approved Date: Effective date: Version 3.0_ April 16, 2014 2 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials CIRB-approved NCTN Trials accepted by the TJU IRB through the facilitated review process as described in the IRB Authorization Agreement between TJU and the NCI CIRB. Responsibility for Executing the Policy For the departments that conduct cancer research, the Department Chair will hold the Director of Solid Tumor Oncology and the Director of Hematological Malignancies responsible for reviewing and approving all new potential cancer trials for their tumor type prior to MDG review and approval to ensure that the appropriate clinical trials are being opened and available to our patients. The Director of Solid Tumor Oncology and the Director of Hematological Malignancies will also hold the PIs responsible for the timely completion of the study. The Master Cancer Submission Committee Form (MCSF) will be provided to the PI by the MDG coordinator or the PIs can also retrieve this form from the KCC website. The PIs will then need to submit both the MCSF and the approved MDG protocol to CCRRC@jefferson.edu, for expedited administrative review. Roles The following information describes which areas (groups or Individuals) and associated roles that shall adhere to this policy. A single person may perform multiple roles. Department Chair: The Department Chair or designee is responsible to ensure compliance with all aspects of this policy specifically to ensure that all new potential trials are being reviewed by the appropriate Director and their decision to move forward or decline is communicated to the CRMO. Director of Solid Tumor Oncology and the Director of Hematological Malignancies: The Director of either Solid Tumor Oncology or Hematological Malignancies shall be responsible for the review and approval to either move Approved Date: Effective date: Version 3.0_ April 16, 2014 3 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials forward with a new CIRB-approved trial or decline participation for Jefferson as a site. MDG Leaders (e.g. Trial Team Leaders or “Champions”): The Trial Team Leaders shall be assigned by the Director of STO and the Director of HM, and shall be responsible for the initial review of protocols prior to sending to the Director of STO or the Director of HM for final approval. If the Trial Team Leader is interested in pursuing the protocol, s/he shall submit to the MDG coordinator to place trial on the MDG agenda. Principal Investigator: The Principal Investigator or designee shall be responsible for the timely completion of the MCSF and protocol submission to the CCRRC@jefferson.edu CRMO: CRMO Associate Director of Regulatory Affairs or designee is responsible for relaying all new potential trial information to the CRMO or ROPG in the bi-monthly (protocol development meeting and entering information in to JeffTrial for CCRRC submission). Multidisciplinary oncology working groups (MDG): MDGs are responsible for vetting each trial for feasibility, coordination, data management, and regulatory resource capability and to ensure that the current docket does not contain open competing trials. The MDG physician leader will approve the study to move forward to IRB submission by signing the MCSF. Procedure START-UP OF CIRB PROTOCOL Role PI,JKCCN Senior Step Activity Receives notice of CIRB NCTN trial activation by the respective Sponsor. Sends targeted email to the MDG leader and MDG Approved Date: Effective date: Version 3.0_ April 16, 2014 4 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials Outreach Coordinator MDG Coordinator PI Associate Director of RA or Designee 1.0 1.1 1.2 coordinator to gauge interest of the trial at TJU. If MDG leadership confirms interest in the trial, the CRMO/ROPG will manage the trial (proceed to step 1.0). If MDG leadership declines interest in study the JKCCN will open trial for the JKCCN affiliates only (proceed step 1.1) by submitting the MCSF to CCRRC. Will send an email to CCRRC regarding the New NCTN trial approval at MDG Will submit the Protocol and MCSF to ccrrc@jefferson.edu Upload the information from MCSF and protocol to JeffTrial for expedited administrative review and assign a CCRRC number. This timeline will be approximately 3-4 working days The study title format must read: ** “(CIRB)” before the actual title and end with the NCTN and number**. Associate Director of RA or Designee 1.3 Delegate the approved CIRB trial to the regulatory coordinator. • 1.3 Regulatory Coordinator Will complete the TJU KCC internal form: CIRB Acknowledgment Memo (CAM) (APPENDIX I) and send out for signature to PI, chair and administrator, Complete CIRB Study-specific worksheet found in the CIRB Management Site about local context Confirm with JKCCN to see if any JKCCN affiliates are participating in the trial • Regulatory Coordinator Merge CIRB ICF (downloaded from CIRB portal) with TJU approved ICF template language, • Retrieve the Protocol and MCSF from JeffTrial. • Signatures have returned, log on to the CIRB website and download the CIRB approval letter, subject materials if applicable, and investigator brochure • Send the merged ICF document and the CIRB consent to the regulatory supervisor for QA 1.4 • Regulatory Supervisor or designee of Network (in network only trials) Regulatory Coordinator • • 1.5 QA by comparing the two documents received electronically from the Regulatory Coordinator and verify all CIRB requirements are incorporated. Return email confirmation of approval and consent to the regulatory coordinator for TJU IRB submission You may NOT QA and stamp a consent that you merged. Submission to the local TJU IRB Portal includes : • CAM only. (The purpose of creating a Portal submission is Approved Date: Effective date: Version 3.0_ April 16, 2014 5 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials twofold: to trigger assignment of IRB control # to study and to enter study onto an IRB agenda.) Transaction Submission to JeffTrial: Under “Review Information”: Submit Date: date submitted Review Reason: initial Under “Details”: • CAM • Protocol • Subject materials (if applicable) • Consent • Appropriate JKCCN consent addendums (if applicable) • IB • CIRB Acceptance Letter NO PAPER COPY will be submitted to the TJU IRB TJU IRB Personnel 1.6 Receives CAM from TJU IRB electronic submission Portal and logs into JeffTrial to assign the IRB control number and place it in the management tab section in a timely manner TJU IRB Personnel 1.7 In JeffTrial, under the “Reviews”>> IRB Tab, finds transaction and completes the following fields: Review date: date received Committee: NCI CIRB Review type: facilitated Action : acknowledged Action date: same as review date e-mail regulatory coordinator that trial was received and acknowledged Regulatory Coordinator Regulatory Supervisor or designee of network (in network only trials) 1.8 No TJU IRB approval letter is issued. Add the TJU IRB control number to the consent form per header template and send to the Regulatory Supervisor for stamping of the consent. stamp consent and subject materials with : “CIRB STUDY (do not sign after: expiration date _________)” Approved Date: Effective date: Version 3.0_ April 16, 2014 Expiration consent date is listed on initial CIRB approval letter and subject materials are to expire at “end of study” Footer with version number is required 6 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials Then send back to the Regulatory Coordinator to upload into JeffTrial. Regulatory Coordinator or designee 1.9 Upload Transaction Submission documents to JeffTrial: • • • • • • • CTSU 2.0 CAM Protocol Stamped Subject materials (if applicable) Stamped consent Stamped JKCCN consent addendum (if applicable) IB- these must be downloaded from the appropriate sponsor site or CTSU CIRB Acceptance letter CTSU will be copied on the NCI CIRB initial approval email. CTSU will email requesting confirmation of all site codes participating. Note: (This is all that needs to be done for new CIRB studies in terms of CTSU). Regulatory Coordinator or designee 2.1 Regulatory coordinator will respond via email to CTSU with TJU site code and any participating network site codes. Regulatory Coordinator or designee 2.2 Follow internal CRMO red folder process email Clinical Coordinator 2.3 Activates trial as per CRMO, ROPG or JKCCN standard practice Continuing Reviews Regulatory Coordinator 3.0 When due at 4 weeks out from CIRB expiration • • • login CIRB website and download the CR approval, stamp current Merged consent “CIRB STUDY (do not sign after: expiration date _________)” Expiration consent date is listed on current CIRB approval letter Footer with version number is required Note: the CIRB perspective on CRs - local sites have no regulatory responsibility and this strictly a TJU process Approved Date: Effective date: Version 3.0_ April 16, 2014 7 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials Regulatory Coordinator 3.1 Regulatory Coordinator or designee 3.2 Regulatory Coordinator or designee 3.3 Upload Transaction Submission to JeffTrial: Under “Review Information”: Review date: date submitted Submit date: date submitted Committee: NCI CIRB Review reason: Continuing Review Review type: Facilitated Action : acknowledged Action date: same date as submit date Expiration date: According to CIRB approval letter Under “Details”: • Stamped consent (for open to accrual only) • Stamped JKCCN consent addendum (for open to accrual only) • CIRB Continuing Review Approval letter Note that CR will NOT be uploaded to the Portal Follow internal CRMO red folder process email and file accordingly Complete and Fax CTSU the ‘Acknowledgment Form (for sites utilizing the NCI CIRB)’ Amendments (Internal) Regulatory Coordinator 4.0 Receives amendment via clinical coordinator or P.I. Examples of internal amendments include: adding or removing staff, adding a JKCCN site, increasing accrual, foreign language consents etc) **Note: Closing accrual doesn’t change the consent or the memo therefore only emailing notification to Regulatory Registration Compliance Manager to update JeffTrial is required. Print out the email and file it accordingly. Regulatory Coordinator 4.1 *** Note: if PI changes all parties need notification ( TJU IRB, CIRB, CTSU) proceed to step 5.0 Necessary changes are made to the consent form or CIRB Acknowledgement Memo ( CO-I change, staff list etc) Need to be sent out for signature and re-stamp consent (updating the ‘TJU version’ date in the footer) Email the Senior Outreach Coordinator at the Network all staff member changes. Approved Date: Effective date: Version 3.0_ April 16, 2014 8 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials Note: 12B/Cs are not used in this process “CIRB STUDY (do not sign after: expiration date _________)” Senior Outreach Coordinator Expiration consent date is listed on current CIRB approval letter Footer with version number is required Responsible for maintaining the CIRB rosters for TJU and its affiliates. Regulatory Coordinator or designee 4.2 Upload changed documents and release in JeffTrial. Upload Transaction Submission to JeffTrials:: Under Review Information: Review date: date submitted Submit date: date submitted Committee: NCI CIRB Review reason: Amendment Review type: Facilitated Action : acknowledged Action date: same date as submit date Under Details: • Stamped consent (if applicable) • Stamped JKCCN consent addendum (if applicable) Updated CIRB Acknowledgement Memo Note that these Amendments will NOT be uploaded to the Portal Regulatory Coordinator or designee 4.3 Follow internal CRMO red folder process email and file accordingly Amendments (External) Regulatory Coordinator 5.0 Receives amendment via email from applicable NCTN, **Note: this includes PI Changes** Regulatory Coordinator 5.1 Log into CIRB website and download all amendment materials Regulatory Coordinator 5.1 Necessary changes are made to the consent form, updating the footer to read the new protocol version date, and re-stamp consent. “CIRB STUDY (do not sign after: expiration date _________)” Approved Date: Effective date: Version 3.0_ April 16, 2014 9 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials Regulatory Coordinator or designee 5.2 Expiration consent date is listed on current CIRB approval letter and subject materials are to expire at “end of study” Footer with version number is required Upload Transaction Submission to JeffTrials: Under “Review Information”: Review date: date submitted Submit date: date submitted Committee: NCI CIRB Review reason: Amendment Review type: Facilitated Action : acknowledged Action date: same date as submit date Under “Details”: • • • • • • Protocol --only if changed Summary of Changes Stamped Subject materials --only if changed Stamped Consent-- only if changed IB- -only if changed CIRB Amendment Approval letter Note that these amendments will NOT be uploaded to the Portal Regulatory Coordinator or designee 5.3 Complete and Fax CTSU the ‘Acknowledgment Form (for sites utilizing the NCI CIRB)’ Final Closure Regulatory Coordinator 6.0 Receives closure notification via email from applicable NCTN Group Regulatory Coordinator 6.1 Log into CIRB website and download all closure materials Regulatory Coordinator or designee 6.2 Upload Transaction Submission to JeffTrials: Under “Review Information”: Review date: date submitted Submit date: date submitted Committee: NCI CIRB Review reason: Final Review type: Facilitated Approved Date: Effective date: Version 3.0_ April 16, 2014 10 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials Action : acknowledged Action date: same date as submit date Under “Details”: • CIRB Final Closure Approval letter Note that Final Reports are NOT uploaded to the Portal Regulatory Coordinator or designee 6.3 Complete and Fax CTSU the ‘Acknowledgment Form (for sites utilizing the NCI CIRB)’ Approved By: Endorsed by: TJU IRB: Jackson Bruce Smith, MD, CIP –Director, Office of Human Research , Thomas Jefferson University KCC CRMO: Sylvia O’Neill, MD- Associate Director of Regulatory Affairs and QA Natalie Schultz, BA- Regulatory Coordinator JKCCN: Joshua Schoppe, MPH, CCRP, Senior Outreach Coordinator for Research, ECOG/CTSU Administrator Appendix I: CIRB Acknowledgement Memo: CIRB Trial Acknowledgement Memo (CAM) Date of Notification: Protocol Title: PI: JeffTrial Number: IRB Control Number: CCRRC number: Approved Date: Effective date: Version 3.0_ April 16, 2014 11 Clinical Research Management Office - Kimmel Cancer Center Policy 120 Policy: CIRB NCTN Trials ITEMS REQUESTED: Network participation: Yes or No Only Staff members list included (staff signatures not needed) Communication to TJU IRB will be limited to: Initial study acknowledgement, any modifications to CIRB Trial Notification Memo, and suspensions due to safety issues Serious Adverse events will only be reported per the NCTN specific protocol and the CIRB SOP reporting guidelines. Unanticipated problems and potential noncompliance will be reported to both the TJU IRB (OHR-20) and the CIRB via the appropriate established mechanisms. The Signatory Institution must provide independent oversight of the conduct of the research. The TJU IRB reserves the right to conduct audits or interim trial reviews as needed. In the latter case, the OHR-9 will be used. Signatures _______________________________________________Date______________________ PI signature ____________________________________________Date____________________ Chairman _______________________________________________Date______________________ Regulatory Coordinator Appendix II: CIRB Transmittal form Approved Date: Effective date: Version 3.0_ April 16, 2014 12