Monitoring and Special Considerations for Multi-Center Trials September 10, 2010 Pav Aujla, MS, CCRP, RAC Primo N. Lara, Jr. MD A Translational Innovation Forum Agenda • Basic principles of: • Investigator’s Responsibilities • Sponsor’s Responsibilities • Monitor’s Responsibilities • “Sponsor – Investigator’s” Responsibilities • Investigator-Initiated Trials (IITs) • Investigator-Initiated Multi-Center Trials Agenda • Types of Monitoring Visits: Study Initiation Visit (SIV) • Periodic Monitoring Visits • Study Termination/Closeout (COV) • Agenda Understand safety reporting, record retention, and FDA regulations, among other important elements International Conference of Harmonization for Good Clinical Practice (E6) A common approach to clinical research Represents a “passport” to global use of clinical trial data Establishes common definitions and reporting guidelines for adverse events International Conference of Harmonization for Good Clinical Practice (E6) 1. Glossary 2. Principles of GCP 3. IEC/IRB Responsibilities 4. Investigator’s Responsibilities 5. Sponsor’s Responsibilities 6. Protocols and Amendments 7. Investigator’s Brochure 8. Essential Documents What are GCPs? Good Clinical Practices are the ethical, scientific and regulatory standards for conducting research involving human subjects. Essential Elements - Data Integrity - Patient rights and safety Is GCP training available at UCDHS? Yes, there is a GCP online training program on the CITI training site CITI homepage: http://www.citiprogram.org ICH GCP Section 4 Investigator □ □ □ □ □ □ □ □ □ □ □ □ □ 4.1 Investigator’s Qualifications and Agreements 4.2 Adequate Resources 4.3 Medical Care of Trial Subjects 4.4 Communication with IRB 4.5 Compliance with Protocol 4.6 Investigational Product(s) 4.7 Randomization Procedures and Unblinding 4.8 Informed Consent of Trial Subjects 4.9 Records and Reports 4.10 Progress Reports 4.11 Safety Reporting 4.12 Premature Termination or Suspension of a Trial 4.13 Final Report(s) by Investigator Investigator’s Responsibilities • 4.1 Investigator’s qualifications and agreements • • • 4.2 Adequate resources • • • • Education, Training, Experience Be familiar with protocol and IB Do you have the time? Staff and facilities Can you recruit patients under the recruitment period? 4.4 Medical care of subjects Medical decisions • Adverse events • Investigator’s Responsibilities 4.4 Communication with IRB • 4.5 Protocol compliance • 4.6 Investigational product(s) • Inventory, records (dates, quantities, batch/serial numbers, expiration date) • Investigator’s Responsibilities • • • 4.8 Informed consent of trial subjects 4.9 Records and reports 4.11 Safety reporting ICH GCP Section 5 Sponsor □ □ □ □ □ □ □ □ □ □ □ □ □ 5.1 Quality Assurance and Quality Control 5.2 Contract Research Organization (CRO) 5.3 Medical Expertise 5.4 Trial Design 5.5 Trial Management, Data Handling, and Record Keeping 5.6 Investigator Selection 5.7 Allocation of Responsibilities 5.8 Compensation to Subjects and Investigators 5.9 Financing 5.10 Notification/Submission to Regulatory Authority(ies) 5.11 Confirmation of Review by IRB 5.12 Information on Investigational Product(s) 5.13 Manufacturing, Packaging, Labeling, and Coding Investigational Product(s) ICH GCP Section 5 Sponsor □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ 5.14 Supplying and Handling Investigational Product(s) 5.15 Record Access 5.16 Safety Information 5.17 Adverse Drug Reaction Reporting 5.18 Monitoring 5.18.1 Purpose 5.18.2 Selection and Qualifications of Monitors 5.18.3 Extent and nature of Monitoring 5.18.4 Monitor’s Responsibilities 5.18.5 Monitoring Report 5.19 Audit 5.19.1 Auditing Procedures 5.19.2 Selection and Qualification of Auditors 5.19.3 Auditing Procedures 5.20 Noncompliance 5.21 Premature Termination of a Trial 5.22 Clinical Trial/Study Reports 5.23 Multicenter Trials Sponsor’s Responsibilities • 5.3 Medical Expertise • Selects qualified investigators • 5.9 Financing • Maintains records of financial payments to investigators • 5.10 Notification/Submission to Regulatory Authority(ies) • Maintains an effective IND with respect to the investigations • Ensures compliance with IND Sponsor’s Responsibilities • 5.14 Supplying and Handling Investigational Products(s) • Supplies the study drug in accordance to applicable regulations & maintains necessary records of receipt, shipment & disposition of study drug • 5.16 Safety Information • Ensures that FDA & investigators are informed of significant new adverse effects ICH GCP Section 5 Monitor □ □ □ □ □ □ 5.18 Monitoring 5.18.1 Purpose 5.18.2 Selection and Qualifications of Monitors 5.18.3 Extent and Nature of Monitoring 5.18.4 Monitor’s Responsibilities 5.18.5 Monitoring Report Monitor’s Responsibilities • Ensures clinical studies are conducted and reported in compliance with the approved protocol, SOPs, GCPs, and with applicable country and state-specific regulatory requirement(s) • Ensures that the rights and well being of human subjects are protected • Confirms reported trial data are accurate, complete, and verifiable from source documents Common Deficiencies (when GCPs are not followed) • • • • • Failure to follow protocol Inadequate informed consent process, record keeping, drug accountability Failure to report adverse events in a timely manner Inadequate monitoring Failure to submit IND amendment/progress reports Investigator-Initiated Trials (IITs): “Sponsor – Investigator” Investigator-Initiated Trials (IITs) Investigator comes up with the concept and designs the protocol Review literature/preclinical data Calculate sample size Trial cost Investigator gets the study “up and going” Investigator-Initiated Trials (IITs) Highest priority studies within the Cancer Center Viewed as of higher academic value Typically, the investigator serves as both investigator and sponsor roles Preferred UC Davis term: “Sponsor-Investigator” Most IITs are single institution; however, some may require multi-institution involvement Monitoring of multi-institutional IITs are more resource demanding Ensure that this is accounted for in the IIT budget!!! Investigator-Initiated Trials (IITs) Active to Accrual studies 10 IITs/Single Institution 4 with Pharmaceutical Industry Support 2 with Lawrence Livermore National Laboratory 4 with UCDCC support only Investigator-Initiated Multi-center Trials: “Sponsor – Investigator” Investigator-Initiated Multi-center Trials Single protocol conducted at more than one location Inter-Institutional Agreements Determine Authorship Policies Register trial with clinicaltrials.gov Oversee regulatory documents Adverse Events Reporting - Central Monitoring Body Site Monitoring ?? CC does not have the funds to do this Investigator-Initiated Multi-center Trials Active to Accrual studies 5 IITs/Multi-Center 4 with Pharmaceutical Industry Support 1 with UCDCC support only Types of Monitoring Visits Study Initiation Visit (SIV) • Periodic Monitoring Visits • Study Termination/Closeout (COV) • Study Initiation Visit (SIV) Verify that all required documents and supplies are available at the site, and that the study team is ready to enroll patients. Some items discussed at Site Initiation Visit: Review the study protocol Eligibility Criteria Treatment Procedures Periodic Monitoring Visits Verify informed consent for each subject enrolled Assess IRB status Review study files Check source documents Identify deviations and protocol violations Study Closeout/Termination The following activities are performed when a trial is completed as planned (close-out) or prematurely (termination). Final review of all study documents Inventory, itemize, return or destroy unused supplies and/or study treatment Obtain copies of any source documents only available in the medical records or ensure that medical records are not destroyed in the event of subject’s death Study Closeout/Termination Ensure that the regulatory files are complete and current Provide the sponsor with a summary overview of the study documenting official close Once all study activities are completed, submit the final report to the IRB Prepare a quick reference file including subject identification code list, sponsor contacts and document storage location for future reference Maintain study records according to long-term storage requirements Safety Reporting • Definitions (21 CFR §314.80) • • Serious Adverse Experience Reporting Requirements SAE Processing for UCD Patients SAE is identified by CTSU Staff Study Coordinator completes SAE Report per protocol Study Coordinator completes “UCDCC Serious Adverse Event Cover Sheet” Fax MedWatch Form to FDA Study Coordinator and PI determine event was unanticipated, related and increase risk “Acknowledgement of Receipt” Letter from FDA UCDCC Serious Adverse Event Cover and SAE report submitted to CC Database Study Coordinator submits ‘”Report of Unanticipated Problems Involving Risk to Participants or Others” to IRB [SAE Report = IND Safety Report or MedWatch Form] Safety Reporting Document and report all adverse events Report Serious Adverse Events to IRB per IRB SOPs Document all information regarding adverse events in the source document Clinical Trial Documentation Communications with subjects Shipping records Accountability logs Clinical Trial Documentation Documentation of used and unused drug supply returned to the Sponsor IRB approvals for study protocol and all amendments All source documents and laboratory records Essential regulatory documents (ie. FDA form 1572s) Any other pertinent study document Record Retention Clinical trial data records (GCP) At least 2 years after • • • The IND is discontinued (If no NDA is submitted) 5 years after submission of an NDA May have to keep the documents for a longer period of time Summary Be familiar with GCPs! Know your responsibilities as the “Sponsor-Investigator” Initiating a multi-center trial is complex Research whether the trial can be conducted at external sites Establish excellent communication with external sites Have the resources to provide administrative and other support to ensure proper conduct of the study References 21 CFR 50, 54, 56, 312 Friedman et al. Fundamentals of Clinical Trials, 3rd Edition 1999 FDA Guidance for Industry: ICH E6 Good Clinical Practice Guideline for the Monitoring of Clinical Investigations Helpful Links Investigator’s Handbook http://ctep.cancer.gov/investigatorResources/ investigators_handbook.htm • ICH website http://www.ich.org • US Department of Health and Human Services http://www.youtube.com/user/USGOVHHS#g/c/59 65CB14C2506914 Questions? Clarifications?