Essential Documents & Source Documentation SOPs Margaret Matula, R.N., M.G.A. Nurse Consultant Clinical Research Management Branch TRP/DAIDS/NIAID/NIH e-mail: mm154j@nih.gov phone: 301- 402- 2302 DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 1 Principles Ensure data quality Create an audit trail Verify all data DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 2 Local Requirements Always refer to local, state, institution, and IRB/IEC policies and procedures. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 3 Essential Document SOP DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 4 Definition: Essential Documents Permit evaluation of: Conduct of a trial Quality of the data Generated throughout various stages of a trial: Before the trial begins. During the conduct of the trial. After completion or termination of the trial. Serve to demonstrate compliance with: Standards of good clinical practice (GCP). All applicable regulatory requirements. Audited/inspected by sponsor and regulatory authorities. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 5 IRB Approvals – revised 3. Dated proof of IRB/IEC submission of the following for both initial submissions and revisions (if any). Revised documents must be labeled (e.g., date and/or version number) to differentiate them from previous versions IND Safety Reports, Safety Memos, & Safety Alerts Investigator’s Brochures DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 6 Laboratory – revised To document competence of local, central or Group laboratories to perform protocol required tests and support reliability of results of medical/laboratory/ standardized procedures/tests, one of the following must be on file: Laboratories located in the United States CLIA Certification of Compliance CLIA Certification of Accreditation AND the agency certificate (e.g., CAP Certification of Accreditation) Laboratories located outside the United States Results of an established quality control and/or external quality assessment program Other validation DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 7 Screening & Enrollment Logs Pretrial screening of subjects (screening log) Chronological enrollment of subjects (enrollment log) Consists of: Initials of all patients screened PID # (if patient receives one) Date screened Date randomized Indicate reason if not randomized DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 8 Signature Key/Log Documents signatures of individuals using initials in place of a full signature to sign CRFs and source documents. Documents signatures and initials of all persons authorized to make entries and/or corrections on CRFs, ie, clinicians, MDs, Pharmacists, data personnel, etc. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 9 Signature Key Key must include: initials printed signature legal signature (first and last name) credentials (if appropriate) DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 10 Source Documentation SOP DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 11 Definition: Source Document Any original documents or certified copies that include documentation pertaining to a subject’s medical history, treatment, and condition while on a research study. Includes but is not limited to: Clinic chart Medical record Office notes Flow sheets DHHS/NIH/NIAID/DAIDS Laboratory reports Medication records Prescriptions Radiology reports SOP Training July 27, 2002 Slide # 12 Source Document continued… Make available for direct access all requested documentation that may be relevant to the subject’s trial participation. Saved as: Electronic media / computer records Original paper documents Certified copies DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 13 Informed Consent DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 14 Screening - revised Federal Regs and Institutional Policy must be followed when screening subjects to determine eligibility: 1. Screening: any procedure done solely for the purpose of determining a potential subject’s eligibility. 2. Consent must be obtained prior to invasive procedures. 3. Written consent required for screening unless IRB waives requirement. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 15 Screening….. 4. Either IRB approved generic screening consent or protocol specific consent is acceptable. Screening consent must be signed before screening begins. 5. If site uses screening consents, protocol consent must be signed prior to randomization. 6. Review of medical records and/or databases to identify potential subjects outside the institution is not permitted without prior consent of potential subjects. 7. Maintain a list of subjects screened for a protocol. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 16 Screening Find out how HIPPA is going to impact screening activities at your site!! DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 17 Special Populations Refer to 45 CFR 46 for special requirements of obtaining informed consent of special populations in research. 1. Pregnant women, fetuses, and neonates (subpart B) 2. Prisoners (subpart C) 3. Children (subpart D) Includes adolescents DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 18 Other Special Populations….. Non-English Speaking Information given to subject must be in language they understand— Refer to the regulations: 45 CFR 46, Subpart A and 21 CFR 50. OHRP guidance: http://ohrp.osophs.dhhs.gov/humansubjects/guidance/ic-non-e.htm FDA guidance: http://www.fda.gov/oc/ohrt/irbs/informedconsent.html#nonenglish DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 19 Requirements 1. Consent must be documented on a written consent form. 2. All consent forms must be approved by IRB. 3. All consent forms must be submitted to DAIDS for review. 4. All consent forms for new protocols and amendments must be approved by DAIDS. 5. Protocol-specific consent must be obtained prior to randomizing/enrolling subject. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 20 Signatures 1. Must be legal name. 2. Must not use initial for last name. 3. Strongly recommend not using an initial for first name. 4. Must be in ink. 5. Must be dated by each person signing the form (It is NOT acceptable for research staff to complete the date for another signer). DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 21 Signatures 1. Must be legal name. Sites are not expected to routinely verify a person’s legal name; however, if the site becomes or is aware that a person has not used his/her legal name to consent, then the following must be done: Obtain a new, signed consent with the legal name. Notify the local IRB/IEC. Document the events in the research record and the actions taken by the site. Ensure that there is documentation linking the two names. For monitoring and audits, the site must be able to show that the names refer to the same person, (i.e., John Doe is really John Smith). Follow local institutional/IRB policy regarding continued use of the alias. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 22 Signatures • If a subject is not able to write or sign his/her name in the form of a traditional “signature” as indicated above: 1. If permitted under state/local law or institutional/IRB policy, document in the research record that the person cannot sign his/her name and that it is their “mark”. 2. Also refer to the bullet on illiterate persons in this section. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 23 Case Report Forms (CRFs) as Source Documents (SDs) DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 24 CRFs – revised Requirement to maintain a list of the CRFs being used as source documentation. Requirement to sign/initial and date the original CRF as you would any other source documentation. Suggestion about the use of the SAE form as a source document. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 25 Copies: certified DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 26 Copies: Certified – revised It is a suggestion, NOT a requirement to certify copies of source documentation. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 27 Source Document SOP What’s the difference? Chart Note Flow Sheets Medical Records Research Record Source Document DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 28 Chart Note All notes related to study visits In Medical or Research Record Recorded by Site Staff SOP does not apply to notes from sources other than site personnel DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 29 Chart Note and Flow Sheets All entries must be signed/initialed & dated each new entry by person making the entry Exceptions: multiple entries by same person/same day single date with multiple entries by different staff DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 30 Medical Records At institutions with primary care facilities must be accessible to monitor if missing, staff notes efforts to locate them DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 31 Medical Records – revised Requirement is to obtain source documentation from outside sources to support endpoints or SAEs. Also, DAIDS Medical Officers may request that records be obtained when investigating AEs. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 32 Medical Records - revised Suggestions: Document all attempts to obtain records pertinent to subjects study participation Acknowledge (in SD) when records are missing Hospital records not held to GCP standards Obtaining records from outside sources is driven by need to gather sufficient info for adequate clinical assessment of the subject’s medical condition. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 33 Research Record All documents that are relevant & substantiate subject’s participation in research: IC, SD, Pharmacy. Records, CRFs, etc. Subject consented and Investigator agreed to monitors direct access to all records. Sites to produce record in it’s entirety: Source of data must be verifiable in original or certified copies. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 34 Research Record Shadow Files are an adjunct: May include: IC, Screening, Baseline, Vitals, Clinic & Lab findings, study drug, etc. Originals are preferred—monitors may ask for originals even if you have a shadow file. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 35 Source Document Original or certified copy Includes: Medical Record Primary Care office chart Clinic Chart Flow sheets, medical records, Rx, EKG CRFs used as SD Research record Sites must provide direct access to all requested, relevant documentation DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 36 Source Document No documentation for protocol required data = Inadequate Source documentation DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 37 Error Corrections – revised Suggestion for when it is considered necessary to give an explanation for why data were changed: If it is something a reviewer can “see” or is obvious, such as a transcription error, then it needs no explanation. For example, if the site corrected a lab value that was initially transcribed incorrectly to the CRF then an explanation for the correction is not necessary as long as it can be verified with the original lab report. If it is not clear, like a diagnosis or symptom that was deleted after initial entry, then there should be a rationale for the change. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 38 Other SD Sections to Ponder Contraception Study Drug/Agent protocol specified non-specified Concomitant Medications Toxicities Questionnaires DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 39 Contraception – revised Updated to reflect the changes in the revised TRP policy (to be released August 2002), “Guidance for Selecting and Modifying the Appropriate Protocol Eligibility Criteria Template for Pregnancy Prevention”. Addresses reproductive potential of children/ adolescents. Must not participate in a conception process…and if participating in sexual activity that could result in pregnancy, the study volunteer/partner must use… DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 40 Concomitant Meds: Non-Study All Non-Study specified Suggestions: Include non-Rx. Drugs (aspirin) vitamins illegal drugs herbals DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 41 Study Drug/Agent Dispensed only by written order of Investigator of Record or licensed practitioner responsible to IoR Recorded in research record DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 42 Study Drug/Agent - revised Protocol Specified distributed by NIAID’s distribution center specifically required by protocol EXCEPT if the study is designed to evaluate subjects already receiving specified drugs as part of their routine medical care before study entry. risks identified in the IC Protocol will specify AE/SAE reporting DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 43 Study Drug/Agent Non-Specified agent used to address study’s primary therapeutic objective or other study objectives types or classes of drugs not specified by name Risks do not need to be identified specifically Protocol will specify AE/SAE reporting requirements DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 44 Toxicities: grading – revised ALL toxicities and signs/symptoms, including those reported by the subject, must be recorded in the research record and assessed for clinical significance: Numerical grade or written description that corresponds to the toxicity table. Exceptions for abnormal labs & non-reportable AEs that are not clinically significant: Grade is NOT required. Assessment of event IS required. Staff must assess and grade event if it was originally assessed by non-study staff. Relationship to study agent only if it is a reportable SAE. Alternate etiology if “not related” to study agent. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 45 Questionnaires - revised Retain completed form Except if site staff are blinded to the completed questionnaire as per the protocol. DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 46 Internet Sites DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 47 Internet Sites Regulations Code of Federal Regulations (CFR) http://www.access.gpo.gov/nara/cfr/index.html DHHS — Protection of Human Subjects, 45CRF46 Title 45: Public Welfare – Part 46: Protection of Human Subjects FDA — Protection of Human Subjects, 21CFR50 Title 21: Food and Drugs – Part 50: Protection of Human Subjects FDA — Institutional Review Boards, 21CFR56 Title 21: Food and Drugs – Part 56: Institutional Review Boards DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 48 Internet Sites continued… Regulations FDA — Investigational New Drugs, 21CFR312 Title 21: Food and Drugs – Part 312: Investigational New Drug Application FDA — Electronic Records, 21CFR11 Title 21: Food and Drugs – Part 11: Electronic Records; Electronic Signatures FDA — Financial Disclosure, 21CFR54 Title 21: Food and Drugs – Part 54: Financial Disclosure By Clinical Investigators FDA Financial Disclosure Forms FDA 3454 & 3455 – http://www.fda.gov/opacom/morechoices/fdaforms/cder.html DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 49 Internet Sites continued… Guidances FDA http://www.fda.gov Good Clinical Practice http://www.fda.gov/cder/guidance/index.htm – Select “ICH” (from list on left) » “Efficacy” (scroll down on right) » “E6: Good Clinical Practice” Computerized Systems Used in Clinical Trials http://www.fda.gov/ora/compliance_ref/bimo/ffinalcct.pdf Financial Disclosure By Clinical Investigators http://www.fda.gov/oc/guidance/financialdis.html DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 50 Internet Sites continued… Guidances Regulatory information http://www.fda.gov/cder/regulatory/default.htm Information Sheets http://www.fda.gov/oc/ohrt/irbs/default.htm Information for Health Professionals http://www.fda.gov/oc/oha/ DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 51 Internet Sites continued… Guidances OHRP http://ohrp.osophs.dhhs.gov/ – Workshop schedule – Educational materials – Compliance Information IRB Guidebook http://ohrp.osophs.dhhs.gov/irb/irb_guidebook.htm Guidance materials http://ohrp.osophs.dhhs.gov/g-topics.htm Policy information http://ohrp.osophs.dhhs.gov/polasur.htm – Regulations – Informed consent – Assurances DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 52 Internet Sites continued… Guidances and Information NIH http://www.nih.gov Grants Policy and Guidance http://grants.nih.gov/grants/policy/policy.htm Policy: Education in the Protection of Human Research Subjects http://grants.nih.gov/grants/guide/notice-files/NOTOD-00-039.html Frequently Asked Questions: http://grants.nih.gov/grants/policy/hs_educ_faq.htm Bioethics Resources on the Web http:// www.nih.gov/sigs/bioethics/ DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 53 Internet Sites continued… Guidances and Information NIAID http://www.niaid.nih.gov DAIDS http://www.niaid.nih.gov/daids/ Regulatory Operations Center http://roc.s-3.com/ DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 54 Internet Sites continued… Professional Organizations (a few examples) Associates of Clinical Research Professionals http://www.acrpnet.org/index.html Barnett International http://www.barnettinternational.com/ Center for Clinical Research Practice: http://www.ccrp.com Drug Information Association http://www.diahome.org/ Institute for International Research http://www.iir-ny.com Pharmaceutical Training Institute http://www.pharmatraining.org RAN Institute, Inc. http://www.raninstitute.com/ DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 55 Contact Margaret Matula e-mail: mm154j@nih.gov phone: 301-402-2302 DHHS/NIH/NIAID/DAIDS SOP Training July 27, 2002 Slide # 56