Presentation on theme: "Managing Regulatory Documents Electronically Adrienne Meyer, CIP Regulatory Specialist Institute of Translational Health Sciences Research Coordinator."— Presentation transcript:
Managing Regulatory Documents Electronically Adrienne Meyer, CIP Regulatory Specialist Institute of Translational Health Sciences Research Coordinator Networking & Education Day May 17, 2013
Goals and Contents Describe regulatory binders Describe things to consider when developing and implementing an electronic regulatory binder Demonstrate a simple system for electronic binders Questions and Discussion
What is a Regulatory Binder? Originates from the conduct of clinical trials – FDA regulated, e.g. IND or IDE Synonyms: investigator binder, investigational site file (ISF), investigator files, study binder, study administrative file Good Clinical Practice (GCP) Guidelines define Essential Documents as those documents which individually and collectively permit evaluation of the conduct of a trial and the quality of data produced. – Full List of Essential Documents can be found on the FDA’s website: http://www.fda.gov/downloads/Drugs/Guidances/ucm073122.pdf
What is a Regulatory Binder? Essential Study Documents which are NOT patient specific are organized in a Regulatory Binder It is often the first document reviewed during audits and inspections. A complete regulatory binder provides documentation to support that the investigator adhered to his or her responsibilities under federal laws and guidance for conduct of human subjects research.
What is a Regulatory Binder The collection of paper documents under pre- specified tabs is a convention NOT a stipulation of GCP. “Regulatory Binder” is simply a place where we organize and store and update regulatory documentation
What kinds of documents should be in a regulatory binder? Depends entirely upon the nature of the research Involves Human Subjects? a. Current and Past Protocols/Standard Operating Procedures/Manuals of Operation b. IRB approvals and correspondence c. Current and Past Versions of Consent Forms and other Authorizations to be signed by Subjects d. Documentation of Investigator and Staff Training e. Sponsor required documentation Involves Labs? CLIA and CAP certifications Current and Past Lab Normal Ranges Drugs and Devices? Past and Present Investigator’s Brochure Device Manual FDA Form 1571/1572 Subject Screening and Enrollment Logs Adverse Event and Protocol Deviation Logs Monitoring and Site Visit Logs Delegation of Responsibility Log Curriculum Vitae and Licenses Sponsor Correspondence Other Approvals Radiation Use Committees Institutional Approvals For more specifics including a checklist and downloadable templates, see our resource page: https://www.iths.org/forms
Thinking electronically Many of these documents are retained as copies at the investigational site UW has been directed by the legislature to reduce paper consumption by 30% http://f2.washington.edu/ess/engage/paper-conservation
Show and Tell Why not e-copies instead of paper copies?
Getting Started Come up with a plan – Are you starting from scratch with a new study or are you converting existing paper documents into electronic? – What will you NEED to keep in paper?
Security & Technology How large are your files? Do you have enough storage space? Is your system secure? Is it backed up regularly? Is it in danger of disappearing or changing in the foreseeable future. Is it accessible to key study personnel? What format will you use? Will it be readable in the future? Archivable? Can you put procedures in place for providing access to the electronic regulatory files at the time of a visit by a monitor or auditor. – For example: if documents are copied to a CD or DVD for a monitor’s visit, can you test the CD or DVD to make sure the documents were copied successfully and completely?
Institutional Requirements? Records belong to the institution, not necessarily the sponsor or the investigator – At UW – It’s the state’s property and public records to boot! Specified and required order and content? – UW has none, but others may – VA folks? What file types are acceptable? Contact your records management office!
Tips and Tricks Minimize the use of paper at its source – Does that really need a signature? – Do I really need to keep this in paper? Describe your documentation process in your Standard Operating Procedures or Manual of Operations! Develop naming conventions so that the contents of each file and document are apparent when viewing the labels. Any appropriate and easily understandable labeling convention is fine. Examples: – Limburg_medlic_x21Jan2010 – Limburg_CV_02Feb2009 – Limburg_HSP_x10Jul2010 Keep study closure and long-term record retention in mind when developing your system.
Tips and Tricks Place a paper placeholder in the relevant location of the binder that directs an individual to the electronic location OR place a paper placeholder in one location in the binder that includes a list of all documents that are stored only in electronic format, along with the specific electronic path for each item. Develop support materials for your monitors and auditors.
General good practices applicable to both paper and electronic Tailor the binder to meet the needs of your specific protocol Unless required by your institution, Include only sections pertinent to your protocol. Organize and order the sections to facilitate easy use and reference Add additional folder and/or documents to each section as needed. Keep the Regulatory Binder current and up-to-date. Identify an individual(s) responsible for maintaining the binder. Ensure that this person is on file with the IRB as an Additional Person to Contact to ensure that all IRB correspondence and documents are received/filed in a timely manner. Store binder in a safe and secure location, but accessible to study staff at all times. Participant-specific documentation and information, e.g., signed consent forms, test results, and completed case report forms, should be maintained separately in participant-specific binder/file. The Regulatory Binder may sometimes consist of several folders that are stored in the same or different locations. It is important to know where all these documents are located to be able to pull them out when needed in a timely manner.
Thanks and Credit! Thanks to Phase I Medical Oncology group at SCCA! – Bojana Askovich – Reina Hibbert – Jamie Williams Thanks to Christine Taylor of UW Medicine Records Management! Help ITHS ensure our resources are available for all future research. We rely on these citations as a critical performance measure when reporting our annual productivity to NIH. Remember cite our grant UL1TR000423 in your publications