Business Operations Pre-Award
What is required to begin the business process? Possible indicators CDA executed Cancer Center MDG/PRC approvals Department contacts business office Electronic Proposal Transmittal Form (ePTF) What is it/what is it for? It is an electronic mechanism for Jefferson to manage, maintain, and approve research Used for all research at Jefferson
Electronic Proposal Transmittal Form (ePTF) What is needed? Materials required to complete (ePTF) for approval Protocol Investigator Brochure (IB) Draft Informed Consent (ICF) Clinical Trial Agreement (CTA) Sponsor Budget
Electronic Proposal Transmittal Form (ePTF) What is the approval process? Clinical trials First Round approval Contract/MCA/Budget Process may begin Second round approval MCA/Contract/Budget negotiated IRB approval letter and informed consent
JCRI Business Operations Coverage Analysis & Budget
Coverage Analysis
Materials needed to conduct a Coverage Analysis From Study Team: Same as (ePTF) process Protocol Investigator Brochure (IB) Draft Informed Consent (ICF) Clinical Trial Agreement (CTA) Sponsor Budget Approved electronic proposal transmittal form (ePTF) First round only
What is a Coverage Analysis? Document that determines the appropriate payor (i.e. Sponsor, Medicare or third party payor) for each item and service required by a clinical research trial
Why is a Coverage Analysis important? Reduces risk for submitting false claims Billing for services not part of a qualifying clinical trial Billing for items and services promised/paid for by Sponsor Billing for research only items and services Assists in budget negotiations with Sponsor/CRO Identifies costs that need to be accounted for in the sponsor budget Basis of billing compliance/audits Provides evidence of due diligence and a mechanism for compliance with billing rules
Coverage Analysis Process Receive all materials from the study team Create a grid that reflects all clinical events and time points in the protocol Review clinical guidelines along with CMS national and local coverage determinations to identify the appropriate payor for each event Send the CA to PI/SC for review and approval Approve or revise the CA as necessary
Clinical Trial Budget
Develop a financial plan that encompasses all phases of the study: Start-up costs Institutional costs Other costs incurred throughout the study Subject costs
Develop a financial plan that encompasses all phases of the study: Start-up costs training, meetings, IRB/regulatory work, source document creation Institutional costs Other costs incurred throughout the study Subject costs
Start-Up Costs
Develop a financial plan that encompasses all phases of the study: Start-up costs training, meetings, IRB/regulatory work, source document creation Institutional costs F&A, IRB fees, billing compliance fees Other costs incurred throughout the study Subject costs
Develop a financial plan that encompasses all phases of the study: Start-up costs training, meetings, IRB/regulatory work, source document creation Institutional costs F&A, IRB fees, billing compliance fee WIRB/Quorum – One time fee $2,500 Other costs incurred throughout the study site monitor fees, IRB work on continuing reviews or amendments, dry ice, close-out costs, etc. Subject costs
Other Costs
Develop a financial plan that encompasses all phases of the study: Start-up costs training, meetings, IRB/regulatory work, source document creation Institutional costs F&A, IRB fees, billing compliance fee WIRB/Quorum – One time fee $2,500 Other costs incurred throughout the study site monitor fees, IRB work on continuing reviews or amendments, dry ice, close-out costs, etc. Subject costs Any items that are not billable to insurance or provided by the sponsor
Accomplished by considering all stakeholders input: PI and Study Coordinator Radiology Pathology Pharmacy Hospital Billing Professional Services Billing Other departments Sponsor
Clinical Trial Agreement
What is required to complete a contract? Who wrote the protocol? Sponsor Clinical Trial Agreement PI/Jefferson Investigator Initiated Agreement Is the sponsor contract new or previously negotiated? If new – review/red line changes Forward to legal If previously negotiated – similar protocol Review/red line changes Forward to sponsor
What is required to complete a contract? Negotiate terms Ensure budget, billing and payment terms are acceptable Is the IRB approved? Approval letter and informed consent reviewed Sponsor and protocol must match contract Subject injury and indemnification language Different terms in each but intent must be the same (ePTF) secondary approvals
What is required to complete a contract? Execute Forward to PI Return to sponsor PDF or mail Account set up Establishment letter to staff and accounting MCA includes account number sent to staff and billing
Post Account Establishment Modifications/Amendments No cost extension Change in PI Modification to protocol No budget modification Modification to protocol Budget modification $5,000 or greater (ePTF) supplement Approvals, etc. Follow same SOPs as a new clinical trial
How to initiate the process Please, please, and please reach out to your clinical research administrator for more information. Ronald Polizzi, Director, Business Operations JCRI, Michael Caggiano, Team Lead, Jennifer Lott, Team Lead, Jenny Campbell, Clinical Research Administrator, LouEllen Daniel, Clinical Research Administrator, Ryan Massimilla, Clinical Research Administrator, Mary Rose Taft, Clinical Research Administrator,