CRA Interview Flashcards
FDA’s CFR (Code of Federal Regulations)
• Fundamental principle of research ethics
o Respect for persons
Recognizes the rights of individuals to make their own choices and decisions
o Beneficence
Researcher is responsible for participants well being
o Justice
Researcher’s obligation to distribute drug and practices equally
• Title 21 Food and Drugs
o Part 11 = Electronic Records; Electronic Signatures
o Part 50 = Protection of Human Subjects
o Part 54 = Financial Disclosure by Clinical Investigators
o Part 56 = Institutional Review Boards
o Part 200-499 = Drugs
o Part 312 = Investigational new drug application
Sec 312.32 = IND Safety Reports
• Serious and unexpected suspected adverse reaction
o Part 314 = Application for FDA Approval to market a new drug
o Part 600-699 = Biologics
Part 600 = Biological products
o Part 800-899 = Medical Devices
Part 812 = Investigational device exemptions
Part 814 = Premarket approval of medical device
• Title 45
o OHRP (Office of Human Research Protections) = “the common rule”
o OCR (Office of Civil Rights) – HIPPA
Phase I
15-30 pts, 1st in humans
Phase II
100-300 pts, determine efficacy and safety
Phase III
100-1000s pts, compare agent to standard treatment or placebo
Safety
Phase IV
Several hundred or 1000s
Post market, long term safety and efficacy
GCP
(Good Clinical Practices)
• International ethical and scientific quality of standard for designing, conducting, recording, and reporting trials with humans
o Protects the rights, safety and welfare of subjects
o Assure quality of data
o Makes trial data credible
• Focus on Rights and safety of pts, data integrity, confidentiality
• EXAMPLES: Draw a single line, initial and date, Data entered by authorized personnel only, EDC keeps audit trail
ICH
(International Conference on Harmonization)
• Concerned with quality, safety, and efficacy
• ICH Guidelines
o Trials should be conducted in accordance with ethical practices
o Risks are weighted against benefits
o Rights, safety and wellbeing of subjects
o Must have adequate clinical information to support the trial
o Must be scientifically sound
o Trial must be completed in accordance to the protocol
o Medical decisions for patient always responsibility of physician
o Must explain and train subjects on what their requirements are in the trial
o Freely given informed consent
o Investigation products manufactured, handled and stored in accordance to GMP (good manufacturing practices)
Fundamental Principles of Research Ethics
- Respect for persons - capacity and rights of patients; pts right to choose
- Beneficence – researcher is responsible for patient’s physical, mental, and social well-being; risks weighed
- Justice - equal distribution to all patients
Study Start-Up Process
• Identify sites • Contact sites • Execute CDA o Confidential Disclosure Agreement Between site an sponsor in order to share protocol specifics • Conduct Feasibility o Determines site interest and capabilities to perform study Staff and lab info Availability of staff Patient population • How many seen, how often and diagnosis • SQV • Initiate and Negotiate CTA & Budget o Agreement between site and sponsor that outlines each party and responsibilities within the research Includes budget • Reg Doc submission and IRB approval • SIV
AE
- Untoward medical occurrence
* Record as soon as study drug received to 30 days after last dose
SAE
(21 CR 312.32) Adverse event where the outcome was • Death • Life threatening • In-patient hospitalization • Birth defects • Permanent disability Must be reported within 24 hours
Regulatory Binder Checklist
• Protocol and amendments
• IRB approval
• ICF
o Proper version is signed
o Approved by IRB
o Patient, witness, and PI signatures and dates
ensure signature dates match
ensure dates are prior to any study visits and procedures
o Check for initials on each page if necessary
o ensure amended consent is signed if necessary
o ensure nothing was crossed out or altered
• IB and safety info
• Logs and forms (such as drug accountability logs, screening and enrollment logs, 1572, Financial disclosure form
o 1572 – Statement of Investigator
Agreement signed by investigator to provide information to sponsor, and will comply with FDA regulations related to study (IND studies)
Provides the sponsor with investigator’s and site qualifications to conduct study
Signed when investigator is going to participation in a new IND, prior to any study procedures or drug is given
Resigned if changes such as IRB address change, new subinvestigators, or new research lab has occurred
What to look for on 1572
• Section 1 = Investigators full name and address
• Section 2 = Education, training (CV)
• Section 3 = Name and addresses of all sites
• Section 4 = Name and address of all labs
• Section 5 = Name and address of IRB
• Section 6 = Names of Subinvestigators
• Section 7 = Name of protocols in the IND to be conducted by investigator
• Section 8 = Protocol information
o Financial Disclosure Form
FDA Form 3455 – 21CRF 54
PI and sub’s sign
Any compension made to PI from sponsor
•
o Drug accountability log
Lot number
Visit number
Date and amount dispensed, initialed by personnel
Date and amount returned, initialed by personnel
• Delegation of Authority Log
o Log that lists all site members names, roles, and study tasks within the study
o Authorized by the PI
• CV’s & Licenses
• All study communications (correspondence w/sponsor and IRB)
• Training records
• Lab records
• Manuals
• Medwatch forms
• Safety reports
• Blank CRFs
ICF
o Proper version is signed
o Approved by IRB
o Patient, witness, and PI signatures and dates
ensure signature dates match
ensure dates are prior to any study visits and procedures
o Check for initials on each page if necessary
o ensure amended consent is signed if necessary
o ensure nothing was crossed out or altered
1572
– Statement of Investigator
investigator agrees to comply with FDA regulations related to study (IND studies)
Provides the sponsor with investigator’s and site qualifications to conduct study
Signed when investigator is going to participation in a new IND, prior to any study procedures or drug is given
Resigned if changes such as IRB address change, new subinvestigators, or new research lab has occurred
What to look for on 1572
• Section 1 = Investigators full name and address
• Section 2 = Education, training (CV)
• Section 3 = Name and addresses of all sites
• Section 4 = Name and address of all labs
• Section 5 = Name and address of IRB
• Section 6 = Names of Subinvestigators
• Section 7 = Name of protocols in the IND to be conducted by investigator
• Section 8 = Protocol information
Financial Disclosure Form
FDA Form 3455 – 21CRF 54
PI and sub’s sign
Any compension made to PI from sponsor
PI name, title, organization
Study title
Signature and date
Drug accountability log
Log that tracks drug from the time the site receives IP to when its disposed/returned
Date of shipment received, batch number, who received it, quantity of IP
Date dispensed to patient, who dispensed, what patient and visit
Date returned by patient, who received it, and how much received.
Date disposed/returned, by who
CRA monitoring initials and date
Delegation of Authority Log
GCP E6 4.1.5
PI delegates tasks to all study staff (nurses, coordinators, sub-is, pharmacist, etc)
Staff name, signature, initials, list of responsibilities, start and stop dates
PI signature at the bottom at the end of study
Quality or SIV
• All visits require preparation, as in confirm time and date with coordinator, ensure investigator will be present, provide the site with your intended timeline and what you expect to see • While there: o Introductions o Facility Tour o Discuss Investigators obligations Protocol Source documentation requirements Maintenance of regulatory docs IP accountability Assess interest and ability of site • Write trip report
How would you prepare for a monitoring visit?
1) look at previous monitoring trip reports especially if it’s your first time visiting the site to familiarize yourself with the site and see what’s really been going on with the site
2) look at the EDC to see how much time you would need to perform STV
3) look thru EDC and assist in resolving any outstanding queries
4) remote verification to see if there are any protocol deviations
5) write confirmation letter to the site- agree on a specific date and time to visit the site
6) book your travel dates
7) go into IBRS system and print out IBRS report that’s used to perform IP accountability
8) go into TMF system and retrieve the TMF report in order to see all outstanding documents that need to be retrieved at the site
Walk me through an IMV
- All visits require preparation, as in confirm time and date with coordinator, ensure investigator will be present at some point, provide the site with your intended timeline and what you expect to review, ask them to pull files prior to you being there, and/or provide you with a login for electronic records
- “During a typical day, I would greet the Study Coordinator, sign the visit log, perform SDV (reviewed subjects with SAE’s first, then new enrolled subjects, and then subjects that have been previously SDV’d, check the Regulatory Binder, visit the Pharmacy to do drug accountability, meet with PI, then the Study Coordinator to discuss pending queries, follow up items, enrollment logs, and schedule next visit.
Arrive onsite and sign the monitoring log
Tell the SC your plan for the day to ensure that works for them
Review ICFs of newly enrolled or reconsented subjects
Complete SDV and make a list of discrepancies discovered for the SC to fix while I review the reg binder
Review reg binder for accuracy of logs and completeness of reg docs
Visit the lab and/or pharmacy as necessary
Have a discussion with the PI and SC at the end of the day to go over visit and findings
Walk me through a COV
• All visits require preparation, as in confirm time and date with coordinator, ensure investigator will be present at some point, provide the site with your intended timeline and what you expect to review, ask them to pull files prior to you being there, and/or provide you with a login for electronic records.
• While there:
o Sign Monitoring log
o Since it’s close out visit, ensure all CRFs are completed entered and correctly.
o Ensure there are no outstanding queries.
o Ensure all AEs have been captured
o Review reg binder for completeness
ensure all ICF signed on appropriate version
protocols and amendment
IRB Approvals
Licenses, certifications, CVs
Lab documentation
Completeness of all logs (Delegation of Authority, training, screening, enrollment, monitoring,
o Ensure study closure was reported to IRB
o Return or dispose of any remaining IP
• Write trip report