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  Clinical Trials Registration
    Several initiatives are underway to establish clinical trial registries. The registries would make information about clinical trial results accessible to the scientific community, health care practitioners, and members of the public. Such registries would include corporate sponsored research as well as investigator-initiated research.

The establishment of publicly accessible clinical trial registries promotes full disclosure of research results, positive or negative, and transparency of clinical trial activities. Making information accessible through registries acknowledges the contributions of those individuals who have participated as subjects in clinical trials. Participants expect the results of trials to be made available to others and to contribute to the advancement of medical science.

Principal investigators are now being asked to register their clinical trials in a publicly accessible registry. In some cases this is a condition of consideration for publication in a journal that has adopted the registration requirements of the International Committee of Medical Journal Editors (ICMJE). [See: N Engl J Med 351:12, September 16, 2004]

Currently, there is no single set of instructions, guidelines, or requirements and more than one registry has been established. This leaves investigators wondering which trials, what information, and which registry. The registry developed and maintained by the National Library of Medicine at NIH is the most commonly used such registry and can be accessed at http://www.clinicaltrials.gov.

The Partners Human Research Office has published guidance and instructions for investigators seeking to register their clinical trials. For more information, please see the PHRC web page, "Registration of Clinical Trials with ClinicalTrials.gov," or for assistance with the registration process, contact the PHRC registration administrator.

   
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    HIPAA Security Rule Is Here
   

The HIPAA Security Rule, which addresses the privacy protection of electronic protected health information (PHI), went into effect in April 2005. Similar to the Privacy Rule, the Security Rule also deals with identifiable health information as defined by the HIPAA-designated 18 identifiers. The Security Rule defines standards for protecting electronic PHI with detailed attention to how PHI is stored, accessed, transmitted, and audited.

Who is affected by the Security Rule?
Any researcher who stores PHI electronically, including (but not limited to):

  1. A single researcher who stores data in a spreadsheet, Word document, etc. on an H: drive.
  2. A researcher who stores data on a personal laptop, zip drive, or other portable hard drive or non-Partners PC.
  3. A researcher and co-investigators who access data on a shared drive maintained by their department or Partners IS.
  4. Researchers who transmit data electronically as part of a multi-center study
  5. Researchers who maintain small, medium, or large data repositories

Please review the new HIPAA Security Rule documents on the following PHRC web pages for more information: HIPAA Security Rule and Mac Security.

   
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    PHRC Review Metrics
    The PHRC office monitors its review activities to assure an efficient and effective operation and to identify areas for improvement. The table below contains FY05 data on review of new protocols at convened meetings of the PHRC, commonly referred to as “full board review.” The data includes the average length of time it took to complete each step in the review process - from date received in the PHRC office to the date the PI was notified of PHRC approval. We plan to provide this and other similar reports on PHRC review activity on a quarterly basis.
   
New Submissions: Full Board Review - FY05 1st Quarter 2nd Quarter 3rd Quarter
Data limited to studies approved with modifications (requires modification) Ave # days Ave # days Ave # days
# studies reviewed by full board
74
87
69
Time from receipt to IRB review
21
21
18
Time from IRB review to PI notified
10
8
6
Time from PI notified to receipt of response from PI
27
26
28
Time from receipt of PI response to IRB review of PI response
14
7
10
Time from IRB review of PI response to PI notified
8
5
7
Time from receipt to PI notified of approval
77
58
65

Note: The data include delays due to incomplete submissions and/or incomplete responses.
   
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    What's New at the IRB?
    New Drug/Biologic Form Released
    The PHRC recently released several updated submission forms, and has just released an updated Drug/Biologic form. The new form can be downloaded on the “New Submissions” page of the PHRC web site. As always, feedback on the revised form is welcome. Please e-mail Daniel Connor with any comments on our new forms, and please remember to always check the PHRC website for updated forms prior to making any submissions to the PHRC.


New Guidance on Research Involving Prisoners
The PHRC has just issued new guidance on research that involves prisoners. Please go to the PHRC Policies and Guidance web page titled, "Research Involving Prisoners" for more information.


   
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    Upcoming Events and Workshops
     
Title: Research Consent Writing Workshops
Speaker: Ann Ogletree, MBA - Partners Human Research Committee
Available Dates/Times:
September 15, 2005 from 8:30am-11:30am in the MGH Yawkey Center, Room 10640
October 5, 2005 from 9:00am-noon in the MGH Yawkey Center, Schiff Room 4820
October 20, 2005 from 9:00am-noon in the BWH OBC 4-002G

Summary: Register for a half-day “Plain Language” research consent form writing workshop, presented by Ann Ogletree, Senior Human Research Specialist at the PHRC. Recent participant feedback included, “…consent form on the new template (approved by the IRB with no revisions!!!),” and “It was so helpful.” An additional workshop has been added in September to accommodate demand. To register, please email Ann Ogletree and specify which dates work for you. Feel free to sign up at either campus. Seating is limited to 12 at each session, so please list all acceptable dates.


Title: ICH GCP - What Is It and How Does It Affect You?
Speaker: Sarah A. White - Senior QA/QI Specialist, Human Research QI Program
Available Dates/Times:

September 16, 2005 from 12pm-1pm at (MGH) 50 Staniford Street, 10th Floor, Room 1064
September 23, 2005 from 12pm-1pm at (BWH) 1 Brigham Circle, CCI Conference Room BC-3-014B

Summary: The International Conference on Harmonisation (ICH) published Good Clinical Practice (GCP) Guidelines in 1996. This session will review the ICH GCP guidelines and discuss how they affect you. This session was offered in the summer. It is being offered again due to high demand from the Partners research community. To register, visit the QI registration web page, or call 617-424-4137.


Title: Issues for the Bench and Desk Scientist
Speaker: Elizabeth L. Hohmann, MD - Chair and Director of the Partners Human Research Committee
Date/Time: November 9, 2005 from 4-5 p.m.
Location: MGH O’Keeffe Auditorium

Summary: The purpose of this seminar is to discuss ethical, regulatory, and institutional issues relevant to analysis limited to human biological samples and medical records. It answers questions, like: What needs IRB review (all of these things, at least initially!)? Which research is appropriate for expedited review? What is a "secondary use" of data or samples? What information does the IRB need to review a project efficiently? It also teaches how to share your data and specimens properly, how to fill out forms for the IRB, and which pitfalls and problems to avoid. This lecture is strongly recommended for new research fellows, though all investigators and study staff will benefit. Registration will be through the MGH Clinical Research Program. Watch for a registration announcement in the coming weeks.


Title: Record Keeping - Studies In Transition
Speaker:
Sarah A. White - Senior QA/QI Specialist, Human Research QI Program
Available Dates/Times:
October 14, 2005 from 12pm-1pm at (MGH) 50 Staniford Street, 10th Floor, Room 1064
October 21, 2005 from 12pm-1pm at (BWH) 1 Brigham Circle, CCI Conference Room BC-3-014B

Summary: Inheriting a study? Handing off a study? Ensuring good record keeping is essential during periods of staff transition. This session will focus on actions you can take to ensure your study records are complete and accurate when you take on a study or before you hand it off. To register, visit the QI registration web page, or call 617-424-4137.


Title: Monitoring: What Is It and How To Do It
Speaker:
Sarah A. White - Senior QA/QI Specialist, Human Research QI Program
Available Dates/Times:
November 4, 2005 from 12pm-1pm at (MGH) 50 Staniford Street, 10th Floor, Room 1064
November 11, 2005 from 12pm-1pm at (BWH) 1 Brigham Circle, CCI Conference Room BC-3-014B

Summary: Monitoring is an essential activity that ensures regulatory compliance. This session will review applicable regulations and guidelines governing study monitoring and describe various types of monitoring activities for different types of studies. The QI Monitoring Checklist will be provided to each participant. Following the discussion session, QI staff will demonstrate the Program’s new on-line monitoring system for those who may be interested in using such a system. To register, visit the QI registration web page, or call 617-424-4137.


Title: What the IRB Really Wants
Speaker: Elizabeth L. Hohmann, MD - Chair and Director of the Partners Human Research Committee
Date/Time: November 10, 2005 from 4-5 p.m.
Location: MGH O’Keeffe Auditorium

Summary: This lecture will provide important practical advice for investigators submitting protocols to the Partners Human Research Committee (PHRC/IRB). It addresses studies being reviewed by the full committee. Find out exactly what the IRB needs to review your study, and how to present your scientific, ethical, and medical information to the IRB. Understand common design flaws, pitfalls, and omissions. Learn how to avoid time-consuming deferrals and the "back and forth" communication by providing all of the relevant information at the time of initial review of your study! Registration will be through the MGH Clinical Research Program. Watch for a registration announcement in the coming weeks.


Title: Audits: How to Prepare for an External Audit
Speaker:
Sarah A. White - Senior QA/QI Specialist, Human Research QI Program
Available Dates/Times:
December 2, 2005 from 12pm-1pm at (MGH) 50 Staniford Street, 10th Floor, Room 1064
December 9, 2005 from 12pm-1pm at (BWH) 1 Brigham Circle, CCI Conference Room BC-3-014B

Summary: The FDA conducts more than 1000 audits annually, and investigator non-compliance has been responsible for about 70 percent of the deficiencies found. This session will provide an overview of common deficiencies cited by the FDA, as well as corrective/preventive actions you can take no matter whether you are conducting an FDA regulated study or an internally funded study. QI staff will also share their experiences regarding how to prepare for an external audit. To register, visit the QI registration web page, or call 617-424-4137.


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Educational Bullet

Question: Your study has been going well and accrual is right on target. Today you learn that one of your study subjects has been incarcerated for drunken driving and will be in jail for the next 90 days. You check his study schedule and realize he is not due for his next study visit until day 120 and so you do not have to worry about this subject’s study schedule. You hope that he does well and wait for him to return after incarceration. Are your obligations to this study met?

Answer: NO!

The federal regulations state that studies involving prisoners require special review and approval by the IRB. Get in touch with the IRB chair immediately to discuss whether or not this subject should continue on study. The Chair will need to understand whether or not the study treatments are potentially beneficial to the subject. If the chair concurs that there is potential benefit, the protocol will then require re-review by a special IRB panel. This panel must have among its members a prisoner representative. Long story short - in the rare case that a study subject becomes a prisoner, contact the IRB office immediately. For more information on prisoners in research, please refer to the following OHRP web page and the PHRC document, "Research Involving Prisoners."

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In Closing...

Have an idea for a story? Have a question or suggestion? Please contact us by sending an email to: irbeducation@partners.org

And finally, a special thanks to the people involved that made this newsletter happen!

Editorial Staff:
Deborah L. Barnard, Editor
Mary Ellis
Rosalyn Gray
Ann Ogletree

Contributing Staff:
Pearl O'Rourke
Judy Scheer

Technical Staff:
Daniel Connor
Vicki Mirabello

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