November 30, Efficient Startup of Multi-site Research Studies: Central IRBs and National IRB Reliance Platforms

Similar documents
Commercial/ Central IRB An independent organization that provides IRB review services

Ceded IRB Review. The University of Arizona has standing agreements in place for the following entities regarding ceded IRB review:

Ceded IRB Review. The project involves prisoners or other vulnerable populations that require special considerations.

RESEARCH PROTECTIONS OFFICE

Elizabeth Witte, MFA SMART IRB Regulatory Officer Regulatory Foundations, Ethics, and Law Program, Harvard Catalyst

Your Roadmap to Single IRB Review Serving as a Reviewing IRB

Florida State University IRB Standard Operational Procedures

A Guide to SMART IRB s Resources for IRB and HRPP Personnel

Centralized IRB Models

University of Iowa External/Central IRB Reliance Process Standard Operating Procedure (SOP)

University of Pennsylvania Institutional Review Board. Reliance Agreement Guidance: Penn as Central IRB FAQ

Single IRB Review. Jeannie Barone Director, HRPO. Institutional Review Board

Collaborative Research

The Children s Hospital of Philadelphia Committee for the Protection of Human Subjects Policies and Procedures. Cooperative Agreements

IRB Reliance Models: Workshop for OSU Researchers Collaborating with External Partners

Your Roadmap to Single IRB Review Getting Started with SMART IRB & the Online Reliance System

HEALTH CARE SYSTEMS RESEARCH NETWORK

Frequently Asked Questions (FAQs)

Central IRBs: Where Does the UR Fit into the Picture?? Kelley O Donoghue Tiffany Gommel Emily Flagg April 15 th 2015

SMART IRB Agreement Implementation Checklist and Documentation Tool

IRB Authorization Agreement Implementation Checklist and Documentation Tool

IRBMED: Ceding IRB Review to an External IRB

Your Roadmap to Single IRB Review Getting Started with SMART IRB & the Online Reliance System

SOP 801: Investigator Qualifications and Responsibilities

Chapter 4 Institutional Review Board (IRB) Roles and Authorities

UNIVERSITY OF TENNESSEE GRADUATE SCHOOL OF MEDICINE INSTITUTIONAL REVIEW BOARD PROCEDURES FOR FULL BOARD REVIEW

Investigator Manual. If you have questions about whether an activity requires IRB review, contact the IRB Office.

FDA s Guidance on Using a Centralized IRB Review Process in Multicenter Clinical Trials

Human Research Protections Program Medical College of Wisconsin and Froedtert Memorial Lutheran Hospital

CUNY HRPP Procedures: Multisite Non-Exempt Human Subjects Research

University of Iowa External/Central IRB Single IRB (sirb) Reliance Process Standard Operating Procedure (SOP)

Reporting an Unanticipated Problem Involving Risks to Subjects or Others (UPIRTSO) to the IRB

COMPLIANCE MONITORING

HOW TO CONDUCT AN IRB RELIANCE AGREEMENT. What Reliance Agreements Are, How They Are Reviewed, and What It Means for Submitting Research

the HRPP Director will prepare a draft report within three (3) workdays after the IRB meeting at which the determination occurred.

UNIVERSITY OF TENNESSEE GRADUATE SCHOOL OF MEDICINE INSTITUTIONAL REVIEW BOARD CONTINUING REVIEW AND REAPPROVAL OF RESEARCH

Info Sheet - Operations Office for Human Research Studies

Reliance on Independent/Central IRBs for Multicenter Clinical Trials

Michigan State University Human Research Protection Program

What s New in GCP? FDA, OHRP Issue Harmonized Guidance on Transferring IRB Oversight of Clinical Studies

AUTHORITY AND PURPOSE

SOP 407: PROTOCOL DEVIATIONS AND UNANTICIPATED PROBLEMS

OHRP Guidance on Written IRB Procedures

UNIVERSITY OF TENNESSEE HEALTH SCIENCE CENTER INSTITUTIONAL REVIEW BOARD CONTINUING REVIEW OF RESEARCH

CONTINUING REVIEW CRITERIA FOR RENEWAL

IRB Chair Responsibilities

CONTINUING REVIEW CRITERIA FOR RENEWAL

Single IRB Policy. Leslie Cooper, CIP Interim Director, Office of the IRB University of Alabama at Birmingham

Children s Hospital of Philadelphia Committees for the Protection of Human Subjects Policies and Procedures Continuing Review of Approved Research

RESEARCH SUBMISSION REQUIREMENTS

IRB MEETING ADMINISTRATION

UNIVERSITY OF GEORGIA Institutional Review Board

Study Management SM STANDARD OPERATING PROCEDURE FOR Interactions with the Institutional Review Board (IRB)

Administrative Hold, Suspension, or Termination of IRB Approval

Issue in IRB Approvals:

INSTITUTIONAL REVIEW BOARD (IRB) PROCEDURES

2 Institutional Review Board

IRB COMPOSITION AND IRB MEMBER ROLES AND RESPONSIBILITIES

Human Research Protection Program Policy

Supersedes Document Dated: 7/7/11. SOP: RR 401 Version No.: 07 Version Date: 9/8/15 EXPEDITED REVIEW 1. POLICY

MISSISSIPPI STATE UNIVERSITY HUMAN RESEARCH PROTECTION PROGRAM. Collaborative Research and Performance Sites (01-23) Approved

Effective Date: January 16, 2012 Policy Number: Appendix II. Revised Date: November 2, 2015 Oversight Level: Corporate

NIH StrokeNet Network Standard Operating Procedure

Review of Research by the Convened IRB

Institutional Responsibilities Under A Federalwide Assurance

Wayne State University Institutional Review Board

CONTINUING REVIEW 3/7/2016

Yale University Human Research Protection Program

DOCUMENTATION OF IRB DISCUSSIONS AND DECISIONS ( IRB MINUTES)

Institutional Review Board (IRB) Policies and Procedures Manual

Version 1. Submission Guide and Policies

2.0 Institutional Review Board

Guidance for IRBs, Clinical Investigators, and Sponsors IRB Continuing Review after Clinical Investigation Approval

Obtaining IRB Approval: The eirb Application Process

The Top 10 Human Research Protection Compliance Risks

Signature Date Date First Effective: Signature Date Revision Date: 07/18/2011

University of Pennsylvania Institutional Review Board. Reliance Agreement Guidance: Post-Approval Submissions

Lapse in IRB Approval

Investigator Manual Version date: April 1, 2010

SOP 903: HRPP AND NON-COMPLIANCE

PRINCIPAL INVESTIGATOR S ACKNOWLEDGMENT OF RESPONSIBILITIES

SOP 5.06 Full Committee Review: Initial IRB Review

Human Subjects in Research Review and Monitoring Form. Not applicable

Independent Ethics Committees

Policies & Standard Operating Procedures

Baptist Health Institutional Review Board. Study Closure Report (Expedited Review) IRB #: Study Title:

CONTINUING REVIEW OF APPROVED IRB PROTOCOLS

Initial Review. Approved By: Michele Kennett, JD, MSN, LLM Associate Vice Chancellor for Research. Table of Contents

To assure knowledge and compliance by documenting the annual administrative review and continuing IRB review of non-exempt projects for the IRB.

Research Involving Human Subjects: AA 110.7

IRB-REQUIRED INVESTIGATOR ACTIONS

NONCOMPLIANCE. 1. Overview

Children s Hospital of Philadelphia Committees for the Protection of Human Subjects Policies and Procedures. IRB Review Processes

1. Review and approval of the consent document is a responsibility that FDA assigns to the IRB with jurisdiction

Institutional Review Board Standard Operating Procedure. Suspension and Termination of IRB Approval

6/19/2014. Children s Hospital of Philadelphia: Recent Changes. Recent Changes in CHOP IRB Procedures

THE UNIVERSITY OF SOUTH DAKOTA -- INSTITUTIONAL REVIEW BOARD -- STANDARD OPERATING PROCEDURES

IRB MEETING ADMINISTRATION

Institutional Review Board (IRB)

I. Summary. II. Responsibilities

Transcription:

November 30, 2017 Efficient Startup of Multi-site Research Studies: Central IRBs and National IRB Reliance Platforms

Agenda Working with a Central IRB SMART IRB IRBchoice

Single IRB vs. Central IRB They mean the same thing: a single IRB of record overseeing all clinical trial sites participating in a multisite study IRB of Record: the IRB that is responsible for the review, approval and regulatory oversight of a research study Term used most consistently in federal guidance, correspondence and other documentation Term focuses on IRB s responsibilities More important than IRB s location or organizational relationship Single IRB relationship can be established in a variety of ways

Central IRB Review vs. Local IRB Review for Multisite Studies Local IRB: oversees research at just one location Reviews the protocol-level information and investigator/site qualifications as a single unit Central IRB: oversees research being conducted at many locations Reviews the protocol once on behalf of all sites Reviews each investigator/site submission in the context of the protocol

Why Centralized IRB Review? Multiple federal agencies endorse centralized IRB review for multisite research NIH, FDA, OHRP Centralized review = more efficient process Removes duplicative reviews Single IRB overseeing all participating sites = consistent oversight Uniform protocol and informed consent template for all sites Consistent subject protections More reliable study data

How Does This Work? Sponsor/CRO submits the protocol and all protocol level documents Approved The institutional site submits site specific documents Approved Smart forms Informed Consent Investigator CV Deferral information (if applicable) Sponsor/CRO has access to all protocol and site approval documents Sites have access to their own approval documents and protocol-level documents the site may need

Central IRB Responsibilities Central IRBs have the same regulatory responsibilities as local IRBs 21 CFR 50, 56 45 CFR 46 Audited regularly by FDA and relying sites AAHRPP accreditation Shows above-and-beyond commitment to quality HRPP

Deferral/Agreements When another IRB (not the local IRB) will serve as IRB of record, the local IRB may need to provide documentation of deferral 21 CFR 56.114 permits deferral of IRB oversight Possible Options for Documenting Deferral IRB Authorization Agreement (IAA) Master Services Agreement, Reliance Agreement or Global IAA Smart IRB or IRBChoice Study specific Required if research is covered by institution s Federal Wide Assurance (FWA) Covers all research reviewed by cirb Can be established in advance of any new submissions No need for other deferral documents National online platform Study specific Documents deferral

Responsibilities Schulman Responsibilities Assess investigator qualifications as part of submitted material Assess research education and training documentation for investigators and research staff Maintain registration with FDA and OHRP Notify designated institutional officials of accreditation changes Ensure compliance with ethical standards and regulations in approved research Assume regulatory responsibility for IRB s actions as IRB of record Manage necessary site-specific information for inclusion in the informed consent Approve informed consents that meet the IRB s requirements and maintain review of revisions Provide copies of IRB decisions and rosters Notify institution of serious or continuing noncompliance determinations, unanticipated problems in research, and suspension or termination of IRB approval Local IRB Responsibilities Assess investigator qualifications prior to submission to IRB and report any changes to qualifications that negatively impact subject safety Require and document research education and training for investigators and appropriate study staff Provide appropriate credentialing of staff Maintain the institution s approved FWA(s) Conduct security and privacy review of protocol and informed consent as required for HIPAA (unless cirb is responsible) Ensure investigator compliance and conflict of interest is managed in accordance with IRB requirements Decide whether to participate in a study or to limit an investigator s involvement prior to submitting research to IRB Indicate any relevant state laws or institutional concerns regarding the research in IRB s submission material For more information, see FDA Guidance for Industry Using a Centralized IRB Review Process in Multicenter Clinical Trials Include assessment of local context in IRB submission material to be considered during review of research proposals Report to the IRB any serious or continuing noncompliance, unanticipated problems in research, and other compliance issues potentially impacting human subject protections

Most Central IRBs Can serve as a privacy board Will review COI Are the reporting entity if IRB of record Look to the local IRB to be responsible for documenting human subject research protections training Are willing and able to review local context

Site Networks Therapeutically focused site networks designed to get studies started faster and more efficiently These networks are becoming more prevalent Networks assemble a roster of sites; these preferred sites get first option to participate Requiring sites to use a single IRB for network studies is becoming more common

Therapeutic Specialization Networks: Identifying the Need for Single IRB Network for Emergency Care Clinical Trials: Strategies to Innovate EmeRgENcy Care Clinical Trials Network (SIREN) StrokeNet

Evaluating a cirb Partner Regulatory audit history Accreditation Communication structure Submission deadlines and turnaround times Electronic tools References from other institutions

Reliance Platforms/Networks

Reliance Platforms/Networks Supports multisite single IRB review Minimizes duplicate institutional IRB review Can be used between local IRB and central IRB Single global agreement eliminates need for individual agreements One set of SOPs Online platform Documents acceptance of IRB of record and institutional IRB s deferral Flexibility in designating responsibilities (e.g., COI, HIPAA, documentation) Allows institutions to add comments and specific instructions Serves as a resource and provides training

Reliance Platforms/Networks 2014 2016 Founded as IRBrely by Dartmouth Synergy (Later joined by Harvard and University of Wisconsin- Madison) Became SMART IRB Funded by NIH/NCATS in preparation for NIH Single IRB Review policy SMART = Streamlined, Multisite, Accelerated Resources for Trials All CTSA institutions initially required to join (330 members) Generates email to all parties documenting reliance Ambassadors

Reliance Platforms/Networks 2011 2012 2014 R13 grant from NCRR initiated exploration IRBshare began, 45 institutions joined RO1 grant from NHLBI, became IRBchoice with 75 members Detailed institutional profile section in portal Email documentation to all parties Two methods Ceded model Sharing model

Reliance Platforms/Networks Differences No QI/QA requirement noted Requires use of online platform No SOPs Two methods Ceded model Sharing model Requires some type of QI/QA process unless otherwise agreed upon by both sites Does not require use of online platform One set of SOPs Extra documents

Questions?? Maria Stivers Manager, Institutional Services Office: 513.794.5743 Mobile: 859.760.6772 mstivers@sairb.com