View this recorded webinar to hear an overview of the Guidance Document on Electronic Source Data in Clinical Investigations and its practical implementation.
2. Your Speakers
► Maura Bearden
• Maura is a graduate of the University of North Carolina at
Chapel Hill and has been with DATATRAK in a variety of
Clinical Data Management roles since 2012. Ms.
Bearden’s expertise is in the streamlining of study start-up
tactics, data management and customer service.
► Bill Gluck, Ph.D.
• Dr. Gluck has over 30 years of expertise in clinical
research, with experience in sponsors, CROs, and with
DATATRAK in a variety of roles. Dr. Gluck is also the
Program Director for the Clinical Trials Research and
Medical Product Safety/Pharmacoviligance programs at
Durham Technical Community College. Dr. Gluck earned
his Bachelor of Science Degree at the University of
Scranton and Master and Ph.D. degrees from North
Dakota State University.
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3. Agenda
► Key Dates in Time: eSource
► Overview of the Guidance Document on
Electronic Source Data in Clinical Investigations
► Why eSource?
► Practical Applications – eSource: A CDM’s Tale
of Three Studies
• Challenges of eSource Studies
• Benefits of eSource Studies
• Future of eSource
► Summary
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4. Dr. Bill Gluck
Vice President Clinical Knowledge
DATATRAK International
eSource: Guidance Overview
5. Genesis of eSource: Key Dates in
Time
► 1968 – LL Weed, New England Journal of
Medicine 278:593-600
► 1980’s-present – Evolution of IRT, EDC,
ePRO/eCOA technologies
► 1997 – Regulatory definitions begin to evolve
• CDISC and an industry-led standardization movement
begin
► September 2013 – Guidance for Industry on
Electronic Source Data in Clinical Investigations
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6. Guidance Document Addresses the
Following
► Identification and specification of authorized
source data originators
► Creation of data element identifiers to facilitate
examination of the audit trail by sponsors, FDA,
and other authorized parties
► Ways to capture source data into the eCRF
using either manual or electronic methods
► Clinical investigator(s) responsibilities with
respect to reviewing and retaining electronic
data
► Use and description of computerized systems in
clinical investigations
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7. eSource studies pertain to clinical trials where
direct data entry into an electronic data capture
system (EDC) is used in contrast to paper
source studies where data are transcribed from
a paper source into EDC.
Simply put (from the Guidance Document):
“Electronic source data are data initially recorded
in electronic format.”
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8. Data Capture: Electronic Source Data
Origination
► List of authorized source data originators should be
developed and maintained by the sponsor and
made available at each clinical site
► Examples of Data Originators:
• Clinical investigator(s) and delegated staff
• Clinical investigation subjects or their legally authorized
representatives
• Consulting services
• Medical devices
• Electronic Health Records
• Automated laboratory reporting systems
• Other technology
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9. Data Capture: Source Data Capture, Data
Element Identifiers, Modifications and
Corrections, and Use of Data Quality Checks
► Source Data Capture
• Direct entry of data into the eCRF
• Automatic transmission of data directly into the eCRF
• Transcription of data from paper or electronic sources
to the eCRF
• Direct transmission of data from the EHR to the eCRF
• Transmission of data from PRO instruments to the
eCRF
► Data Element Identifiers
► Modifications and Corrections
► Use of electronic prompts, flags, data quality
checks in the eCRF
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10. Data Review
► Clinical Investigators
• Clinical Investigator(s) review and electronic signature
• Data exempt from investigator(s) review
► Modifications and Corrections During Review of
the eCRF
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11. Retention of Records by Clinical
Investigator(s)
► Retain control of the records
• Completed and signed eCRF
• Certified copy of the eCRF
► Be able to provide inspectors with access to the
records that serve as electronic source data
► When transcription from paper occurs – the
paper is the source and must be retained
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12. Data Access
► Viewing Data
• Sponsors, CROs DSMBs and other authorized
personal can view data before and after the clinical
investigator has signed the completed eCRF
– Allow for early detection of study-related problems
– Missing data
– Data Discrepancies
► CDMP should list individuals with authorized
access to the eCRF
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13. Use and Description of Computerized
Systems
► Adequate controls must be in place
► Note: determination of whether a computer
system is suitable may not be under the control
of the clinical investigator or sponsor (EHRs for
example) – see 45 CRF Part 170
► Documentation – if computerized system are to
be used
• Protocol/CDMP/Investigational plan
• Description of security measures employed to protect
the data
• Description/Diagram of the electronic data flow
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14. Why eSource?
► Companies are reluctant to move away from
paper-based source documentation
• It is very familiar and is today’s standard
• It is well documented and has a clear audit trail
• It has well documented security measures
► eSource
• Higher data integrity = Streamlined Data Review
Process
• Real-time accessibility
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15. Maura Bearden
Clinical Data Manager
DATATRAK International
Practical Applications
eSource: A CDM’s Tale of Three
Studies
16. eSource Case Studies
► Three Different eSource Studies
► Study 1:
• Phase 2, 160 subjects and 24 sites
► Study 2:
• Phase 3, 400 subjects and 31 sites
► Study 3:
• Phase 2, 210 subjects and 20 sites
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17. eSource Case Studies
► Analysis of three studies provides the
following information:
• Challenges of eSource Studies
• Benefits of eSource Studies
• Future of eSource
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18. Challenges of eSource Studies
► Workflow process between monitoring and
data management
► Protocol-Specific system checks
► FDA Guidelines pertaining to data
originator elements for transcribed
assessments
► Site Compliance of FDA Guidance of
electronic source data
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19. Challenge of Workflow Process
► Workflow process between
monitoring and data management
• Study: Cross-comparison of all three
studies
• Problem: How to document the review
between monitors and data
management
► Solution: Additional data review flag
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20. Challenges of Protocol-Specific
Checks
► Protocol-Specific System Checks
• Study: Progression of all three studies
• Problem: Number of protocol-specific system
checks
► Solution: Identification of integral protocol
checks, help prompts and additional
electronic case report forms (eCRFs)
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21. Challenges of FDA Guidelines
► FDA Guidelines pertaining to data
originator elements for transcribed
assessments
• Study: Study 3
• Problem: Coordinator entering information
into eCRF that is being read off by PI and the
conflict with the data originator in EDC.
► Solution: additional review fields on eCRF
that correspond to authorized data
originator
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22. Challenges of FDA Guidance
► Site Compliance of FDA Guidance of
electronic source data
• Study: Study 1
• Problem: Sites writing study information on
paper
► Solution: Note-to-File regarding paper
sources and retraining of site
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23. Benefits of eSource Studies
► Higher Data Integrity
► Real-Time Data Availability
► Decreased Time for Data Management
Review
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24. Higher Data Integrity Benefit
► Higher Data Integrity
• No queries needed to correct transcription
errors between paper source and EDC
• Protocol-specific edit checks in the system
and eCRF prompts prevent subjects who are
not qualified from being randomized in the
study
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25. Real-Time Data Availability Benefit
► Real-Time Data Availability
• Allows for all information to be available at
any time
• Reduce review time querying site to enter
information
• Allows for real-time reports with all available
data
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26. Decreased Time for Data Mngt
Review
► Decreased Time for Data Management
Review
• Reduced number of confirmation queries
• Limits data management review to cross-
checks and traditional data management
reviews
• Remote monitoring (increased importance)
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27. The Future of eSource
► Familiarity and optimization of start-up and
workflow process of eSource studies
• Familiarity and optimization can be seen in an
analysis of study 2 and study 3.
–Decreased study deployment time
–Distinct data review responsibilities for data
managers and monitors
–Streamlining user errors
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28. Conclusions
► eSource has been recognized as an accepted
means of capturing clinical data during clinical
investigations by the FDA
► The FDA has provided guidance to industry for
its implementation and use
► Case studies demonstrate the benefits of
eSource trials:
• Higher data integrity
• Real-Time accessibility
• Streamlined Data Management Review Time
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30. Contact Information
► Maura Bearden
• Maura.Bearden@DATATRAK.com
► Bill Gluck, Ph.D.
• Bill.Gluck@DATATRAK.com
► General Questions about DATATRAK
• Dorothy.Radke@DATATRAK.com
► Find Us Online
• www.DATATRAK.com
• http://www.slideshare.net/DATATRAK
• @DATATRAKinc on Twitter
• https://www.linkedin.com/company/datatrak-
international
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31. from Concept to Cure
with DATATRAK ONE
DATATRAK International
Cleveland, Ohio
Bryan, Texas
Cary, North Carolina
London, UK
888.677.DATA (3282) Toll Free
www.datatrak.com
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Notas do Editor
eSource was first attributed to LL Weed:
1 - Introduced the concept of the problem oriented medical record into medical practice
2 - Concept allow a 3rd party to verify the diagnosis
In the 1980’s through to the present we have been able to leverage technology using application offerings such as randomization and drug inventory, ePRO and eCOA (electronic clinical outcome assessments)
In the latter portion of the 1990’s we started to see an industry-wide movement toward standardization. Knowing through the use of standards we would be better positioned to leverage technology and management data more efficiently. With that in 1997/1998 CDISC was formed and an industry-lead standardization movement was underway.
In 2013 the Guidance for Industry on Electronic Source Data in Clinical Investigations was published – unlike the original draft the published guidance is a procedural guideline
To briefly note some of the highlights from the guidance document – the guidance document addresses each of the above items
In order to move forward we will define eSource data….as noted in the slide.
Data originators typically include the clinical investigator and the site staff – data collecting instruments and other technology-based sources
It is interesting to note that the FDA does not intend to assess the compliance of EHRs with Part 11
Pretty much do the same comparison to why use EDC over paper data collection
Now that we have an understanding of what the FDA has provided industry from the guidance document, let’s look a how eSource has been implemented in three active clinical studies – Maura Bearden will define the types and sizes of the studies, some of the challengs faced durting the implementation process and how each challenge was overcome. Based on the preliminary data from the three studies she will also describe the benefits gains through the use of eSource and then before concluding the webinar Maura will provide some of her ideas about the future of eSource in clinical trials.