a seamless research compliance program for small health care … · 2012-04-26 · a seamless...

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A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE, CBHE, CIP, CHC, Vice President of Behavioral Health, Research & Health Care Compliance, and Government Relations for Boys Town National Research Hospital and Boys Town Boys Town National Research Hospital Downtown Medical Campus Pacific Street Medical Campus

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Page 1: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

A Seamless Research Compliance

Program for Small Health

Care Institutions

Pat Connell RN, MBA, CHE, CBHE, CIP, CHC, Vice President of Behavioral Health, Research &

Health Care Compliance, and Government Relations for Boys Town National Research

Hospital and Boys Town

Boys Town National Research Hospital

Downtown Medical Campus

Pacific Street Medical Campus

Page 2: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Center for Childhood Deafness

Page 3: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Youth From 36 States and 5 Countries

Have Been Admitted to the Boys Town Behavioral Health Services

Page 4: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Program Objectives

• Learn how to start compliance activities before grant

submission, including techniques for using existing

office software to track and document research

compliance activities.

• Explore various strategies for incorporating multiple

departments into research compliance programs.

• Learn how a seamless system approach from pre-

grant submission to post-grant review can improve

the effectiveness of your research compliance

program.

Why did we go down this

pathway?

• To reduce potential compliance problems

• To protect our reputation

• To increase organizational competence

• To reduce the temptation to operate “outside

of the box”

• To increase researchers’ success and

satisfaction

Page 5: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Why use a systematic approach?

• Because research compliance is a system,

whose various pieces have to interact

effectively to be successful and meet

compliance standards.

• To demonstrate commitment at every level of

the organization.

• To reflect a team or family approach for

working together.

Page 6: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Seven Stages for Success

• Stage 1 – Initial New Hire Orientation

• Stage 2 – Review of Grant Application

• Stage 3 – IRB review

• Stage 4 – Progress Reports

• Stage 5 – Not-For-Cause Audits

• Stage 6 – IRB Continuing Review

• Stage 7 – Grant Closing

Stage I – Initial New Hire Orientation

• Orientation (on-line) – CITI (every 2 years)

– Healthcare Compliance

– Research Compliance

• Special Topics (on-line) such as: – HIPPA for researchers

– Informed assent or consent

– Preparing grants

– Audit ready record management

• Consultation and Technical Assistance– Grant Preparation, technical assistance, and transfer of grants in and

out of organizations

* Every on-line course requires a post-test with a minimum pass score. Test results are forwarded to their supervisor and their electronic HR record.

Page 7: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Stage 2 - Electronic Review

of Grant Application

• Reviewers are notified by email (10 working days prior to grant due date).

– Link provided to share directory of research grant (PDF)– Reviewer reviews file (average response – 6 days)

– Email feedback provided to Research Coordinator who notify PI of changes needed or approval (same day)

– PI revises application (ranges from 1-4 day)

• Reviewers– Principal Investigator and/or Co-Investigator– Grants Accountant– Director of Research– Associate Administrator of Finance– Chairperson, BTNRH IRB (if human subjects are involved)– Chairperson, BTNRH IACUC (if animals are involved)– Director of BTNRH

Page 8: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Boys Town National Research Hospital Patrick E. Brookhouser, M.D.

Vice President & Director of Health Care, Father Flanagan’s Boys’ Home (FFBH), and Director of Boys Town National Research Hospital (BTNRH)

GRANT PROPOSAL SIGN-OFF SHEET

TYPE OF GRANT APPLICATION:

New Competing Continuation (Renewal) Revised or Amended (Resubmission)

Competing Supplement (Revision) Annual Grant Progress Report Grant Subcontract

Final Grant Report Other

PROJECT TITLE: DECISION PROCESSES IN DETECTION AND DISCRIMINATION

AGENCY: NIH-NIDCD/5R01DC006648-05

DUE DATE: 03/05/2009

TITLE/NAME ELECTRONICALLY REVIEWED DATE OF EMAIL APPROVAL

Program Director/ Principal Investigator (PD/PI)

Walt Jesteadt

ASSURANCE: (1) that the information submitted within the application is true, complete and accurate to the best of the PI’s knowledge; (2) that any false, fictitious, or fraudulent statements or claims may subject the PI to criminal, civil, or administrative penalities; and (3) that the PI agrees to accept responsibility for the scientific conduct of the project and to provide the required progress reports if a grant is awarded as a result of the application.

Original Signature Required for PD/PI

Approved 2/19/09, 10:36am

Co-Investigator Donna Neff

Approved 2/19/09, 2:58pm

Director of Research

Walt Jesteadt same as above

Division Director

Walt Jesteadt same as above

Grants Accountant

Theresa Langer Approved 2/20/09, 11:48am

Director of Finance or Associate Administrator of Finance

Leigh Jean Koinzan or Mary Brown-Zoucha Approved 2/20/09, 8:18am

VP & Director of Health Care, FFBH, and Director of BTNRH

Patrick Brookhouser Approved 2/20/09, 3:34pm

Chairperson,BTNRH Institutional Review Board (IRB)

Patrick Connell Approved 2/19/09, 5:39pm

Are Human Subjects Involved: YES NO

If YES to Human Subjects, is the IRB Review Pending: YES NO

Human Subject Assurance Number: FWA00004176

IRB Approval Date: 04/11/08

Protocol #: 04-11-XP Exemption #: (if applicable)

Chairperson, Institutional Animal Care & Use Committee (IACUC)

JoAnn McGee N/A

Are Vertebrate Animals Used: YES NO

If YES to Vertebrate Animals, is the IACUC Review Pending: YES NO

Animal Welfare Assurance Number: A3349-01

IACUC Approval Date:

Protocol #:

Please return this form to Barb Olmedo, BTNRH Coordinator of Research Administration

Stage 3 – IRB Review

• In addition to the normal human subject

protection functions, the IRB reviews:

– How the IRB protocol matches the funding grant

application and any amendments.

– How and the frequency of protocol monitoring by

the research compliance auditor.

– Any special consideration for protocol auditing.

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Stage 4 – Progress Report Reviews

• Principal Investigator • Director of Research• Division Director• Grants Accountant• Associate Administrator of Finance• Chairperson, BTNRH IRB (if human subjects

are involved)• Chairperson, BTNRH IACUC (if animals are

involved)• Director of BTNRH

Stage 5 – Not-For-Cause Audits

• Two individuals trained – (they have fulltime jobs in non-research areas)

• 48 hours notice

• Minimum sample size (30 records or 10% of subjects)

• Non-voluntary

• 3-6 hours per audit including report preparation

• Audit utilizes consistent methodology and components

• PI required to prepare action plan

• Random re-audits

• Seen by researchers as a learning and continuous improvement process

Page 10: A Seamless Research Compliance Program for Small Health Care … · 2012-04-26 · A Seamless Research Compliance Program for Small Health Care Institutions Pat Connell RN, MBA, CHE,

Stage 6 – IRB Continuing Review

• Grant Progress Reports

• Continuing Review Application

– Summary of: Progress to date, adverse events,

progress in meeting recruitment and enrollment

goals, early findings, etc.

– Update consent or assent forms

• Not-for-cause audits & action plan progress

• For-cause audits & action plan progress

Stage 7 – Grant Closing

• PI request permission for IRB to close protocol

• PI prepares closing report which includes a summary of activities

• IRB support staff provide direction on how to organize storage to include: subject logs, consent and assent forms, and other related research related materials.

• Protocol documentations is boxed and sealed for a minimum of three years in a central locked storage area.

• Three years later “tickler file” raises how many additional years before files can be shredded. This decision is made jointly by IRB and Research Compliance Officer.

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Changing the Organization Culture

• Commitment to compliance that is driven from top down

• No exceptions in following the process.

• Customer service mentality with all reviewers –resulting in timely feedback to PIs.

• Developing process “Champions” amongst senior researchers and division directors.

• Provide ongoing feedback to all PIs so everybody learns from each others experiences.

• Our simple goal is that “we are here to help each other”.