a seamless research compliance program for small health care … · 2012-04-26 · a seamless...
TRANSCRIPT
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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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Center for Childhood Deafness
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Youth From 36 States and 5 Countries
Have Been Admitted to the Boys Town Behavioral Health Services
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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
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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.
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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.
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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
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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
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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”.