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Misconduct in Clinical Research – Room for Improvement

Misconduct in Clinical Research – Room for Improvement

IMARC Research believes history provides important examples of clinical research misconduct  that have helped establish a foundation for understanding the principles that guide modern clinical research.  If you visit our offices, you will see artwork that is featured in our history of clinical research timeline hanging on our walls that depict critical events in history that have helped shape and improve modern clinical research for the well-being of human subjects.

Why Unique Device Indicators are Crucial for Device Surveillance

Why Unique Device Indicators are Crucial for Device Surveillance

The FDA’s Sentinel Initiative, mandated by Congress two years ago to include and cover medical devices, aims to electronically track the safety of investigational products after they have reached post-market. Recently, however, John Rising of The Pew Charitable Trusts informed a congressional subcommittee that lack of unique device identifiers on insurance claims forms poses a major road block to ensuring the effectiveness of this initiative.

The Delegation Log - A Clue Provider?

The Delegation Log   A Clue Provider

The terms Essential Documents, Investigator Binder or Study Binder are sometimes used interchangeably. For all clinical research trials involving human subjects, there must be a file maintained by the Sponsor and the Investigator containing all the necessary paper work to support the clinical trial and could be called any of the above-mentioned names. During an onsite review of study records by an IMARC monitor, essential documents are reviewed to ensure that they are present, accurate, complete and current by following the ALCOA checklist and as specified in the FDA regulation 21 CFR 812.140.

A Medical Device Clinical Auditor’s Favorite Regulation: 21 CR 812.100

A Medical Device Clinical Auditor%27s Favorite Regulations

I am often asked by industry colleagues that if I had to pick just one “favorite” federal regulation what would it be?  The answer is easily 21 CFR 812.100, as this regulation embodies 95% of the investigational site non-compliances  I observe as I conduct clinical investigator audits. Let me elaborate.

CEC and DSMB: What’s the Difference?

CEC and DSMB   What’s the Difference

Medical device sponsors, according to 21 CFR 812.40 and 812.46, are responsible for monitoring clinical trials.  The regulations require that sponsors monitor a trial at a site by ensuring that an investigator is compliant with the federal regulations, agreements with the sponsor, the investigational plan, and the requirements set forth in the approval of the study by the IRB.  It is also the responsibility of the sponsor, according to 21 CFR 812.43(d) to select monitors qualified by training and experience to monitor a study in accordance with 812 and other applicable FDA regulations. Sponsors may also appoint other individuals and groups to ensure compliance and proper clinical trial monitoring as well as evaluate the accumulating outcome data. The FDA guidance, The Establishment and Operation of Clinical Trial Data Monitoring Committees for Clinical Trial Sponsors, defines a Data Monitoring Committee (DMC), also knows as  Data Safety Monitoring Boards (DSMBs) or Data and Safety Monitoring Committees (DSMCs), as a group of individuals with pertinent expertise that reviews, on a regular basis, data from one or more ongoing clinical trials. Additionally, DMCs:

3 Costly Traps on the Road to Device Innovation

3 Costly Traps on the Road to Device Innovation

No matter the therapeutic area, device companies agree: Creating cutting-edge products is expensive. From the R&D costs to the pricy FDA fees, the expense for innovation adds up quickly. As products become more technologically advanced, the cost for designing new devices has increased. At the same time, device companies are being hit with fees that are wiping out their R&D budgets, such as the 2.3% medical device tax, which reportedly requires companies to collectively pay an estimated $194 million per month.

More Innovative Med Tech

More Innovative Med Tech

According to an August 22nd article in FierceMedicalDevices the FDA has picked up the pace on the most novel medical devices, but this year might not match levels seen in 2011 and 2012.  To highlight this point, the article points out the agency granted 17 premarket approvals, which is a marked increase over the 23 granted for the entirety of 2013.

Cell Therapy: The Fourth Pillar of HealthCare

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As the cell therapy market continues to grow, it’s important to note the similarities between medical device and cell therapy clinical trials. To help illustrate this, we’ve created an infographic, “Cell Therapy: The Fourth Pillar of Healthcare,” which is available for download.

“If it is not documented, it was not done”

Documentation in Clinical Research

In clinical research this phrase is used to emphasize the importance of complete and accurate documentation to site staff.  Still, every year we see that FDA issues multiple warning letters which cite, “You failed to maintain adequate and accurate records.”

1937 – Elixir Sulfanilamide

Elixir Sulfanilamide Disaster

You may be familiar with IMARC Research’s History of Clinical Research (HCR). We recently released an eBook about it that briefly describes all of the images that currently make up the timeline. If you have visited our office, you may have also been given a guided tour of one of our most renowned resources. Due to the overwhelmingly positive feedback we have received, we will be highlighting each time point with a series of blogs that we plan to release over the course of the 2014 calendar year.

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