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Page 1: 20 Ways to Improve Your IRB and Consent Content Audit
Page 2: 20 Ways to Improve Your IRB and Consent Content Audit

IRB

Page 3: 20 Ways to Improve Your IRB and Consent Content Audit

Keep IRB information for each protocol in a separate

folder or separate by dividersAll IRB approvals for treatment and stand alone companions will need to be providedEmbedded companions are not applicable

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Print out individual protocol webpage for each study audited

Account for all updates, memos, broadcast SAEs, Action Letters, etc. listed on the protocol webpagePrint out most recent CALGB Audit Update List from

CALGB website

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Verify full board (FB) approval performed before any patient was registered to study

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Verify annual renewals or continuing reviews are performed <365 days since initial approval or last renewalReviews provided for all open studies and all closed

studies with patients that are still in follow-up status

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All updates that are bolded on the CALGB Audit Update List will be checked at audit time for IRB approvalUpdates requiring IRB Approval must be approved within 90 days of distribution

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All Action Letters distributed must be submitted and acknowledged by the IRB within 90 days of distribution

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All broadcast SAEs must be submitted to the IRB within 90 days of distribution

ORProvide institutional policy/procedure/SOP for handling/processing broadcast SAEs (submission to Central Office for approval must be done prior to audit)

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The local IRB should be notified of local adverse events according to local institutional policyFollow protocol guidelines in the designated section of

the CALGB protocol titled “Adverse Event Reporting (AER)”

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It is highly suggested that all studies on audit list be pre-audited prior to the official auditRule of thumb: Audit all open studies on a monthly basis, if possible, and note all missing itemsInternal audits enable you to catch omissions and still

make the 90 day time period

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Assign one staff person familiar with the IRB files to sit with the auditor to aid in the review of the IRB

portion of the audit

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Keep a positive perspectiveIf error is found, admit your mistake and communicate

the corrective action plan your institution has implemented to avoid or prevent future errors

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Consent Content

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Maintain same format with the local institutional consent form that is utilized by the NCI approved CALGB model consent formAdd specific institutional information as required by the

local IRB

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The risk or side effect section of the local institutional consent form should match the CALGB model

consent form with exact wording, if possibleOne risk omitted results in a MAJOR deficiency

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The patient consent forms must have all blanks (patient/participant initials and/or signature, IRB contact person and phone number, MD name and phone number, etc.) completed or filled in before the patient signs the consent form and before the patient is registered to the study

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Please provide the original consent form signed by the patient/participant

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Patient/participant should date their own signature or initials

Research staff should not insert date the patient/participant signed the consent form

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The options/alternatives or other choices of treatment or no treatment section of the local consent must be identical to the CALGB model consent form

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Obtain the consent content checklist from the CALGB webpage under Resources titled “CALGB Audit Information”

Verify all elements are included in your local institutional consent form

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Provide most recently IRB approved local consent form that incorporates all consent form changes mandated by CALGB updatesPatient/participant consent form will be utilized to verify

correct version was signed prior to registration

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New OHRP Regulations distributed by NCI for CTEP/OHRP/FDA applies to new or modified risk information added to CALGB consent formsCALGB Central Office will communicate the exact IRB

procedure specific to each update

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Questions/Concerns

Contact:Barbara Barrett

CALGB Audit Program Manager

Susan Tuttle

Vice Chair of CALGB Audit Committee


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