National Institutes of Health, Department of Defense, and Industry - Post Award
- Study Begins
- Screening Potential Study Participants
- Schedule & Conduct Study Visits
Conduct the Study
|1.||Obtain Notice of Award, fully executed inbound subcontract, or fully executed contract.
Office of Research Administration (ORA) provides copy of award letter or fully executed contract to Principal Investigator (PI) and Department highlighting key terms and conditions.
For NIH awards, the PI can check eRA Commons directly.
NOTE: Department of Defense (DoD) requires the completion of the post submission activity (required award information and documents) in eBRAP System before receiving the contract.
|2.||PI/delegated study staff review award terms and conditions and protocol to ensure appropriate management and oversight. PI/appropriate departmental support must communicate with the Office of Research Administration (ORA) Post Award to ensure compliance with terms and conditions. Confirm who, what, when, and how (including recruitment strategies), and discuss discrepancies between protocol text and schedule of events.|
|3.||PI and study staff complete applicable required training (e.g., Collaborative Institutional Training Initiative (CITI), Conflict Of Interest (COI)*, VELOS, HIPAA training, new PI training**, Cerner training*** (Jackson electronic medical records), UChart training****, etc.). If the project is a clinical trial, the PI and study staff must complete the CITI GCP training.
PI and study staff complete required interest disclosure process in the UDisclose System
Carefully read the HSRO Investigator Manual. Become familiar with all Human Subjects – related policies and Standard Operating Procedures at the University.
*For questions about COI and the UDisclose System, contact the UDisclose System helpline at (305) 243-0877.
**For new PI training, contact Clinical Research Operations and Regulatory Support (CRORS).
***For Web-Based Training, contact MiracleTraining@JHSMiami.org; for JHS Cerner credentials/JHS Security Request form CERNER Access, contact CSC@JHSMiami.org.
****For UChart training, click here.
|4.||Submit protocol to Institutional Review Board (IRB) via eProst, if not previously submitted.
Use the appropriate UM template protocol and consent document.
NOTE: ORA will put a hold on any new account until they receive the protocol IRB approval letter. A hold on the account means no salary allocations are allowed and ORA usually will not input a budget in WorkDay.
NOTE: Additional requirements for DoD: refer to HRP-318 and HSRO Investigator Manual (Chapter 13).
NOTE: If you will be accessing a potential subject’s electronic medical record for screening purposes, you must request a waiver of HIPAA authorization by completing the checkboxes in the UM Template Protocol.
NOTE: Ensure that JHS has been selected as a site at time of IRB submission to view study documentation. If unable to view, the JHS review process cannot be initiated.
|5.||Submit protocol modifications to IRB, if protocol or staff have been changed since being awarded.
Obtain all ancillary approvals prior to starting the study (i.e., JHS, UHT)
|6.||Ensure that the UDisclose System is completed for all study personnel, and Financial Conflict of Interest (COI) clearance obtained from the Office of Disclosure and Relationship Management (DRM).
NOTE: To check project compliance for all personnel, log into the UDisclose System → go to “COI” tab → select “Triggering Events” →search for most recent New or Competing Renewal InfoEd number.
|7.||Once conflict of interest (COI) clears, a new/existing award and related grant are issued/extended. ORA notifies PI and Department of the award and grant ID’s upon receipt of award/contract.
NOTE: If your project anticipates subcontracting to external entities, the subcontracting process should begin immediately utilizing the Outbound Subaward / Jackson Work Order Request Form. Outbound Subcontract Process Flow can be found here. If your project anticipates a JHS Work Order under the Master Clinical Research Agreement, the process should begin immediately utilizing the Outbound Subaward / Jackson Work Order Request Form. The Jackson Work Order process can be found here.
Once the award and grant ID’s are established/extended, a petty cash account can be initiated (e.g., for participant payments). Workday is used to initiate all orders of study supplies and request of petty cash.
|9.||Create Regulatory Binder/Site Master File (may be provided by sponsor). For information on required study documentation, Standard Operating Procedures (SOPs), master file, etc. contact the Clinical Research Operations and Regulatory Support (CRORS), and visit International Conference on Harmonisation.
Note: Study correspondence may be stored in the regulatory binder or in a separate binder
|10.||For studies that are not FDA regulated, create Case Report Forms (CRF), data collection forms (if not provided by sponsor), and database.
If your study is FDA regulated, and the Sponsor has not provided you with CRFs, please contact VELOS for assistance. VELOS email: firstname.lastname@example.org.
Research Electronic Data Capture (REDCap) is an application that allows users to build and manage CRFs and databases quickly and securely. Please note that REDCap cannot be used to maintain data for studies under FDA jurisdiction as it is not compliant with 21 CFR Part 11 requirements.
The BioStatistics Collaboration and Consulting Core (BCCC) can assist in the development of study databases.
NOTE: Investigator-sponsored Investigational New Drug (IND) or Investigational Device Exemption (IDE) must use Velos (Part 11 compliant) for all data management. To use or purchase another data management system for use in FDA-regulated studies, contact RCQA or Research IT for an FDA Part 11 evaluation of the system
|11.||Create Study Participants binders.|
|12.||Create training binder to store all training documentation (e.g., certificates of completion, etc.)
Note: study-specific training will be stored in regulatory binder
|13.||Create tracking system (paper, electronic) for each required study visit/assessment.|
|14.||Engage all third party facilities (e.g., clinical research units, comprehensive treatment unit, pharmacy, radiology, hospital wards, Jackson Health System, Clinical Teams etc.).|
|15.||Engage Clinical Research Operations and Regulatory Support (CRORS) for monitoring or regulatory support, as applicable.|
|16.||Confirm that all study supplies are available, and in sufficient quantities. Note expiration dates.|
|17.||Confirm that laboratory facilities and arrangements for dispatching samples to lab(s) are organized, and that any special equipment that may be required will be available throughout the period of the study (e.g., centrifuge, freezer, etc.)
Ensure chain of custody documents are created for investigational products and samples.
Note: Confirm that all study lab facilities maintain and document temperature monitoring and maintenance/service reports.
|18.||Conduct and document the Site Initiation Visit or protocol in-service (whether federally or industry-funded). The PI, Study Staff, research pharmacist, all personnel who will be a part of the clinical research study will attend, including third party facilities.
NOTE: Your study may also require study–specific training for clinical departments where study procedures will take place (e.g., echo lab, cath lab, radiology, etc.).
|19.||Ensure all Institutional Review Board (IRB) and institutional specific approvals have been obtained (e.g., Jackson Health System, Veterans Affairs, University of Miami Hospital, etc.).
NOTE: Additional requirements for DoD: Submit Human Research Protocol Submission Form to DoD Human Research Protection Office (HRPO) after UM IRB approval. Confirm approval (~3 months).
NEVER START STUDY ACTIVITIES WITHOUT IRB APPROVAL AND EXECUTED CONTRACT/AWARDED GRANT.
|20.||Create a Protocol Registration and Results System (PRS) account to register study with ClinicalTrials.gov.
For clinical trial disclosure information, contact Research Compliance & Quality Assurance (RCQA) office.
|21.||Confirm the study has been registered in Velos by the PI or delegated study staff upon IRB submission/approval.|
|22.||Enter NCT Number (ClinicalTrials.gov Identifier) in Velos.|
|23.||If using Velos, enter the information required for listing your study in the Clinical Trial Search Tool (CTST) (e.g., keywords, therapeutic areas, and NCT #, etc.).|
|24.||THE STUDY MAY BEGIN ONLY AFTER ALL THE STEPS ABOVE ARE COMPLETED. AN APPROVAL LETTER FROM JHS MUST BE OBTAINED BEFORE STARTING THE STUDY.|
|25.||Perform pre-screening, if applicable. If accessing the electronic medical records for pre-screening, obtain a waiver of authorization (HIPAA) from the Institutional Review Board (IRB) by completing the appropriate sections in the UM template protocol.
Requests for datasets should be submitted to the Data Broker Group via the Clinical Data Request Form using the ServiceNow Self-Service Portal or email to email@example.com.
|26.||Conduct Informed Consent Process and obtain signed HIPAA Authorization if you will create, obtain or access protected health information for research purposes. (Ensure the blanks and boxes on the HIPAA authorization are marked correctly before asking a subject to sign an authorization.)|
|27.||Provide a copy of the signed and dated Informed Consent Form (ICF) and a copy of the signed and dated HIPAA authorization to the participant.|
|28.||Document the Research Enrollment/Research Encounter*:
|29.||Send signed copies of HIPAA Authorization to Office of HIPAA Privacy & Security. Submit Attachment 45 when accessing the EMR with a waiver of authorization or under an exception to the requirements for an authorization using a FORM D or E.|
|30.||Perform screening visit(s) as per protocol, and assign study participant ID.|
|31.||IMPORTANT: The following section might need to be revised in 2020 as UM is working on an alternative to adding the consent document to the EMR to avoid violating Certificates of Confidentiality.
Send signed and dated copies of ICF to the following offices/sites, as applicable.
|32.||Schedule study visits. Use applicable system to schedule research appointments:|
|33.||Submit required study procedures forms to third parties facilities as applicable (e.g., physician treatment orders, lab requisition form, etc.).|
|34.||Perform study visit AS PER PROTOCOL.|
|35.||Complete Case Report Form/data collection form, and/or obtain documentation associated with study visits.|
|36.||Enter Collected Data.
For Investigator-initiated Investigational New Drug (IND) or Investigational Device Exemption (IDE) studies: You must Velos for all data management. For any other data management system, contact RCQA or Research IT for an FDA Part 11 validation of the system.
(e.g., Velos, RedCap, Excel, Access, SASS, SPSS, Web-based database).
|37.||Submit modifications (amendments), reportable new information (RNI), continuing reports, unanticipated problems (UPs), etc. to Institutional Review Board (IRB), via ePROST as outlined in the HSRO Investigator Manual
NOTE: If the modifications affect the study budget, contact the appropriate department support. PI/delegated study staff notifies Office of Administration (ORA) PreAward and JHS (if involved) of any modification. PI/appropriate departmental support initiates Proposal/Contract Routing Form-L (PCRF-L) , or Proposal/Contract Routing Form-S (PCRF-S) based upon Decision Matrix, and submits to Office of Research Administration (ORA) via firstname.lastname@example.org. All forms are available here.
|38.||Verify and update ClinicalTrials.gov records annually during the actively recruiting stage (if applicable).|
|39.||Report deviations and adverse events to IRB, and sponsor, as outlined in the HSRO Investigator Manual , sponsor protocol, and applicable regulations.
Report any JHS related adverse events to the JHS Office of Research and all drug/device related events through JHS Quantros system as per hospital policy. Quantros Reporting System
Issue participant’s payments/reimbursements on an ongoing basis and ensure that a W9 Form has been completed for all payments.
|40.||When the study participants have completed their involvement in the study, dis-enroll them in Velos within 2 business days of withdrawal or completion of in-person visits, by changing the participant status to “Off-Study”. This ensures that patients are no longer flagged in UChart as research participants. If JHS subjects are involved, send the Patient enrolment form updating the information for the participant as “Off-Study” within 48 hrs.|
|41.||Monitor the study (Quality Control).
Studies may be monitored by external or internal monitors (Office of Clinical Research Operations and Regulatory Support – CRORS).
|42.||Report all external audit requests/notifications:
|43.||The Department of Defense (DoD) requires quarterly and annual technical progress reports. NIH requires annual technical progress reports. Financial reports will be concurrently submitted by ORA.|
|44.||Ensure that all study visits are completed.|
|45.||Ensure that all regulatory documentation is current, complete and filed correctly in the site master file/regulatory binder.|
|46.||Ensure that all subject files are complete (data collection forms, labs, notes to file, etc.).|
|47.||Ensure that all data queries have been resolved, and copies filed in the research binders.|
|48.||Ensure that a plan is in place to appropriately follow-up on ongoing adverse events, as per protocol requirement.|
|49.||Notify engaged ancillary departments involved in the conduct of the study (e.g., Clinical Research Translational Site, Comprehensive Treatment Unit, Pharmacy, Radiology, Jackson Health System etc.) of study closure.|
|50.||Confirm that all Investigational Product (IP) has been returned or destroyed at the site, as specified in the study protocol, and that records of the return or the destruction are filed in the regulatory binder. File copies of study packing slips, shipment receipts, and study participants in the regulatory binder.|
|51.||Ensure that all other study-related materials (e.g., unused study kits, data collection forms, etc.) are returned or destroyed, as specified in the study protocol/operations manual/sponsor instructions.|
|52.||Ensure that any equipment on loan is returned.|
|53.||Ensure that final participant’s payments have been submitted and/or distributed (if applicable), and that W9 Form has been completed.|
|54.||Verify that all study participants have been dis-enrolled in Velos, to ensure they are no longer flagged in UChart as research study participants.|
|55.||Submit a continuing review report from to the HSRO via ePROST|
|56.||Ensure that Purchase Orders (PO) are closed and that recurring expenditures will no longer be charged to the project. Also ensure that all related revenue is recognized and expenditures are charged to the project. Residual balances are subject to the terms and conditions of the award and ORA’s policies.|
|57.||Ensure the completion and submission of all Office of Research Administration (ORA) account reconciliations, as well as sponsor’s required technical financial, property, invention, etc. close-out forms (including updated financial disclosures) as appropriate.|
|58.||Confirm requirements for data retention, destruction and storage, per applicable regulations and sponsor requirements.
|59.||Confirm that all study results have been submitted to ClinicalTrials.gov (if applicable). The initial study results are required within 12 months of achieving the last primary outcome. This may be sooner than study close-out.
For assistance with ClinicalTrials.gov, contact Clinical Trial Disclosure on the RCQA website.
|60.||Per study protocol and ICF, study summary results should be disseminated to participants by the PI/delegated study staff, ideally after data interpretation has undergone peer-review.|
|61.||For questions, contact ORA Post-award at email@example.com|