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OBJECTIVE 4: PROTOCOL-SPECIFIC SITE REGISTRATION
Steps to achieving protocol-specific site registration:

(1) Identify protocol(s)
(2) Check protocol(s) for specific requirements
(3) Obtain local IRB approval
(4) Register site

A site must receive IRB approval prior to screening, consenting, and enrolling a patient into a protocol. The Federal regulations that address Institutional Review Boards (IRBs) are available in the Resources section of the CTSU Registered Members Website. Compliance with these regulations is intended to protect the rights and welfare of patients involved in research studies.

Section topics include:

Local IRB Approval
Initial Site Registration
Site Registration Review and Notification Process
Assurance
IRB Renewal of Protocol
Protocol Amendments
Module Objectives
1
Summarize CTSU pre-registration information for Cooperative Group members
2
Initiate CTEP-AMS registration of Cooperative Group members
3
Explain the expansion of membership to investigators not Affiliated with a Cooperative Group (CTSU Independent Clinical Research Sites- CICRS)
4
Identify the protocol-specific registration process and regulatory requirements that enable a site to participate in a clinical trial through the CTSU
5
Define the sequential steps in the patient registration process
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Local IRB Approval

Local IRB approval is required on three occasions:

(1) Upon registering a site for a new protocol
(2)
Renewal at intervals appropriate to the degree of risk, but not less than annually
(3)
When protocol amendments are initiated

To learn more about IRB issues, click here.

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Initial Site Registration

The site will submit protocol-specific site registration documents to the CTSU Central Regulatory Office as soon as the local IRB has approved participation in the protocol and before patients are screened, consented, or registered onto the protocol. Regulatory processing is completed within approximately 3 business days. Institutions wishing to verify that regulatory materials have been received and processed should access the RSS tab on the CTSU Registered Member Web Site and select the Site Registration Status link. Sites that cannot confirm receipt of regulatory documents after 3 business days should contact the CTSU Help Desk at 1 (888) 823-5923. NOTE: Sites requiring "time of need" enrollments should contact the CTSU Help Desk at the time the regulatory packet is submitted to expedite the review process.

The required site registration documents are available on the protocol page of the CTSU Registered Member Web Site. The following documents are required for site registration:

IRB/Regulatory Approval Transmittal Form

This form is used as a checklist to ensure that the required documents are submitted.

The CTSU IRB Certification Form, or IRB Approval Letter, or the Protection of Human Subjects Assurance Identification/IRB Certification/Declaration of Exemption (formerly HHS 310) form, or a combination of the CTSU IRB Certification Form and IRB memo or Declaration form, as long as one is signed by the IRB signatory
CTSU IRB Protocol Certification Form is preferred; other forms are accepted.
Other Materials
As directed in the protocol.

The CTSU assists with the time-consuming IRB submission process by providing protocol-specific IRB submission templates that are available for each protocol on the CTSU menu. This template is a tool that provides answers to questions most frequently asked by the IRB in the protocol review process. Staff can "cut and paste" from this document to the specific forms required by the local IRB. The template is called the IRB Submission Application Template, and it can be found in the Site Registration documents on the protocol-specific page of the CTSU Registered Member Web Site.

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Site Registration Review and Notification Process
Mail site registration materials to the CTSU Central Regulatory Office.
The CTSU Central Regulatory Office reviews the materials for completeness. The site will NOT be notified of approval, but instead should check the status of the approval by using the RSS Registration Status page on the CTSU members' web site. The RSS will be updated within 72 hours after receipt of the regulatory materials at the CTSU.
If documentation is incomplete, the CTSU Central Regulatory Office notifies the site to obtain the needed information.
Sites are expected to retain documentation of all protocol approvals in the site regulatory files.
It is recommended that a Regulatory Binder be set up at the time a site submits its protocol-specific site registration materials.
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Assurance

The Code of Federal Regulations for the protection of human subjects (45 CFR 46.103 (a)) requires that each institution engaged in federally-supported human subject research file an assurance of protection for human subjects.

Assurance formalizes the institution's commitment to protect human subjects. The requirement to file an assurance includes both awardee and collaborating performance site institutions. Each site needs to have an IRB assurance number, which is awarded by the Office of Human Research Protections (OHRP), to cover Principal Investigator(s) and his/her/their site before the PI or site may conduct any clinical trials. Before filing for an assurance number, check with your IRB to see if your institution already has one.

One of Three Project Assurance Numbers
Can Be Used for the CTSU
Multiple Project Assurance (MPA)
Cooperative Project Assurance (CPA)
Federal-wide Assurance (FWA)

For more information, visit the OHRP Website, http://www.hhs.gov/ohrp.

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IRB Renewal of Protocol

The site's local IRB must renew approval of a protocol and the informed consent form at intervals appropriate to the degree of risk, but not less than annually. The date of original review, rather than the dates of amendment submission, determines the scheduled date of the annual review. In general, continuing review for treatment protocols open to accrual is expected to be a full board IRB approval, but CTSU recognizes that federal policy allows for use of expedited review in limited circumstances. Institutions submitting expedited continuing review for protocols open to accrual must submit justification for the expedited approval in accordance with 45CFR46.110.a-c. The CTSU IRB Certification Form in box 10 and 21 lists the appropriate review categories that can be used for justification of expedited continuing review.

Sites may access the RSS tab of the CTSU Registered Member Web Site and select Site IRB Expiration Status to review the status of pending reviews for their institution. This resource tool requires the site to enter its CTEP institution code to begin the search process. Other parameters, such as protocol and date range, can be entered. This tool shows only protocols within at least 90 days of their scheduled continuing review date.

A copy of the CTSU IRB Certification Form, IRB Approval Letter, or Protection of Human Subjects Assurance Identification/IRB Certification/Declaration of Exemption must be sent to the CTSU Regulatory Coordinator following IRB renewal on all protocols open to accrual and protocols closed to accrual as indicated by the sponsoring Group. If the CTSU IRB Protocol Certification Form is used, more than one protocol may be included on the same form if the information in lines #1-14 is identical for all the protocols. Sites are expected to retain documentation of all protocol approvals, renewals, and revisions in the Regulatory Binder.

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Protocol Amendments

An amendment is a change to an approved clinical protocol that can be initiated only by the sponsoring Cooperative Group. An amendment may address changes related to patient safety, parameters, the scope of the study, or new scientific findings. It may include minor administrative changes, such as changes in personnel or spelling errors. The NCI requires Cooperative Groups to implement use of a "version date" to commonly identify protocol version changes. This date is noted on the front cover of the protocol. Other versioning notation such as the terms "revision" and "amendment" and all number schemes are specific to the Cooperative Group.

When a Cooperative Group issues an amendment, revision, or update, notification is sent to all CTSU members via the bimonthly broadcast email. Protocol changes that have an immediate impact on patient safety are promptly communicated via a separate broadcast email. The CTSU follows the instructions given by the Cooperative Group sponsoring the protocol to determine how quickly notification of amendments is given to sites (immediate or bimonthly broadcast email).

Proposed changes in a research activity during the period for which IRB approval has already been given may not be initiated without IRB review and approval, except when necessary to safeguard patients from immediate hazards. If the original protocol is amended, the site must forward the amendment and supporting documentation to the local IRB for review. If the amendment necessitates a change in the consent, the revised consent accompanies the IRB submission documents. It is critical that the site submit protocol amendments to the IRB within the timeframe requested by the sponsoring Cooperative Group.

The NCI/CTEP Clinical Trials Monitoring Branch (CTMB) guidelines state that an amendment should be submitted immediately to the IRB and an approval obtained within 60 to 90 days. It is critical that the site submit protocol amendments to the IRB within the established guidelines outlined by NCI of 60 to 90 days. The Cooperative Group leading the trial may require that proof of IRB approval be submitted to the CTSU Central Regulatory Office within a specified timeframe (generally 90 days) to continue patient enrollment privileges. Sites are responsible for following the guidance provided by the Cooperative Group leading the trial.

The text of a protocol amendment often includes recommendations from the sponsoring Cooperative Group as to the type of IRB review and approval that is needed. If the amendment specifies whether expedited or full board review is most appropriate, the CTSU site should take this into consideration when presenting the amendment to their local IRB. The immediate email and the bimonthly broadcast email that notifies the site of the amendment will also provide information about the required type of IRB review (Full Review or Expedited Review). On occasion, the lead Group will require that the site provide proof of IRB approval within a specified timeframe to continue enrollment of patients. CTSU will communicate to the sites any specific instructions for submitting proof of IRB approval of an amendment.

Once the local IRB has approved the amendment, consent form, and any other related documents, the documentation of IRB approval and the IRB-approved materials must be kept in the site's regulatory files for verification at the time of audit. In some cases, the CTSU requires proof of IRB approval and a copy of the new IRB-approved materials (e.g., informed consent form) before patient enrollment can continue. The CTSU will follow the instructions given by the Cooperative Group sponsoring the protocol to determine when the additional materials are needed. The amended protocol documents will be available from the CTSU Registered Member Web Site.

Click to learn more about protocol amendments.

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