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The Research Subject Advocate (RSA) Program
These
guidelines were developed to assist you in preparing a DSMP, and which can be
incorporated into the Human Subjects section of your protocol in a narrative
form.
There
are several steps to a DSMP plan, which include the following:
Step
1 – Brief
Description of the Study: May
use protocol abstract
Step
2 - Risk Assessment:
Estimate risk level (low, medium, high) and briefly discuss risk consideration relevant to your protocol. For help in determining your protocols risk level click here.
·
Risk assessment should involve not only
issues relating to potential risks and toxicities of study interventions, but
also other risks, including risks associated with
vulnerable populations (e.g., children, patients with dementia, UTMB employees),
personal health information, privacy/confidentiality issues, problematic or
difficult informed consent issues, and research in socially or politically
sensitive areas (e.g., research involving minority populations, gene therapy
research).
·
Other factors that might be considered in
a risk assessment include: risk inherent in the study population or the
number/frequency of clinically adverse events in the absence of study
interventions (as, for example, in a very medically ill study population), risks
associated with the study interventions, previous experience with the study
intervention, previous experience of the study PI, anticipated difficulties in
meeting study goals
(e.g., recruitment difficulties, drop outs from the study, noncompliance
with the study protocol).
·
Specify the name
and contact information of the individual responsible for monitoring the safety
environment of the participants (i.e. PI only, or additional monitoring by a
Medical Monitor, Safety Officer, Independent Committee, or DSMB).
·
Specify what you will monitor (i.e. subject
eligibility, adherence to treatment plan, documentation of dropouts,
evaluation of primary and secondary endpoints, adverse events, and/or problems
with informed consent).
·
If a DSMB is required, describe the composition of
the board, what role the board will play, and the frequency of meetings.
Confirm that the PI, IRB, RSA, and other appropriate entities will
receive all reports of DSMB meetings and other aggregate data analyses that may
be indicated in evaluating subject safety.
For
additional information on Data Safety Monitoring Boards
click here
Step
4 – Plan for
Data Management:
·
Indicate who is responsible for collection and
storage of data, where it will be stored. (i.e. Lab notebook, CRF, database) and
any security measures needed to properly protect data from inadvertent loss or
inappropriate use.
·
Include a description of how often interim data
will be reviewed and by whom.
·
Specify any conditions that would necessitate
early termination of the study (i.e. some clinical trails require documentation
of stopping rules that might be used if the participants are found to be exposed
to excessive risks in relation to anticipated benefits).
·
Indicate
who will perform aggregate analysis of data and adverse events, if applicable
Step
5 – Plan for
Adverse Event Reporting:
·
Indicate the
name and contact information of the individual responsible for monitoring and
reporting the occurrence of adverse events throughout the study, whether they
are anticipated, unanticipated, or serious, and the frequency of monitoring
(annual, 6 months, other).
·
Describe the
anticipated adverse events listed in the Consent Form for this protocol.
State your plan for how these will be reported and to whom (i.e. IRB,
FDA, NIH).
·
Identify the
scale that will be used to grade the severity attribution of adverse events.
to use the GCRC Adverse Event Scale or
the Common Toxicity Criteria (CTC) scale available at:
http://ctep.cancer.gov/. or another
scale of your choice.
·
Indicate
that you will follow the UTMB IRB Adverse Event Policy on mandatory reporting of
Serious Adverse Events (SAEs), and also report them immediately both orally and
in writing to the GCRC Program Director or RSA within 24 hours of occurrence or
recognition.
·
For additional information on Adverse Events,
Scales and Policies click here
Step 6 –
Protection of Human Research
Participants-Computer Based Training:
·
Specify that
all key research personnel have completed the NIH required training course:
"Protection of Human Research Participants".
· To complete this training: UTMB Online Training
Page updated: 01/28/05