audit program tammy neseth ncctg compliance coordinator

AUDIT PROGRAM

AUDIT PROGRAM

Tammy Neseth

NCCTG Compliance Coordinator

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AUDIT COMMITTEE MEMBERSHIP

AUDIT COMMITTEE MEMBERSHIP

• Research Base Chair: Thomas Habermann, MD

• Community Co-Chair: Philip Stella, MD

• Community-Based Practice PI's: 8

• Community-Based CRAs: 7

• Other Research Base Personnel: 7

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PURPOSEPURPOSE

• Oversee the audit process

• Review audit results to ensure compliance and communication of the NCI’s audit guidelines

• Implement policies and procedures to ensure consistency in how audits are conducted and results managed

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PURPOSEPURPOSE

• Facilitate communication and ensure that the educational element is present during on-site process

• Communicate outcomes, trends and issues to the Executive Committee of the NCCTG and influence policy

• Enhance communication with the CCOP and non-CCOP membership institutions and with the Clinical Trials Monitoring Branch (CTMB)

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DISTINGUISHING CHARACTERISTICS


• A premise that this is a key quality control and CRA development aspect of the NCCTG

• Pre-audits are performed prior to the majority of audits

• Integrated multi-group approach: NCCTG cancer treatment, Cancer Control, intergroup, ECOG, and CTSU

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• All NCCTG audits are overseen by NCCTG Compliance Coordinator

• Team approach to the chart at the audit: Physician and CRA from NCCTG Audit team along with CRA from site

• An extensive exit interview is held with the membership immediately following the audit

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• An Audit Executive Review Committee formed in October of 2002

• Thresholds: 8% for major deficiency rates or 30% overall deficiency rate

• Committee membership: Research Base Chair of the Audit Committee, the NCCTG Group Statistician, the NCCTG Statistician member of the Audit Committee and the NCCTG Compliance Coordinator

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• Institutional Evaluation and Assessment• Participation as an auditor and auditing

outcomes are included in the formal evaluation of NCCTG membership performance as of 2005

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KEY ACCOMPLISHMENTSKEY ACCOMPLISHMENTS

• Enhancements of the educational component of the NCCTG Audit Program

• All new NCCTG memberships are required to attend an orientation session which includes “ABCs of Auditing”

• Education and system based practice initiatives at the exit interviews of audits have been more emphasized

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KEY ACCOMPLISHMENTSKEY ACCOMPLISHMENTS

• A $500 supplement for sites that send new CRAs on an audit was initiated. The purpose of this is to expose new CRAs to the clinical trials process and the audit process

• The Audit Manual and the Pharmacy Manual are continually updated and were posted on the NCCTG web site in 2004

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SITE AUDIT TIPSSITE AUDIT TIPS

• Provide a room for the audit

• Confirm staff/investigator availability

• Prepare staff

• Flag charts

• Order scans/x-rays

• Be ready to start the audit when audit team arrives

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AUDIT ISSUESAUDIT ISSUES

IRB and Informed Consent Review

• Informed consent document sent to Auditor for review not the most current IRB approved form

• No organization of IRB correspondence - approval letters, AE submissions

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AUDIT ISSUESAUDIT ISSUES

Accountability of Investigational Agents and Pharmacy Operations

• Agents not stored separately

• Satellite DARFs not available

• Write-overs on the DARFs

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AUDIT ISSUESAUDIT ISSUES• Informed Consent – re-consenting

• Eligibility - physician notes

• Treatment – oral compliance

• Disease Outcome/Response – scans

• Adverse Events/Study Parameters – test schedule, toxicity assessments, dose modifications

• General Data Quality – corrections, timeliness

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QUOTE OF THE DAYQUOTE OF THE DAY

“If not documented – it didn’t happen.”

- Roxanne Tabery6/28/2005

audit program tammy neseth ncctg compliance coordinator

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