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Hightower Clinical Mock Audit

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Here's a bit of a wrap up from the 3 day audit.

Ultimately, in the opinion of the auditor, nothing rose to the level of 483 but this was a very messy and chaotic study. We definitely learned we need to stop, take a breath, and think about any changes in documentation that we make - especially those that are at the direction of a CRA. We did have some newer CRCs working on this particular study so it's difficult to know when to challenge and CRA and it takes a certain level of confidence to do that. That takes time and experience. I, personally, should have been more diligent in helping support my CRCs throughout such a difficult trial (easier said than done.)

Ultimately, it is clearly important we take more specific and concise progress notes so every change that is made can be easily tied back to something. We had too many instances in which we changed something that was right the first time but didn't note why we changed it and then it was difficult to determine after the fact.

We had a couple of very "messy" patients who were implanted and then unable to randomize and then needed revisions which created a lot of confusion in terms of visit windows and the timing of visits so we learned we needed to do a better job of accurately and concisely documenting the chain of events as they happened.

All in all, the moral of the story is we strive to ensure each binder could be reviewed by a third-party and they could make sense of the complete patient journey without having to ask questions. Each binder should be closed loop, so to speak. It was actually a great experience and the lessons we learned were very valuable.

I'll eventually write a more coherent article about this so sorry for the stream of consciousness for anyone who was kind enough to read along.

Hightower Clinical / Note to File Podcast / Existential Dilettante / "Specialization is for insects"
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Quote from Guest on July 13, 2022, 7:22 pm

1) Have you been audited before? If so, what would you do the same/differently based on that previous audit?

 

2) What is the general approach when FDA is at your site? I’ve heard mixed things… depending on the auditor you get it can be a good experience or completely terrible 
- In my estimation when the FDA is on-site it doesn’t seem to be a collaborative exchange (never having been through an FDA audit myself)

I've been through several FDA audits. Each auditor has their own style and things they like to focus on. Being nice to them actually makes a difference. If the host (or even the PI) is rude or argumentative, it's not going to make things go smoother or faster at all. 

Have a quiet and dedicated space for the auditors. Don't keep them in a busy area like the break room, or a spot where they have unlimited access to other studies' data (like an archival room). 

If the study being audited is 5 years old, refresh everyone's memory of the study and any notable issues or SAEs that occurred. 

Don't try to comb through the documents right before the audit to have explanations ready, and definitely don't make any changes to the documents. Instead, gather any CAPAs or process improvements that have occurred since the study. If a 483 is issued, the PI can reference that information in their response. 

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Hi - Would you happen to recommend any vendors who provide mock audit and inspection services for clinical sites? 
Any information, would be greatly appreciated!

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Brad, 

Thank you for posting this! I have shared this with my team as a training mechanism. I like to tell my staff to "tell the story and the visits are the chapters in the book". I also tell them to "close the loop". 

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Quote from Guest on July 22, 2022, 3:10 pm

Brad, 

Thank you for posting this! I have shared this with my team as a training mechanism. I like to tell my staff to "tell the story and the visits are the chapters in the book". I also tell them to "close the loop". 

Glad it can help someone.

Hightower Clinical / Note to File Podcast / Existential Dilettante / "Specialization is for insects"
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