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1. CCOP, MBCCOP & Research BasePrincipal Investigator and Administrator MeetingBreakout Session: Drug Distribution Mimi Passarello, M.B.A.
NSABP, Pittsburgh, PA
5. NSABP Trials – Resources for Protocol-Specific Drug Accountability Protocol*
Protocol-Related Documents
Fact Sheet*
Nurse/CRA Guidelines
6. What Auditors Review Drug Accountability Record Form (DARF)
DARFs (or NCI-approved logs) are present for all investigational agents
Logs are completely and correctly filled out
Separate form for each agent / protocol / dosage form / dosage strength
Logs for all satellites
7. What Auditors Review (con’t) Storage and Stability
Balance on the DARF matches the physical inventory and/or discrepancies are accounted for
All study drugs are stored securely in a separate, limited-access area (at appropriate temperatures)
Expired drugs are disposed of or returned
Unused drug on closed studies has been transferred properly to open protocols or has been returned
8. What Auditors Review (con’t) Tracking and Disposition
Shipping receipts, transfer forms and drug return forms for each drug are on file
Destruction records are on file
Able to follow drug from shipment to patient (including dates)
9. NSABP Pharmacy/Drug Accountability Audit ResultsJune 1, 2006 – May 31, 2007
10. “Major” Drug Accountability IssuesNSABP Sees on Audit Use of commercial agent when agent is supplied
Patient / insurance charged in error
Cost to site
Do not replace commercial agent with investigational
Shipping of agents between sites
NCI logs not in use for PMB-supplied agents and/or use specified in protocol; particularly problematic for double-blind trials
No log for small offices
12. Some NSABP Protocols allow shipment to patient(double blind, tamoxifen)
13. Newer Issues
14. Avoiding Problems Conduct periodic audits of pharmacies
Communication with pharmacist regarding study-specific information
Read protocol and protocol-related documents
Avoid re-writing messy drug logs
15. Audit Program
CTMB Guidelines Presentation and Audit Deficiencies, provided by the Clinical
Trials Monitoring Branch 3/07
CTMB Audit Deficiency Examples
Guidelines for Monitoring of Clinical Trials for Cooperative
Groups (PowerPoint)
Site Visit Audit News (01/11/2007)
Audit Program Description (07/17/2007)
Examples of Audit Deficiencies (06/19/2007)
Sample of Notification Letter (Treatment) (07/17/2007)
Sample of Notification Letter (Prevention) (07/17/2007)
Sample of Final Report (Treatment)
Sample of Final Report (Prevention)