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CCOP, MBCCOP & Research Base Principal Investigator and Administrator Meeting Breakout Session: Drug Distribution. Mimi Passarello, M.B.A. NSABP, Pittsburgh, PA. NSABP Trials – Resources for Protocol-Specific Drug Accountability. Protocol* Protocol-Related Documents Fact Sheet*
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CCOP, MBCCOP & Research BasePrincipal Investigator and Administrator MeetingBreakout Session: Drug Distribution Mimi Passarello, M.B.A. NSABP, Pittsburgh, PA
NSABP Trials – Resources for Protocol-Specific Drug Accountability • Protocol* • Protocol-Related Documents • Fact Sheet* • Nurse/CRA Guidelines
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
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
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)
NSABP Pharmacy/Drug Accountability Audit ResultsJune 1, 2006 – May 31, 2007
“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
“Lesser” Drug Accountability Issues NSABP sees on Audit: • “Write-overs”, changes not initialed • Math errors corrected during audit • Late return of drug • Blanks, incomplete headings
Some NSABP Protocols allow shipment to patient(double blind, tamoxifen) • Oral agents, stable at room temperature • Patients on long-term treatment • Intensive, frequent on-site follow-up not required • Patient-specific labeling on bottles • Controlled ordering through NSABP Biostatistical Center
Newer Issues • Double blind studies only – patient returns of IND agents are recorded on log • Master logs highly recommended by NSABP for double blind studies
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
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)