Use Risk Assessments on Trial Monitoring Decisions: FDA
FDA has added information in a revised guidance about remote monitoring of clinical trials conducted during the Covid emergency and whether onsite monitoring should audit the remote monitoring once Covid restrictions are lifted. The re-monitoring discussion is contained in the appendix and the just-revised guidance entitled Conduct of Clinical Trials of Medical Products During the Covid-19 Public Health Emergency.
The document notes that FDA regulations require sponsors to monitor the conduct and progress of their clinical investigations, but they are not specific about how sponsors must conduct such monitoring, which means there are many approaches that may vary depending on multiple factors. “The decision as to whether remote monitoring conducted for a given site or clinical investigation was adequate or should be followed up with additional on-site monitoring visits should be based on the sponsor’s ongoing risk assessment,” the guidance says. “The sponsor may determine that on-site follow-up of remote monitoring activities is appropriate based on a risk assessment (e.g., sites with certain data anomalies or a higher frequency of errors, important protocol violations, or dropouts relative to other sites). As with on-site monitoring, remote monitoring should be focused on critical data and processes for human subject protection and trial integrity, such as the site’s conduct of key study procedures and documentation related to important efficacy endpoints and safety assessments.”