December 2004
Human Subjects

IUPUI/Clarian SOPs for Data Management and Security of Research Data Available for Public Comment; Previous SOP Release Comment Period Closes on Dec 22
The comment period on the following SOPs closes on December 22, 2004:

Collection, Storage, and/or Use of Biological Specimens for Research
Conflict of Interest Reporting to the IRB
Handling Humanitarian Use Devices
Handling Serious and/or Continuing Noncompliance with Human Subjects Regulations
Handling Unanticipated Problems Involving Risks to Subjects and Protocol Deviations and Violations
Involving Minors (Children) in Research
Involving Pregnant Women, Human Fetuses, Neonates, and Fetal Tissue Transplantation in Research
Involving Prisoners in Research
Safety/Risk Assessment and Oversight Plan for Research Involving Human Subjects

As reported in the SOP Communication #1, (http://www.iupui.edu~res-poly/human-sop/communication-1.htm)/, IUPUI/Clarian developed Standard Operating Procedures (SOPs) governing the policies and procedures for all human subjects research being conducted by researchers whose work is subject to review and approval by the IUPUI/Clarian Institutional Review Boards (IRBs).These SOPs will become the minimum required standards for conducting human subjects research and will be the framework against which all applications are evaluated and audited by the IRBs.

The SOPs roll out plan calls for the SOPs to be released to the IUPUI/Clarian research community via this Web site. For a limited time, the SOPs will be open to the IUPUI/Clarian research community for review and comment. All comments must be received prior to the close of the comment date posted in the SOPs Table of Contents. Approved revisions to a SOP will be made in a timely manner and displayed on this Web site (http://www.iupui.edu/~respoly/human-sop/human-sop-menu.htm). Only comments that are appropriate, constructive and objective will be considered. Due to resource limitations, we can only accept comments transmitted electronically to the Research Compliance Administration mailbox at resrisk@iupui.edu. Comments received by other media (e.g., by telephone, fax, mail and to other e-mail addresses) will not be considered.
Clarification Regarding Compliance Training for Researchers
HIPAA Security Training
The IUSM Office of Compliance Services is offering HIPAA Security Training on DVD which will be available to all of the Departments in January. The DVD only references the HIPAA Security Regulation, IUPUI, and IUSM policies; it does not include FDA 21 CFR Part 11 regulation. You will need to check with your Department to determine if they will accept the HIPAA Security training on the DVD as meeting their obligations under the HIPAA Security Rule. The Office of Compliance Services is also offering General HIPAA Security Training (these sessions do not include FDA 21 CFR Part 11) in March, 2005.

Attendance at prior sessions has been unexpectedly overwhelming and therefore, in order to attend any one of these sessions listed below, registration is required at least 5 days before the date of the session you wish to attend. We cannot guarantee that the session you wish to attend will be open when you email or call. If we cannot accommodate your session choice, we will contact you directly.

Registration Information for HIPAA Security Only
Registration will be limited at each session.
You will need to register by contacting the IUSM Office of Compliance Services
via email at: wecomply@indiana.edu or
by phone at: 278-4893.

Please include in your email or phone message your full name, the spelling of your last name (if leaving a message by phone), department, division, campus phone number, campus email address and the date and time of the session you wish to attend. Because this email and phone number is used to register other training, it is very important that you state the name of the training session for which you are registering. Those who show up at any of these sessions but did not register at least 5 days before the date of the session will only be permitted in the training session if there are extra seats available. The HIPAA Security Training sessions are listed below. Again, these sessions do not include FDA 21 CFR Part 11.

March 2, 2005 (Wed), 12:00 – 1:00 p.m., ROC Auditorium
March 8, 2005 (Tue), 1:00 – 2:00 p.m., ROC Auditorium
March 10, 2005 (Thu), 4:00 – 5:00 p.m., ROC Auditorium
March 22, 2005 (Tue), 3:00 – 4:00 p.m., ROC Auditorium
March 24, 2005 (Thu), 10:00 – 11:00 a.m., ROC Auditorium
March 30, 2005 (Wed), 11:00 – 12:00 noon, ROC Auditorium

Attendance Forms and Tracking for HIPAA Security Training
The IUSM Office of Compliance Services only provides access to training for HIPAA Security. A copy of the attendance form obtained during a face to face training session conducted by a member of the IUSM Office of Compliance Services staff must be provided to your supervisor or Department or division HIPAA Liaison. It is the responsibility of each Department to assure their staff attends the Security Training prior to April 20, 2005. The IUSM Office of Compliance Services does not track training. Please contact the HIPAA Security Liaison in your Department for more information.

Combined HIPAA Security/21 CFR Part 11 Training
Unlike HIPAA Security Training, there is no federal mandate to attend training for 21 CFR Part 11. However, if you conduct FDA regulated research it is highly recommended that you attend. Again both the IUSM Office of Compliance Services and the IUPUI Research & Sponsored Programs Compliance Office do not require this training. This decision is left to your Department or division. There is one scheduled training session that includes both HIPAA Security and 21 CFR Part 11. Other training sessions that include both of these topics are being scheduled.

Attendance at prior sessions has been unexpectedly overwhelming and therefore, in order to attend any one of these sessions listed below, registration is required at least 5 days before the date of the session you wish to attend. We cannot guarantee that the session you wish to attend will be open when you email or call. If we cannot accommodate your session choice, we will contact you directly.

Registration Information for HIPAA Security/21 CFR Part 11
Registration will be limited at each session.
You will need to register by contacting the IUSM Office of Compliance Services
via email at: wecomply@indiana.edu or
by phone at: 278-4893.


Please include in your email or phone message your full name, the spelling of your last name (if leaving a message by phone), department, division, campus phone number, campus email address and the date and time of the session you wish to attend. Because this email and phone number is used to register other training, it is very important that you state the name of the training session for which you are registering i.e., HIPAA Security/21 CFR Part 11. Those who show up at any of these sessions but did not register at least 5 days before the date of the session will only be permitted in the training session if there are extra seats available. The HIPAA Security Training sessions are listed below.

January 11, 2004 (Tue), 5:00 – 6:00p.m., ROC Auditorium

Additional training sessions for this combined training is being scheduled for February but could not be announced at this time pending room confirmations.

Attendance Forms and Tracking for HIPAA Security Training/CFR Part 11 training
The IUSM Office of Compliance Services only provides access to the combined training for HIPAA Security/CFR Part 11 training. A copy of the attendance form obtained during a face to face training session conducted by a member of the IUSM Office of Compliance Services staff must be provided to your supervisor or Department or division HIPAA Liaison. It is the responsibility of each Department to assure their staff attends the Security Training prior to April 20, 2005. Again 21 CFR Part 11 training is not required but recommended. The combined training is provided to those interested in attending both. The IUSM Office of Compliance Services does not track training. Please contact your supervisor in your Department for more information on their training requirements.

OHRP Guidance Results in Revised Follow-up Consent for Subject Withdrawing from a Study
In a recent meeting, the IRB Executive Committee reviewed the standard statement “In the event that you withdraw from the study, we request you allow us to continue to follow your health and continue to collect clinical data from your medical records,” as stated in National Cancer Institute (NCI) informed consent template. A concern was identified that this statement does not allow subjects to completely withdraw from the study since information collection would continue after the subject’s participation was terminated. The Office for Human Research Protections (OHRP) was queried for their input regarding this practice.

OHRP’s response noted that regulations require that subjects be permitted to withdraw from a study at any time, without penalty or loss of benefits. The above-referenced standard statement, calls for continued participation, without the option to fully withdraw, as a condition to participate in the study. OHRP and the IRB Executive Committee agreed that it would be appropriate to give subjects the option to consent or refuse to allow the investigator to continue to follow their health and collect clinical data from their medical records. As a result, the IRB now requires that in studies intending to continue to follow subjects’ health and collect clinical data from their medical records, investigators develop a separate informed consent or an addendum to the main consent to allow subjects to “opt-in” or “opt-out” of continuing data collection at the time they withdraw from the study. The committee recognized that there may be studies where it is necessary to continue to follow subjects even after their withdrawal for safety reasons (e.g., FDA may require such follow-up to learn about newly developing toxicities related to a study drug).

Appropriate revisions will be made to the IUPUI/Clarian informed consent template (included in the IRB Instruction Packet) to comply with the new policy. Ongoing studies will be evaluated at the time of continuing review to determine the appropriateness of this requirement.
What's New

Christmas 2004/New Year 2005 Holiday Closing Information for Research and Graduate Education
Additional holiday closing information is provided for the following Research and Sponsored Programs offices:

Research Compliance Administration (IRB/IBC)
If there is a life-threatening emergency which necessitates the use of an investigational agent, please call University Hospital Pharmacy at 317.274.0362.

Sponsored Program Administration
Proposals with a postmark or receipt date between December 23, 2004 and January 3, 2005 must be received by R&SP no later than noon on December 20, 2004. Proposals will not be processed during the holiday period.

The staff of R&SP wishes everyone a happy, peaceful, and safe Holiday Season!
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E-mail: sfwalden@iupui.edu

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