| Literature DB >> 34192053 |
Barry S Coller1, John B Buse2, Robert P Kimberly3, William G Powderly4, Martin S Zand5.
Abstract
The 2020 COVID-19 pandemic has had a profound impact on the clinical research enterprises at the 60 Clinical and Translational Science Award (CTSA) Hubs throughout the nation. There was simultaneously a need to expand research to obtain crucial data about disease prognosis and therapy and enormous limitations on conducting research as localities and institutions limited travel and person-to-person contact. These imperatives resulted in major changes in the way research was conducted, including expediting Institutional Review Board review, shifting to remote interactions with participants, centralizing decision-making in prioritizing research protocols, establishing biobanks, adopting novel informatics platforms, and distributing study drugs in unconventional ways. National CTSA Steering Committee meetings provided an opportunity to share best practices and develop the idea of capturing the CTSA program experiences in a series of papers. Here we bring together the recommendations from those papers in a list of specific actions that research sites can take to strengthen operations and prepare for similar future public health emergencies. Most importantly, creative innovations developed in response to the COVID-19 pandemic deserve serious consideration for adoption as new standards, thus converting the painful trauma of the pandemic into "post-traumatic growth" that makes the clinical research enterprise stronger, more resilient, and more effective. © The Association for Clinical and Translational Science 2021.Entities:
Keywords: COVID-19; CTSA; clinical research; pandemic; translational research
Year: 2021 PMID: 34192053 PMCID: PMC8137226 DOI: 10.1017/cts.2021.10
Source DB: PubMed Journal: J Clin Transl Sci ISSN: 2059-8661
Fig. 1.CTSAs and COVID-19. Major elements of the translational research enterprise at Clinical and Translational Award (CTSA) hubs and nationally related to the COVID-19 pandemic. FDA, US Food and Drug Administration; IRB, Institutional Review Board; N3C, National COVID Cohort Collaborative.
Things to do now and a Checklist for a future similar public health emergency
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Institutional Administration Create policies to align health system, hospital, university, and medical school senior administrations, along with legal departments, Institutional Review Boards (IRBs), and technology transfer departments, to expedite decision-making related to clinical and research operations in the event of a major sustained public health emergency. Create Advisory Boards and Develop Charters and Policies Clinical Research Prioritization Advisory Board. Establish criteria for prioritization of research studies, including those related to the pandemic and those unrelated to the pandemic. For studies related to the pandemic, these may include, for example, institutional priorities; resource Intensity; patient availability; staff capacity; minimization of duplication of studies; clinical equipoise; consent; statistical power to be informative; and adequate funding. For studies unrelated to the pandemic, criteria may include whether it involves a life-threatening disease, whether participants already enrolled need continuing access to otherwise unavailable drugs or other treatments, whether the studies are time-limited by virtue of a sponsor’s requirements, and whether the studies are crucial for the career development of trainees who have time-limited appointments. Biorepository Scientific Advisory Board. 1) Establish principles related to organization (centralized, federated, and/or decentralized); potential modifications for consent (patient, legal representative if incapacitated, next of kin for autopsy); availability of translated consent documents; potential proactive sample collection priorities even if there is no current protocol (e.g., health care workers, pediatric samples, convalescent patients); potential specimen types and volume; processing standards; facilities; linkage to clinical data and informatics support; tracking and storage; retrieval; and distribution. 2) Communicate with and engage all stakeholders to minimize individual investigator resistance in the future. 3) Develop a broad consent document to encompass all potential uses of samples. Biorepository Governance Advisory Board. Establish principles of operations: biosafety, including availability and access to BSL2+ and BSL3 facilities; personnel training; regulatory and legal aspects; data sharing; sample sharing (academic investigators, government investigators, industry). Institutional Safety Board. Assess on regular basis the latest information on safety risks to patients, health care workers, supporting staff, students, and others, and develop and modify policies and procedures to maximize protections accordingly. Charge the Board with making quantitative recommendations at timely intervals for stockpiling of personal protective equipment (PPE) and identifying restocking supply lines, including expectations for the need for redundancy in suppliers. If institution needs to shut down, use Institutional Safety Board as core for a Reopening Committee. Research Support Board. Create a Pilot Project Program and review proposals and disperse funds rapidly. Integrate efforts with Technology Transfer Department to ensure that all intellectual property protection and licensing opportunities are maximized. Individual Departments and Units Communications Department Develop plan for communicating with staff, faculty, students, house staff, and institutional supporters through a variety of different media, including town hall meeting (in person or virtual), email, messaging, and social media, Design websites related to clinical activities, research activities, community engagement information, and others. Plan for communication with public-facing media, including radio, television, and social media about the essential role well-designed clinical studies play in selecting the safest and most effective preventive and therapeutic interventions. Community Engagement and Health Disparities Programs Strengthen bidirectional partnerships with community organizations and community leaders. Strengthen and support community health workers by providing resources, training, access to technology, and ability to gain access to medical care for patients in referral centers. Develop strategy, policies, and procedures for measuring relative impact of public health emergencies in neighboring populations at high risk by virtue of poverty, population density, racism, occupations (especially health care workers and other essential personnel), environmental air pollution, and other relevant factors. Develop language-appropriate translations of all important communications. Ensure that electronic health records (EHR) include sufficiently granular race and ethnicity data to assess disproportionate impact of disease on specific groups. Develop a proactive plan with community leaders to provide a steady stream of accurate medical information and dispel misinformation in the community. Develop a proactive plan with community, government, and industry partners to diminish the “digital divide” by supporting programs to make internet access and computers broadly available to individuals for health care information. Maximize the communication value of patient portals for transmitting health information. Plan with local public health agencies to bring needed services directly into the community, including diagnostic testing and long-term follow-up. Development Department. Prepare a draft of a campaign for philanthropic support of basic and clinical research for rapid implementation. Human Resources Department. Develop a plan to address need for increased support of essential personnel with pre-school and school-age children. Develop a plan for potential redeployment of personnel and craft cross-training experiences to expedite redeployment if necessary. Review policies for sick leave if need to quarantine. Consider developing “Work from Anywhere” policies for rapidly hiring individuals with required skills, such as informatics. Information Technology (IT) Department Strengthen informatics platforms to ensure security, privacy, and technical capability to support rapid expansion of virtual operations, including tele-medicine, institutional operations, educational activities, and both basic and clinical research, including eConsent and documentation of eConsent. Develop customized dashboards for different Clinical and Translational Award (CTSA) hub leaders and institutional leaders based on data required to manage pandemic preparedness and pandemic operations. Participate in the N3C data enclave that links the EHRs on individuals diagnosed with COVID-19 from multiple sites so that investigators can search the records to answer key questions about the diagnosis, prognosis, and treatment of the disorder. Partner with state and local public health departments, health exchanges, claims databases (CMS Medicare and Medicaid) to integrate informatics platforms to address public health issues such as vaccination records. Assess needs for data reporting to regional and national agencies. Work with clinical teams and institutional leadership to align as best as possible the information clinicians require for patient management and research (clinical decision support with predictive tools, cohort identification, grant submissions, response to new experimental therapies) and institutional leaders require for global planning (intensive care unit [ICU] beds, ventilators, PPE) versus the data collected by current systems. Adjust as necessary to better align the needed and collected data. Work with legal department to speed implementation of data use agreements and memoranda of understanding. Review cybersecurity protections in the face of urgent requests for data sharing. Legal Department Prepare to expedite contracting for clinical trials with industry by exploring master agreements that can be rapidly implemented. Review legal aspects related to security and HIPAA with rapid expansion of virtual operations. Research Pharmacy Stockpile pharmacy-specific PPE and identify potential alternative suppliers if encounter a shortage. Develop policies for emergent, expedited processes for developing drug profiles and computerized physician order entry screens for novel experimental drugs and repurposed drugs. Ensure availability to dispense drugs 24/7/365 for studies requiring rapid drug initiation. Assess current capacity for formulating novel experimental agents and assess potential value and cost of expanding capabilities. Assess relationships with network pharmacists and whether to expand relationships in anticipation of future needs for drug distribution in an emergency. Develop policies for delivering experimental drugs to participants in research studies under emergency conditions, e.g., home delivery by hand or mail/messenger or curb-side or valet pick-up from site or collaborating network pharmacy. Assess most likely medications to be in short supply as a result of a major public health emergency (e.g., medications used in ICUs) and consider stockpiling, identification of alternative suppliers, and creation of teams to modify and restrict utilization of drugs in short supply. For novel potentially life-saving medications in short supply, develop policies with clinicians and bioethicists on criteria for fairest method to decide on distribution (e.g., drug lottery). Work with community engagement groups on combating misinformation related to evidence of drug safety and efficacy. Sponsored Projects Department. Develop a plan to systematically scan on a daily basis funding opportunities from government (federal, state, local), foundations, individual philanthropy, and industry. Create a communication plan to disseminate funding information. Plan for expansion of a cadre of sponsored research personnel to facilitate timely grant proposal submissions. Technology Transfer Department Prepare to expedite Material Transfer Agreements (MTAs) for investigators at other institutions who may want access to Biorepository samples and for institutional investigators who may want access to samples at other institutions by developing master MTAs with institutions most likely to want or provide such samples. Monitor Pilot Research Projects related to the public health emergency for potential intellectual property and licensing opportunities. Human Research Protection Plan and IRB Review policies and procedures, and if necessary, add sections describing actions to be taken in response to a public health emergency: a. Criteria for differentiating Public Health Surveillance projects from Human Subjects Research; b. Temporary expansion of IRB capacity by adding personnel, reassigning and prioritizing reviews among existing IRBs, and/or creating a new IRB to address protocols related to the emergency; c. Developing and updating a roster of past IRB members and IRB staff who may be willing to volunteer to return to active duty to help address the need for rapid review of protocols; d. Triage of protocols based on their need for rapid review; e. Analysis of impact of single IRB review requirements on review mechanism, with potential to petition for exemption when supported by specific circumstances; f. Potential modification of general principle of limiting participation to a single experimental protocol. g. Impact of family members not being allowed to visit patients in hospital on informed consent process. h. Proactive assistance to inexperienced investigators in developing protocols requiring IRB review. i. Importance of insuring equitable and appropriate recruitment of research participants from groups disproportionately affected by the emergency through availability of translation of consent documents and community outreach measures. j. Ethical considerations guiding initiation and continuation of randomized clinical trials in the face of rapidly emerging clinical information. Integrate IRB efforts to speed review with efforts by Clinical Research Prioritization Advisory Board and others charged with expediting contracting, insurance coverage, budget negotiations, IND submissions, clinicaltrials.gov registration, obtaining and dispensing medications, and the creation of order sets in the EHR. Monitor the contributions of all of these activities to expediting the time from protocol development to first recruited participant. Consider instituting a Protocol Implementation Checklist to encourage an integrated approach and track relative contributions of each element to the process. Review policies and procedures related to informed consent: a. Acceptable platforms for communicating with participants and legal authorized representatives. b. Acceptable methods beyond signatures on paper informed consent forms for documenting agreement to participate in research. c. Accommodations when infection control does not allow collection of signed paper informed consent forms. d. The relative roles of translations of informed consent documents versus use of interpreters when there are time pressures to start studies and insure representative recruitment into studies. e. Studies involving off-label drugs vs single patient protocols. f. Need for (re-)consenting participants as they regain capacity when the initial consent was provided by a legally authorized representative. g. Provision of information related to consent by means other than in-person discussion between investigator or designee and research participant, such as videos. h. Review of research participants’ experiences with the unusual consent processes during the pandemic. i. Creation of patient and/or community advisory body to review benefits, disadvantages, and burdens of alternative consent processes employed during the pandemic. j. Assessment of the impact of different informed consent processes on equitable and appropriate recruitment, focusing on the potential contribution of the digital divide and cultural variations in trust in different processes. Clinical and Translational Science Award (CTSA) Hub (Institutional Translational Center or Institute)
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BSL, biosafety level; CMS, Centers for Medicare & Medicaid Services; CFR, Code of Feral Regulations; IND, Investigational New Drug; IDE, Investigational Device Exemption.