US Food and Drug Administration Clinical Investigator Inspections

OBJECTIVE

To review the US Food and Drug Administration (FDA) Bioresearch Monitoring clinical investigator inspection process from start to final classification to support clinical research nurses in practice.

DATA SOURCES

Published articles, websites, and author's expertise with FDA inspections.

CONCLUSION

Clinical research nurses should conduct and manage every clinical trial as if it were to be inspected by the FDA. This recommendation is considered best practice for clinical research nurses to prevent last-minute preparations to organize and clean up research data and records retrospectively.

IMPLICATIONS FOR NURSING PRACTICE

This article will assist the oncology research nurse and interdisciplinary research members at the research site in the preparedness for an FDA inspection.

Intra- and inter-investigator reliabilities of oral moisture measured using an oral moisture-checking device

BACKGROUND

Oral mucosal moisture determined using oral moisture-checking devices is used as a mouth dryness evaluation method. Such devices are capable of evaluating the state of mouth dryness in a simple manner and have applicability in a wide range of subjects; however, their intra- and inter-investigator reliabilities have not yet been clarified.

OBJECTIVE

This study aims to investigate the intra- and inter-investigator reliabilities of measuring oral moisture using an oral moisture-checking device for a wide range of age groups.

METHODS

Intra- and inter-investigator reliabilities were investigated in 28 young subjects and 19 older subjects aged ≥65 years. Three trained investigators independently measured oral mucosal moisture values using an oral moisture-checking device. Intra-investigator reliability was assessed using the coefficient of variation (CV) and intraclass correlation coefficient (ICC) (1.1), and inter-investigator reliability was assessed using ICC (2.1).

RESULTS

Mean CV was 0.015 and 0.016, mean ICC (1.1) was 0.806 and 0.877, and ICC (2.1) was 0.873 and 0.829 in the young and older subjects, respectively.

CONCLUSION

In young subjects, the mean values of ICC (1.1) and ICC (2.1) of the oral moisture-checking device were 0.806 and 0.873, respectively, whereas in older subjects, these values were 0.877 and 0.829, respectively. Thus, this confirms that the examination of oral mucosal moisture using the oral moisture-checking device has sufficient intra- and inter-investigator reliabilities for a wide range of age groups.

Research Misconduct in FDA-Regulated Clinical Trials: A Cross-sectional Analysis of Warning Letters and Disqualification Proceedings

BACKGROUND

The US Food and Drug Administration (FDA) ensures that clinical trials meet regulatory and ethical standards through inspections of researchers, also known as clinical investigators. Inspections with significant regulatory/ethical violations may result in regulatory actions, such as a warning letter or a Notice of Initiation of Disqualification Proceedings and Opportunity to Explain (NIDPOE). Objectives included the standardization of regulatory violation themes cited by the FDA for novel analysis of published regulatory actions rate issued by study intervention type, violation theme by intervention type, and violation theme variation between regulatory action type.

METHODS

Cross-sectional analysis of regulatory actions from October 1, 2006, to September 30, 2015, for inspections of researchers. For each FDA regulatory action, the main measure was the Code of Federal Regulations cited coded into a violation theme. Data were paired with FDA's published researcher inspection metrics to perform fiscal year analysis.

RESULTS

The FDA conducted 6375 domestic inspections of researchers in 2007 to 2015: 360 had significant regulatory violations, and 194 received published regulatory actions. Since 2007, rates of significant deviations have decreased. Medical device researchers had higher rates of warning letter issuance than did biologic product researchers. In contrast, medical device researchers had lower rates of NIDPOE issuance as compared to rates of biologic or pharmaceutical researchers. Lack of researcher supervision and submission of false information were cited more frequently for NIDPOEs.

CONCLUSIONS

Researcher compliance has significantly improved as evidenced by medical device researchers having the lowest rate of the most significant noncompliance. Disqualification is more likely to occur when researchers fail to supervise the trial or false information is submitted.

Baseline Assessment of a Global Clinical Investigator Landscape Poised for Structural Change

Mergers and acquisitions, the convergence of clinical research into clinical practice, more effective site selection and management practices, and efforts to improve investigator competence and credentials are all expected to contribute to consolidation in the global investigative site landscape during the coming 3 to 5 years. Tufts CSDD conducted an analysis of the FDA's Bioresearch Monitoring Information System (BMIS) to gather baseline data with which to monitor this anticipated structural change. More than half-a-million records were analyzed on clinical investigators who have filed at least 1 form 1572 with the FDA annually between 2008 and 2015. The results show that the global landscape of unique FDA-regulated principal investigators remains highly fragmented, nascent, and unstable. Principal investigators who file the lowest volume of 1572 forms each year make up the highest proportion of the global landscape, and one-third of all principal investigators each year are first-time filers. Each year, 40% of principal investigators drop out of the clinical research enterprise. However, there are signs that the landscape is beginning to scale and mature, particularly among investigators in North America. In addition, the rate of globalization is slowing and shifting, where recent growth in the number of active principal investigators in Europe has outpaced that in North America and in the rest of world. The implications of this study and future areas of research are discussed.

A European approach to clinical investigator training

A better education and training of clinical investigators and their teams is one of the factors that could foster the development of clinical research in Europe, a key objective of the Innovative Medicines Initiative (IMI). PharmaTrain (an IMI programme on training in medicines development), and European Clinical Research Infrastructures Network (ECRIN) have joined forces to address this issue. An advisory group composed of representatives of universities, pharmaceutical companies and other organisations met four times between June 2011 and July 2012. This resulted in a position paper proposing a strategy to improve and harmonize clinical investigator training in Europe, and including a detailed syllabus and list of learning outcomes. Major recommendations are the establishment of minimal and mutually recognized certification requirement for investigators throughout the EU and the creation of a European platform to provide a suitable course and examination infrastructure.

The value of formal clinical research training in initiating a career as a clinical investigator

The aim of this study was to determine whether formal clinical research training is of value in the initiation of a successful career as a clinical investigator. We conducted a retrospective review of the career choices of all 25 fellows who entered the Academic Clinical Research Track at Brigham and Women's Hospital since its inception in 1995 and examined the impact of formal clinical research training during their fellowship on their career choice. The primary measure of a successful career as a clinical investigator was the obtainment of external funding for clinical research within 3 years of completion of fellowship. Thirteen of the 25 fellows (52%) received a Master of Public Health (MPH) degree at the Harvard School of Public Health during their fellowship. Ten of these 13 fellows (77%) obtained external funding for clinical research within 3 years of completion of their fellowship. None of the 5 fellows who had already obtained an MPH degree prior to their fellowship and none of the 7 fellows who completed a 7-week summer Program in Clinical Effectiveness but did not complete an MPH degree attempted to receive external funding for clinical research within 3 years of completion of their fellowship. We conclude that formal clinical research training culminating in an MPH degree was extremely valuable in the initiation of a successful career as a clinical investigator.