On June 11, 2015, the International Conference on Harmonization released the draft update of Good Clinical Practice guidelines. The addenda feature important changes affecting investigator oversight, document processes, monitoring plans, and validation (the changes will not be final until November of 2016). Each of these pulls the tide towards further electronic management of clinical trials.
With R2, investigator oversight responsibilities are increasing.
R2 explicitly makes it the responsibility of the investigator to ensure any changes to source documents are noted and signed with reason for changes. Of note, R2 also requires the sponsor to provide site access to all essential documents before, during, and after the trial. Clearly there will be more focus on clinical trial document management for both the site and sponsor.
A certain transition to digital source
Importantly, R2 makes direct comments on e-source. It supports certified copies with the statement that certified copies of source can be created through the use of dated signatures or validated processes to produce exact copies as the original. This allows for source documents outside of the trial site EHR workflow to be created and maintained in an electronic format.
Standard operating procedures (SOPs) give PIs control
The transition to new processes is truly under the control of PIs and their management of SOPs. We’re glad that R2 provides guidance here, not only for migration to e-source but also regarding software selection. Specifically: “
What’s it all mean?
The ICH guidance provides sites with freedom to perform more tasks with electronic source, but also mandates reasonable GCP practices for the transition. Without the help of software, PI oversight requirements will increase as a result of this guidance, but if the investigator has a capable source management platform they will be neutral at worst. Now is the time to move beyond three ring binders, scanners, and faxes as the tools of choice for source management and embrace software that can help.