How are studies chosen for Post Approval Monitoring (PAM)?
Any study under the purview of the University of Virginia HSR-IRB or HSR-SBS is subject to review. Studies are chosen:
- At random or per other requests or indications (i.e. per Cancer Center requirements or other request)
- Has an active approval status
- Has a full board or expedited review
Studies may be reviewed for:
- research where compliance concerns have been raised based upon information provided in continuing review reports, adverse events or other sources;
- research approval expires due to failure by the investigator to submit continuation status report and PI is requesting the study to be re-opened;
- research where paperwork submitted to the IRB was felt to be inadequate;
- studies monitored by the Cancer Center DSMC under their institutional Data Safety Plan;
- protocols with junior investigators or inexperienced team members who may benefit from post-approval monitoring assessment and education;
- for any change in PI after initial study approval and study remains open to enrollment
Who is notified that a protocol has been chosen?
A letter is sent via email to the principal investigator, and if applicable to:
- Study coordinator
- IRB coordinator
- Department contact
What will happen during the PAM visit?
The post approval monitor will meet briefly with the PI/study coordinator to become familiar with the study set-up and files. The post approval monitor will review all of the study materials and documentation. A final report of the findings will be written after the audit.
What materials will be reviewed?
The following documents are reviewed during the audit:
- Correspondence with the IRB
- Correspondence with any other institutional oversight committees, such as GCRC, PRC, etc. (if applicable)
- Regulatory documents and correspondence with the Federal authorities and/or sponsor (if applicable)
- Original copies of the signed and dated consent forms for each subject or a sample of subjects
- Written documentation of the consent process for each subject
- Subject study records and any source documents (e.g., hospital and clinic charts; x-rays, scans, and other special studies required by protocol; and operative, pathology and radiotherapy reports)
- Adherence to protocol
- Serious and/or Unexpected Adverse Event documentation and copies of required reports to the IRB, and to the federal authorities (if applicable)
- Drug receipt, storage, labeling, and dispensing log (if applicable)
- Research records (e.g., screening log, subject enrollment log, exclusion log and case report forms)
- Lab certification, normal laboratory values, and staff training or certification documentation (as applicable)
- Data entered for analysis (if applicable)
How long will the PAM visit take?
The amount of time needed for an audit varies greatly. Generally, the post approval monitor would like to meet with the PI for about 15-30 minutes either before, during or after the review of the study documents. The time needed to review the study documents depends on the amount of material and the number of subjects.
What happens after the monitoring visit?
When the audit is complete, the post approval monitor will:
- Meet with the PI/study coordinator if necessary to discuss the findings
- Write a report of the findings
- Send a copy of the report to the PI, the IRB and study coordinator, the School of Medicine Clinical Trials Educator and the IRB.
What types of actions could result from the review?
There are several actions that could result from a PAM review. They include:
- No follow up needed
- The School of Medicine Clinical Trials Office Educator to follow-up with minor issues
- The IRB to follow up with major issues
What if I will be out of town or working on a grant within the few weeks after I receive a PAM notification?
That is o.k. Please inform the post approval monitor of your situation and a date in the future can be arranged for the visit. For most of the PAMs, there is no specific deadline.