Human Research Participant Protection (HRPP) Training for New Investigators and Staff

1. Human Research Participant Protection (HRPP) Training for New Investigators and Staff Syracuse VAMC HRPP Office Serving Bath, Canandaigua & Syracuse VA Medical Centers

2. Introduction • Welcome to human subject research at the Syracuse VAMC! You are taking a first step to begin health-related research that will benefit all of our Veteran patients. • This presentation is a training guide with helpful information for new investigators and staff. • HRPP documents referenced in this training as well as additional education can be found: R&D Website: http://www.visn2.va.gov/apps/visn2shared/research/syr/syrforms.cfm Syracuse Research Service SharePoint (VA Access Only):https://vaww.visn2.portal.va.gov/sites/syr/research/default.aspx Please fill out the HRPP Certificate, print, sign and date when you complete this training and submit it to the IRB Office for course credit.

3. Multiple Governing Bodies over research VA researchers and staff must follow all rules: • International rules (ICH-GCP-E6) for Good Clinical Practice (GCP), • U.S Federal regulations (Common Law, Department of Health & Human Services/DHHS), • FDA rules for foods, cosmetics, drugs and device research, • VA Central Office R&D (ORD) rules and regulations, • Local Syracuse VAMC R&D rules.

4. R&D SOP Policies & Procedures We understand there is a tremendous amount of information within VHA Handbooks and Local Policies and Procedures. Please familiarize yourself with where to look for information. R&D Website: http://www.visn2.va.gov/apps/visn2shared/research/syr/syrforms.cfm or Syracuse Research Service SharePoint (VA Access Only):https://vaww.visn2.portal.va.gov/sites/syr/research/default.aspx or Contact the HRPP Office

5. Mandatory Human Subjects Protection Training(Required Trainings) VA requires annual training for all VA researchers and their staff involved in VA-approved research. NOTE: individuals with WOC (Without Compensation) appointments are VA employees. 1) CITI and VA Human Subject Protection and Good Clinical Practice: Initial Training. You must complete the 5 required GCP modules, plusyour choice of 8 elective modules from a list of 18. Refresher Training. You must complete the 6 required GCP refresher modules, plusyour choice of 8 elective modules from a list of 32. The refresher training is required every two years after the initial training. 2) HRPP Training:This PowerPoint course is only required oncefor staff who have contact directly with patients or personally identifiable data, all committee members and scientific reviewers. • PIs will not receive final protocol approval notification until training is complete for them and any personnel listed as working on the protocol. It is the PI’s responsibility to ensure that staff working on their research protocol(s) remain compliant with required research training. 

6. New Research Protocol Submissions The current IRB Submission Forms can be found at 1) R&D Website: http://www.visn2.va.gov/apps/visn2shared/research/syr/syrforms.cfm or 2) Syracuse Research Service SharePoint (VA Access Only):https://vaww.visn2.portal.va.gov/sites/syr/research/default.aspx HINT: Use the checklist for submission to ensure you have used all of the required forms. You may not need the entire list of forms available online. The items used are dependent on the research you are planning. You will need to ensure allof the required signatures are obtained prior to submission. HRPP Staff will obtain the ACOS R&D Signatures needed on the Conflict of Interest Forms and Scope of Work Documents.

7. Saving forms for re-use may be a good time management strategy; however IRB Forms are updated regularly based on changes in regulations. You need to ensure the form you are using is the current version of the document in order to meet all regulatory requirements, otherwise unnecessary delays may occur with reviewing your protocol.

8. VA Investigator • Any individual who conducts research approved by a VA Research & Development Committee including • VA appointment on VA time • Full & part-time VA employees • Without compensation (WOC) VA employees • Appointed or detailed to VA under the Intergovernmental Personnel Act (IPA)

9. Investigator Responsibilities • Upholding professional & ethical standards & practices • Adhering to all applicable requirements for conduct of research & the protection of human subjects • VA • Other Federal requirements • Syracuse Research and Development’s Standard Operating Procedures (SOPs), • Responsibilities may be defined in the protocol or IRB application • Some of responsibilities may be delegated to an investigator working under the PI, however the PI is ultimately responsible for all study conduct

10. Investigator’s Responsibilities: Assessing Impaired Decision Making Capacity (IDMC) • Beforeproceeding with the Informed Consent Process, the Investigator, or their designee, must complete the Impaired Decision Making Capacity Form (IDMC) with potential subjects. A key factor in participants' decision making is their appreciation of how the risks, benefits, and alternatives to participation in the study apply to them personally. The investigator must retain the IDMC in the Investigator files. It is not intended for issuance to the subject or submission to the IRB. For more information, (please see R&D SOP 151-06: Impaired Decision Making Capacity (IDMC) under Policy and Procedure on the R&D website.)

11. Investigator’s Responsibilities: Performing Subject Outreach • Investigators are required to make available to the potential subjects the informational brochure, “Volunteering in Research – Here Are Some Things You Need To Know” http://www.research.va.gov/programs/pride/veterans/tri-fold.pdf • Contact the HRPP Office for color copies of this tri-fold document. • Documentation that this handout was given to subject must be included in the CPRS Research Study Initiation Note (RSIN)

12. Investigator’s Responsibilities: HIPAA • Investigators are responsible for obtaining HIPAA authorization for the use & disclosure of the subject’s Protected Health Information (PHI), or obtaining a waiver of HIPAA authorization Your approved HIPAA document will be signed by the Institutional Privacy Officer (PO). Donotuse a HIPAA document which does not include the PO signature. HRPP Administrative Staff work with the PO to obtain approval of your HIPAA documents submitted for IRB review.

13. Investigator’s Responsibilities: Informed Consent Obtaining & documenting informed consent prospectively • Investigator cannot screen, interact, or intervene with a subject until aftermeeting the IRB-approved informed consent requirements (see Consent Form Template 10-1086) • If you plan to collect picture, video, or voice recording during your Research Project or Study, please complete VA Form 10-3203 in addition to Consent Form 10-1086 • Exceptions • IRB determines the research is exempt • IRB approves a waiver of informed consent • IRB approves a waiver of documentation of informed consent form True Informed Consent encompasses BOTH the “Process” and the “Form”

14. Investigator’s Responsibilities: Informed Consent Continued… The ICF and HIPAA original documents must be placed in the subject binder and a copy: • copy to subject –PRIOR to subject leaving clinic area even if PI has not signed the document. The subject needs to have in their possession what they signed/agreed to. • copy to medical records for scanning into CPRS within oneweek(use Internal Clinical Records for Scanning Form) • copy to IRB within ONE WEEKof subject enrollment • copy to Pharmacy, if study drug involved, before study drug released to subject. Also provide copy of 10-9012 with consent to research pharmacy

15. Investigator Responsibilities: Informed Consent Continued… GO! Submit Informed Consent copies to the HRPP Office AND for CPRS scanning WITHIN ONE WEEKof enrollment. STOP!DO NOT enroll more participants than the study protocol is approved for.IRB Approval of Total Recruitment Number MUST be granted beforehand. Subjects who sign consent are considered “enrolled” even if they do not qualify for study inclusion immediately after consent. These subjects will count as part of your totalrecruitmentnumbers. CAUTION! CPRS Notes should be used for ALL participants enrolled on your study, UNLESS otherwise waived by the IRB.

16. Significant differences between DHHS, FDA, and VA ICF regulationsResearch in the VA always follows the most rigorous application of a regulation

17. Investigator Responsibilities: Reporting Deviations, Complaints, Problems, & SAEs • Reporting deviations from the protocol & subject complaints to the IRB in a time frame specified by • R&D SOP 151-17 • ORO • Reporting all unanticipated problems involving risks to subjects or others, & all unanticipated internal (i.e., local) SAEs, whether related or unrelated to the research, in accordance with local SOPs & VHA Handbook 1058.01* *See ORO website: http://www1.va.gov/oro/

18. Investigator Responsibilities: Obtaining IRB Approval for All Changes (Amendments) Obtaining IRB approval for all changes to the research prior toimplementing the changes • Amendments or modifications to the protocol • Changes to the IRB-approved informed consent form ONE EXCEPTION • Eliminating apparent immediate hazard to the subject • MUST promptly report these changes to the IRB!

19. Research Data Security • Recently there has been a number of identified issues regarding research data security • Please work with the facility Information Security Officer to obtain their approval on your data security plan (Use Data Security Checklist for PIs Form) PRIOR to IRB submission

20. Scopes of Practice for Researchers and Staff ALL STAFF MUST HAVE PI ADDENDUM (1) or SCOPE OF WORK MEMO (2) As applicable to their research role (HRPP Staff will obtain ACOS R&D signature on these documents for you) (1) SYRACUSE VAMC ADDENDUM TO CLINICAL FUNCTIONAL STATEMENT FOR PI’S All Syracuse VAMC Principal Investigators are required to have an addendum in their Clinical Functional Statements identifying research duties/activities if the research activities are in line with their approved clinical privileges. Syracuse PIs submit this Syracuse VAMCAddendum to Clinical Functional Statement in lieu of the scope of work document. (Canandaigua PIs contact Mary Adams, CAN RCO for additional scope of work guidance) (2) SCOPE OF WORK MEMOS FROM COLLABORATORS/COORDINATORS/ALL STAFF Submit one form from each: Sub-I, NP, all Coordinators and other staff involved with the conduct of the study. (Canandaigua staff contact Mary Adams, CAN RCO for additional scope of work guidance)

21. Investigator’s Responsibilities: Project Regulatory Clock • The IRB can issue approval for your research project for up to 12-months. Do NOT start research activities prior to your receipt of the IRB approval letters. • Continuing Review: • Investigators must provide the IRB sufficient time for reviewing & approving the study before the IRB approval expires. • The scheduled IRB Meeting date for continuing review is found on your IRB approval letters. This is generally the IRB meeting within 30-days prior to the project expiration. • IRB approval automatically expires if the continuing review & approval does not occur by the expiration date of the current approval. • Do NOT let your projects simply expire if you are done with them. Your research protocols must remain open with the IRB as long as you are analyzing identifiable information. Once this is complete and activities are limited to manuscript preparation you may choose to close the project. IRB approval of the final closure formally ends the IRB approval of the project. • Project Closure: Submit the IRB Project Closure Request Form for IRB approval to formally close your project. • Record Retention Requirements (See Page 22) • Communicating the results to subjects or the community from which subjects were recruited (if appropriate) • Reporting Publications to the R&D Committee (R&D Form: Acknowledging VA Research)

22. Record Retention Both the official research file and the investigator’s research records must be retained in accordance with the VHA Records Control Schedule (RCS 10-1). The official research file is a permanent record, which is maintained by VHA for 30 years after cut off of the records (cut off being the end of the fiscal year in which the study closed) and then transferred to the National Archives and Records Administration (NARA). VHA has requested that NARA schedule the retention period for the investigator’s research records and is currently pending. Therefore, all investigator records must be maintainedindefinitelyby the investigator or the service in which the investigator works until schedule by NARA. Please work with your Careline (MVAC, D&T, GEC or Service Line), the ISO and PO to develop secure storage of records in line with this VHA requirement.

23. Rules & Tools • For Investigators to remain compliant during research, find these additional documents in addition to this PowerPoint • Investigator Duties/Responsibilities List • CPRS Notes Guidance • Investigator Regulatory Binder Guidance • Investigator Guidance Proper Informed Consent • Also for your reference: • A Compliance Awareness: http://vaww.visn2.med.va.gov/network/compliance/index.cfm • Compliance Ethics Hotline — 1-888-214-9892

24. Thank you for your participation in HRPP TrainingIf you need additional guidance, please contact the HRPP Office to set up a meeting to review the forms required for submission. The HRPP Administrator will meet with you in regards to the regulatory requirements for submission. You may also request to meet with the IRB Chair if you have questions that are more in-depth regarding the research science/methodology. Human Research Participant Protection Program 800 Irving Avenue | Syracuse, NY 13210  • Paul Dougherty, DC, IRB Chair Paul.Dougherty@va.gov • Andrea L. Hahn, HRPP Program Administrator 315-425-4400 ext. 53607 Andrea.Hahn@va.gov • Colleen A. Marcely-Temple, HRPP Program Assistant 315-425-4400 ext. 53591 Colleen.Marcely-Temple@va.gov Click here for HRPP Certificate