Theradex SAE Reporting
March 09, 2022Presented by Cynthia Neydon on February 18, 2022 | Audience: CRN, CRC and CRA – open to other positions | Purpose: Reviewing the Theradex SAE reporting process with an auditor.
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- 7518
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Transcript
- 00:03And.
- 00:07I it's it's 133,
- 00:08so let's go ahead and get started.
- 00:10I know it's a Friday afternoon and
- 00:12and Cynthia thank you again for
- 00:15giving us your time to review some
- 00:17of the essay reporting requirements.
- 00:19So I will hand it off to you
- 00:21and just note to anyone.
- 00:23If you have questions or
- 00:25comments or anything feel
- 00:26free to use the chat. I'll be
- 00:27checking it throughout the the
- 00:29discussion this afternoon.
- 00:33OK, well welcome everyone and.
- 00:38Again, I'm not. I'm not 100%
- 00:40exactly what you wanted to review
- 00:43in terms of adverse event reporting,
- 00:45but I will just go through a few things
- 00:48that I put together and then we can.
- 00:51You know, discuss it if you have any
- 00:53questions, I'm happy to answer any
- 00:55questions you may have and also.
- 00:57If you want me to go over the SAE reporting,
- 01:00like I said, I will be happy to pull
- 01:03that PowerPoint up and we can go
- 01:05through the new process for reporting
- 01:07SCE with the integrated studies. Uhm?
- 01:10But in general I just wanted to kind
- 01:13of go over at like the adverse events.
- 01:16So I think.
- 01:18You all probably understand all
- 01:20these definitions.
- 01:20You know,
- 01:21adverse event is really anything
- 01:23that was undesirable and unintended
- 01:26that is experienced by the patient.
- 01:28It doesn't matter if it's related
- 01:30to the study treatment,
- 01:32but it wasn't present at baseline,
- 01:33or if it was present it worsened
- 01:36or the attribution changed.
- 01:38Serious adverse events are ones that are.
- 01:42Result in one of the following
- 01:44their their death life threatening
- 01:46a hospitalization that's initial or
- 01:48prolonged and its hospitalization
- 01:49for an event.
- 01:50Not for like a an elective procedure.
- 01:53Disability or permanent damage
- 01:56congenital anomaly.
- 01:57Or birth defect in another
- 01:59serious important medical event.
- 02:00So the important medical event
- 02:02is the one where I think we get
- 02:04hung up a little bit.
- 02:05The NCI likes all Grade 3
- 02:09AE's to be assessed for,
- 02:11whether they're an important medical event.
- 02:13And that should be done by the physician,
- 02:16and that should be done in real
- 02:18time and documented in source.
- 02:21Then the CTC AE.
- 02:23The common terminology criteria for adverse
- 02:26events is how severity is determined.
- 02:28Severity is the grade of the AE,
- 02:31and that is developed that was
- 02:33developed in order to kind of have
- 02:36consistency for adverse event reporting.
- 02:38So everyone that's reports a
- 02:40grade three is using the same
- 02:43standards as the other another site.
- 02:45A specific protocol,
- 02:46exceptions to exit expedited,
- 02:48reporting the sphere which is contained
- 02:50in the caper and the protocol.
- 02:53That's a list of adverse events or events
- 02:55that are protocol specific exceptions,
- 02:58so usually those are adverse
- 03:00events that are expected,
- 03:01so they exclude those from
- 03:05being reported expeditiously.
- 03:07And then the cancer therapy evaluation
- 03:09program adverse event Reporting system,
- 03:11which is C type errors.
- 03:12That's the web based system that
- 03:15is used to electronically submit
- 03:17the expedited reports to the NCI.
- 03:21There's also two different types
- 03:22of reporting for adverse events.
- 03:24There's the routine reporting
- 03:26and the expedited reporting.
- 03:28The routine reporting is when
- 03:30you record the adverse event
- 03:31only on the adverse event CRF.
- 03:33The NCI.
- 03:34Then we'll get that information,
- 03:36and then annually they look at
- 03:38it to put in the annual report.
- 03:40The expedited reporting is when you
- 03:42submit it through seats up errors.
- 03:44That means it is a serious
- 03:45adverse event or it was required
- 03:47to be submitted by the protocol.
- 03:49And in addition to.
- 03:50Submitting that to cite pairs,
- 03:52you also need to record it on
- 03:54the adverse events Sierra.
- 03:56So the adverse PC address adverse
- 03:58events CRF will contain both the
- 04:00routine and expedited adverse events.
- 04:06Why do we monitor adverse events?
- 04:09It's for patient safety.
- 04:10We need to identify if there's
- 04:12any events happening that may
- 04:14be impacting patient safety.
- 04:16We also are able to inform the regulators
- 04:19and best to Gators people treating
- 04:21the patients on anything important
- 04:23that is learned about the medication.
- 04:25Or the treatment regimen.
- 04:27And then also it just provides
- 04:29a summary of the adverse events,
- 04:31which then is used to develop
- 04:34the regimen toxicity profile.
- 04:36If anybody has any questions as we go along,
- 04:38just please. You know,
- 04:41ask that and I'll just pause.
- 04:45For oncology trials,
- 04:46I think the reporting of adverse
- 04:49events is is challenging.
- 04:51Protocols are a little bit more complex.
- 04:52There can be multiple agents being used.
- 04:56Patients could have had prior
- 04:58therapies which will be impacting
- 04:59some of the symptoms that they have.
- 05:02They can have a lot of baseline symptoms,
- 05:03signs and symptoms,
- 05:04either based on their condition,
- 05:06prior treatment, or intercurrent illnesses,
- 05:10and they can be on a lot
- 05:11of different medications.
- 05:12So I think makes it a little
- 05:15bit more complicated to.
- 05:16So to identify adverse events and
- 05:18to determine if there are serious
- 05:20adverse event or routine adverse event.
- 05:25So when when a patient does experience
- 05:28any type of adverse event, it's very,
- 05:31very important that the principal
- 05:33investigator assesses the adverse event
- 05:35and documents it thoroughly in the source.
- 05:38The description should be provided.
- 05:41There should be the start date and if
- 05:43there isn't, if it is an SAE, I advise.
- 05:45Sites to enter the date
- 05:47that it was discovered.
- 05:50Enter that date in the source as
- 05:52well as in the seat Ipars report.
- 05:55Just so that we can determine
- 05:56if you learn of the event late
- 05:59that it was not a late reporting.
- 06:01So in addition
- 06:02to that, I have a a quick question.
- 06:04The date the site was made aware.
- 06:06Does that just go in the comment
- 06:07section in the seat up errors report?
- 06:09Or is there an actual field
- 06:11that we can document that in?
- 06:14That would just go in the narrative section?
- 06:16OK, alright, perfect. Thank
- 06:17you. It just makes it clear if anybody
- 06:20does review that report that you know
- 06:22you discovered it at a later point
- 06:24and that's why it wasn't submitted
- 06:26as quickly as the protocol required.
- 06:28OK, thank you. So in addition to the
- 06:30description of the event in the start.
- 06:32Wait, the severity which is the ctca
- 06:36you is used CTCA is used in the version
- 06:39of that will be in the protocol.
- 06:40So we previously used version four.
- 06:42We're now using version 5 and I think
- 06:44this fall version 6 may be coming out.
- 06:46So protocol will specify which version
- 06:48is to be used, seriousness whether the
- 06:52patient was hospitalized, they died.
- 06:53It was important medical event.
- 06:55Things of that nature or the
- 06:57attribution expected this work up,
- 06:58meaning what did they do to diagnose
- 07:00this issue? If it was something else?
- 07:02Had to be.
- 07:03Done like a CAT scan or something
- 07:05treatment for it.
- 07:06Action taken with study drug and then the
- 07:08stop date or when it changed in severity.
- 07:13Then a flow chart that I created.
- 07:16To kind of help with identifying whether
- 07:20you're going to and a who's going to be
- 07:24reported routinely or expedited reporting.
- 07:27So the first step would be to look
- 07:28at the adverse event, integrate it
- 07:30so that way you know if it's some.
- 07:34You know a Grade 345,
- 07:35which is typically the grades that
- 07:39are recorded doesn't mean a grade
- 07:41one and two will never be recorded,
- 07:43it just that more typically
- 07:45grade 3/4 and five star. Uhm?
- 07:49And then again, as I said,
- 07:50you need to assess whether a Grade
- 07:523A is an important medical event
- 07:54or the physician needs to do that.
- 07:57Step 2 would be to look in the
- 08:00protocol to see if there's any
- 08:02specific reporting requirements.
- 08:03Are there any adverse events
- 08:06of special interest? And.
- 08:09One protocol that I know your site is.
- 08:13Participating in is 10020.
- 08:17Uhm, let's see if I can pull
- 08:20that up real quickly.
- 08:23So.
- 08:26Fat
- 08:37let's see. That protocol has
- 08:41adverse events of special interest,
- 08:43so the first thing you want to
- 08:44do is look in the protocol and
- 08:46see does this protocol have any
- 08:47adverse events of special interests,
- 08:49and then review those?
- 08:51And if the adverse event that you're.
- 08:54Assessing is one of these adverse
- 08:56events and special interests
- 08:58say the patient had colitis.
- 09:00Then it would be reportable.
- 09:02It says here the following adverse
- 09:04events are considered special interests
- 09:05in patients receiving totalism.
- 09:07Evan must be reported expeditiously
- 09:09irrespective of regulatory
- 09:11seriousness criteria.
- 09:12So if that's the case and you see
- 09:14that it is us AE of special interest,
- 09:17then you are going to go ahead and submit it.
- 09:20You don't even have to do anything else.
- 09:23If there are no ayeza special
- 09:25interests in the protocol or the
- 09:27ER assessing is not one of them,
- 09:28then you go on to the next step.
- 09:31The next step is to really identify
- 09:33is this even an SAE doesn't meet the
- 09:36definition of a serious adverse event.
- 09:38And again, going back to the protocol.
- 09:41You can see.
- 09:45These are the definitions of
- 09:46an of a serious adverse event.
- 09:49You know there are results in death,
- 09:51like threatening. Hospitalization.
- 09:57And compared to you know
- 09:58and disability anomaly,
- 09:59important medical event.
- 10:01So does it meet that criteria?
- 10:04And if it if it.
- 10:08If it does not meet the definition
- 10:10of a serious adverse event, then no,
- 10:12you're not going to go any farther.
- 10:14You're just going to enter it on
- 10:16the brave advert adverse event CRF,
- 10:18and then you're done. If it does meet
- 10:21that criteria that it isn't SAE,
- 10:23then you're going to go to the next step,
- 10:25which is now is it excluded
- 10:28by the protocol for reporting.
- 10:30So the spear again are exceptions
- 10:33to expedite reporting.
- 10:35And as a note.
- 10:36You really should look at the entire
- 10:38section of the of the adverse event
- 10:41adverse events section because
- 10:43there are also sometimes additional
- 10:46exceptions to SAE reporting.
- 10:48That might inhibit the make it result
- 10:52in that having to report it so.
- 10:56This is another protocol you guys
- 10:58are participating in 10212.
- 11:09So as you see like, here's the sphere,
- 11:12which is the comprehensive adverse event.
- 11:15And potential risk list which
- 11:16is the caper in the spheres.
- 11:18This this portion of it,
- 11:19the specific protocol exceptions
- 11:21to expedite reporting,
- 11:22so if the patient had free round Wikipedia,
- 11:26which I don't even think actually
- 11:27great to exist for that.
- 11:28But if febrile neutropenia,
- 11:29if they have a grade 3 then it is
- 11:33not excluded for from expedited
- 11:35reporting it most of the time
- 11:37the sphere has a lot more.
- 11:41Yeah, things on here could
- 11:43have like say it was some.
- 11:45You know a neutrophil count.
- 11:46You know, grade grade and if it was.
- 11:49Grade 3 or below.
- 11:50It wouldn't have to be reported.
- 11:53So, but this this protocol then also has.
- 12:02As additional.
- 12:10Exceptions to expedited reporting.
- 12:14So for this so here in this for
- 12:16this protocol, only the AE's grades
- 12:19listed below do not require expedited
- 12:21reporting via CEATEC errors.
- 12:23So then you would look at
- 12:26this chart and see if the.
- 12:29Adverse event was on here.
- 12:31If it was then you don't have to report it.
- 12:33If it is not on here and
- 12:36it's not excluded by sphere.
- 12:38And it is an SAE based on the SC definition.
- 12:42Then it then you are going
- 12:44to report expeditiously.
- 12:46So no, it was not included on the
- 12:48spirit was not included in the protocol
- 12:51as excluded from expedited reporting.
- 12:53So then you are going to.
- 12:55Submit an essay report for that AE.
- 12:58However, if it is excluded
- 13:01then you are going to just go.
- 13:04To the routine reporting.
- 13:07And every expedited AE is also.
- 13:12Recorded like a routine adverse
- 13:14event so the adverse event CRF
- 13:18and rabies comprehensive of all.
- 13:20Non serious adverse events
- 13:22in serious adverse events,
- 13:23so everything should be captured
- 13:26on that one form.
- 13:28Does anybody have any questions
- 13:29about this flow chart?
- 13:35Is this does it?
- 13:36Do you find this helpful?
- 13:37Like does that kind of breakdown
- 13:38the process a little bit for you on
- 13:40how you're going to take an event
- 13:42and then assess it for whether
- 13:44it's an adverse event? Yeah,
- 13:46I have one question, so that chart
- 13:49that's in the NCI protocol that has
- 13:52the reporting timeline that says
- 13:55if it's grades one, two or three
- 13:58and its results in hospitalization,
- 14:00then you have to report it within 10 days.
- 14:03But if it's grade four or five and it
- 14:07is results in hospitalization or not,
- 14:09you have to do an immediate report
- 14:11in 24 hours and then a follow
- 14:13up or a full report within five.
- 14:15Yeah this this chart.
- 14:16Here, so this is only in the case of it.
- 14:20If if it's an SAE.
- 14:23Or an AE that's not covered by spear?
- 14:27Yeah, so if it's an essay
- 14:28it has to be an SAE first.
- 14:30First you have to identify is it an
- 14:33SAE in an SAE is will meet one of
- 14:37these definitions 123456 and the one
- 14:40that kind of captures a lot of them
- 14:42are the important medical events.
- 14:44So does the investigator consider this,
- 14:46you know something that's important that
- 14:49could really result if he's not treated,
- 14:51it could result in one of these other.
- 14:53OK, I see.
- 14:55So first you have to decide and once
- 14:57you figure out it isn't serious adverse
- 14:59event and then you check the sphere,
- 15:01you check that adverse events section.
- 15:02And again,
- 15:03it's unfortunate that it's not altogether,
- 15:05but you do have to check.
- 15:07More than one location to see
- 15:09if there's any exclusions,
- 15:11but just be sure just to make sure
- 15:13you don't have overreporting.
- 15:14Make sure you look at the entire
- 15:16adverse event section of the
- 15:18protocol to be sure you're not
- 15:20missing something that should be
- 15:22reported or should not be reported.
- 15:23And that's when you then use this timeline.
- 15:26Once you've identified that,
- 15:27it should be reported in this time.
- 15:28This chart timeline chart goes into effect.
- 15:32Got it OK. Thank you so much.
- 15:35Cynthia, can I ask a quick confirmation
- 15:38question just for the group?
- 15:40Four, so it's sometimes possible,
- 15:43especially, especially in hematology trials,
- 15:45that a patient may have a grade 4 adverse
- 15:48event that didn't require hospitalization,
- 15:51and what we would have to do in that
- 15:53case is basically confirm that a
- 15:55Grade 4 is not medically significant,
- 15:58and if it's not an SAE but it is
- 16:00a grade four, it's just a regular
- 16:02adverse event like the chart notes.
- 16:05So just because it's a higher grade
- 16:07doesn't necessarily mean that it's
- 16:09automatically going to get expedited.
- 16:11Reporting right
- 16:12exactly exactly, so let me see if this.
- 16:19How do we override
- 16:20that in this system to not report it?
- 16:23Yeah, I can go over that in a minute,
- 16:24but see like right here.
- 16:26Trisha like you can see here you
- 16:29have exception 6 that I'm reporting
- 16:32anemia Grade 4 so it would have to be
- 16:35a great fight for you to report it.
- 16:37Abdominal pain constant.
- 16:38So this is like you know,
- 16:40a lot of these are pretty high,
- 16:41so this is a must get.
- 16:43Hematology study and neutrophil
- 16:45count decrease rate for so.
- 16:49In those cases.
- 16:51The spear will pretty much dictate what
- 16:54needs to be reported and what doesn't.
- 16:56If it's a new.
- 16:58Regimen that there may be a
- 17:00little bit more concerned about
- 17:01it may they may want more things
- 17:03reported than in other situations,
- 17:05so it just depends on how
- 17:06much knowledge they have.
- 17:07Probably on each individual drug
- 17:09on the regimen as to what this
- 17:11fear will list as the greed.
- 17:14And again, then,
- 17:15even if the spear says this,
- 17:16I would look through to make sure there's
- 17:19no additional exceptions to reporting.
- 17:22OK, great so yeah.
- 17:23So maybe if you want to go
- 17:25through the adverse event.
- 17:27So how you override the adverse
- 17:28event if you want to maybe we
- 17:30should just finish this and then
- 17:31maybe we can go over and talk about
- 17:33C tip errors real quickly and the
- 17:35adverse event reporting through.
- 17:37Yeah I. I think going through
- 17:39Rave would be extremely helpful.
- 17:42So anyway, so this is like I said,
- 17:43this is the basic process that you're going
- 17:46to take when you have an adverse event
- 17:48in that you can then determine and again
- 17:50the the physician needs to be involved.
- 17:52In particular in these earlier phases
- 17:55just to get the grade and this.
- 17:59You know and how significant
- 18:01the adverse event is so.
- 18:03Then just some things to consider.
- 18:07When you do have an adverse event,
- 18:09like was it an adverse baseline symptom.
- 18:11If it was an adverse baseline
- 18:13symptom and it did not change like.
- 18:17It was the same grade.
- 18:19There was no change in attribution
- 18:20then it does not have to report
- 18:22it as an adverse event.
- 18:23A routine adverse event or
- 18:24as a serious adverse event.
- 18:26However, if it does change in severity,
- 18:29the grade increases or
- 18:31the attribution changes.
- 18:32It's now possibly or probably
- 18:35related to study drug.
- 18:36Then you would then have to enter it as an
- 18:40adverse event on the seat adverse event CRF.
- 18:43And then again,
- 18:44it wouldn't be an SAE unless it met
- 18:46all those other criteria for an SAE.
- 18:48Another thing that would have to be
- 18:50assessed is if if an adverse baseline
- 18:53symptoms like intermittent something,
- 18:54then that's fine.
- 18:55But if it's a kind of a finite
- 18:57adverse event that has a stop date
- 18:58and it reoccurs during this study,
- 19:00then it would have to be reassessed
- 19:02for now as an adverse event.
- 19:03Just because we want to know what
- 19:05did it reoccur because of study drug.
- 19:08And then you want to look at
- 19:10whether the patients receiving
- 19:11investigational or commercial drug,
- 19:14I believe at the recent audit the
- 19:16patient was initially receiving just
- 19:18commercial and then on day eight they
- 19:21started receiving the investigational drug.
- 19:24So during that first eight
- 19:26days the patient did have.
- 19:28What could have been considered an SAE?
- 19:30But because the patient was only on the
- 19:33commercial part of the study so far,
- 19:35it was not.
- 19:38He did not have to report it
- 19:39because it was an expected event
- 19:41for those drugs and expecting this
- 19:43you can really find out when the
- 19:45commercial drugs by looking at the.
- 19:47The idea for that drug.
- 19:49Do you have a quick question about that one?
- 19:52Because on the previous page it mentioned
- 19:53that it was if it was like a hospitalization.
- 19:56It's regardless of. The attribution,
- 20:01well, this is only for commercial drugs.
- 20:03If there was investigational drug,
- 20:05all of that applies,
- 20:06but for a commercial drug,
- 20:08unless the protocol specifies differently.
- 20:11They you they already have a
- 20:13safety profile for those drugs,
- 20:15so you you refer to that safety
- 20:17profile for that commercial drug
- 20:19to determine if it's serious and
- 20:21if you have a question about that,
- 20:24the safest bet is to call see tip
- 20:26errors and and ask them talk to the lead
- 20:30physician of the national Pi for the study.
- 20:33Talked to them about that again,
- 20:34as soon as it as soon as the
- 20:36patients on either you know,
- 20:38even if they're on commercial
- 20:39and investigational,
- 20:40the Pi thinks is related to the.
- 20:42Commercial, it doesn't matter,
- 20:43it still is reported because that patient
- 20:45also on a new regimen and part of
- 20:47that regiment is an investigational agent.
- 20:48So it goes under the
- 20:50investigational umbrella.
- 20:51The only time this applies if there
- 20:53are only on commercial drugs,
- 20:55and sometimes you might see that
- 20:56if the patients randomized in one
- 20:58arm is only the standard of care
- 20:59and the other one is standard of
- 21:01care plus an investigational agent,
- 21:03and then in that situation he
- 21:06assessment of adverse events can
- 21:08be different just based on.
- 21:10Which arm they're on?
- 21:12So and again,
- 21:13if you have a question about that,
- 21:14the safe route would always be.
- 21:16Talk to your Pi,
- 21:18talked to Li Pi calceta pairs and just
- 21:20confirm whether it should be reported.
- 21:23Look in the protocol, but the standard.
- 21:26Directions are if it's only a
- 21:29commercial agent, that's it.
- 21:30They they have a safety profile
- 21:32and you go by that.
- 21:33And if it's an expected.
- 21:36Event for that for that commercial
- 21:38drug or combination of drugs then it
- 21:41would not be reportable because it's
- 21:43almost like over reporting for the study.
- 21:46Does that make sense?
- 21:47Yeah, so I'm just gonna try to
- 21:50rephrase only once a patient
- 21:51or for the most part site.
- 21:53Some trials are different.
- 21:55Once a patient starts,
- 21:56the investigational drug is when
- 21:58we're making those SAE assessments.
- 22:01Yes, well, not necessarily.
- 22:02You're going to make them all
- 22:04along because you could still
- 22:06have an unexpected adverse event
- 22:08with commercial commercial drugs,
- 22:10so you have to look at it wasn't it
- 22:12wasn't an expected or unexpected.
- 22:14It was unexpected in serious.
- 22:16Then it still gets reported.
- 22:18So, so I'm going to go back to the example.
- 22:20So if a patient is hospitalized
- 22:23on a commercial drug,
- 22:25even though a hospitalization
- 22:27meets the definition of an SAE,
- 22:29it's not necessarily reportable
- 22:31unless it's a non serious.
- 22:36If the patient is hospitalized,
- 22:37I would definitely contact the
- 22:39national Pi or C temp errors.
- 22:42I don't know if you know if they
- 22:45have grade for me peneia that
- 22:47might be an expected event now.
- 22:49What was the reason for
- 22:50them to get hospitalized?
- 22:51You know what I mean?
- 22:52You have to look into that further.
- 22:53I can't really say.
- 22:55Conclusively that they wouldn't.
- 22:56That would need to be repeat reported.
- 22:59I think in that situation you need to like.
- 23:01Like I said, talk to cite pairs and
- 23:02talk to the National Pi and say you
- 23:04know they're only on this commercial.
- 23:06Dr is expected for the patient
- 23:09to have prayed for neutropenia.
- 23:11We're putting him in the hospital
- 23:12for this reason.
- 23:13You should report it.
- 23:14I think in that situation I would
- 23:16just for just confirm what they want.
- 23:21But in a situation,
- 23:22what we had this week,
- 23:23and I think you did contact setep errors.
- 23:27They they came back pretty
- 23:28quickly and said now these are
- 23:29expected adverse events for these.
- 23:31For these drugs and it does not
- 23:32need to be reported because
- 23:34they know historically been
- 23:35treating patients with that drug.
- 23:37But their blood counts are going to
- 23:39drop and they don't need to know that
- 23:40again because they already know it.
- 23:45I know it's a little confusing,
- 23:46but I don't think you need to.
- 23:48I don't think you need to focus too much
- 23:49on that because there's not that many
- 23:51instances there that's going to occur.
- 23:52It's only going to occur in that one.
- 23:55The protocol that you just did when they're
- 23:58only on commercial for that first eight days.
- 24:01Or in a situation where there
- 24:02might be two different arms,
- 24:031 standard of care and one is not standard,
- 24:05one has standard of care plus
- 24:06an investigational agent.
- 24:07Most protocols you're going to have an
- 24:10investigational regimen, even if it's over.
- 24:13The regimen has some.
- 24:14Standard of care and investigational
- 24:16agents or commercial agents and that
- 24:19are used that for new reason than
- 24:21their investigational agent, again.
- 24:24So most protocols are going to be
- 24:26under the investigational umbrella,
- 24:27so my my my feeling is you need to
- 24:31assess every adverse event for it
- 24:33as a E and then in your head you
- 24:35know if you realize this protocol
- 24:37has a standard of care arm.
- 24:39Then you just want to sit there
- 24:41and look at it a little further to
- 24:43make sure it's still reportable.
- 24:45But again,
- 24:45most most of your situations are going to
- 24:47be under the investigational umbrella.
- 24:49I think the commercial umbrella
- 24:51is is not very often,
- 24:53at least not not in our early fate,
- 24:54not in the phase one,
- 24:55and not in the early phase.
- 24:57Two titles that we've been doing.
- 24:59I think that's really helpful,
- 25:00so I guess forever my team standpoint,
- 25:03what we'd want to do is,
- 25:04during study startup,
- 25:05assess whether or not there's a
- 25:07commercial drug use so that we can pay
- 25:09closer attention to the essay reporting,
- 25:11which should be on less than
- 25:13the majority of the trial, so.
- 25:14That's the time point.
- 25:16I think that we maybe want to make that
- 25:18assessment because it sounds like again,
- 25:19it's not for all of them
- 25:21again and again if it,
- 25:23even though it's a commercial drug.
- 25:24If you're taking it for a new reason,
- 25:27it's not approved for it becomes
- 25:29an investigational drug.
- 25:30And if it's if it's not standard of care for
- 25:33what you're giving the patient that drug for,
- 25:36or if it's being combined with
- 25:38another investigational agent,
- 25:39you're looking at the whole regiment.
- 25:40The whole regimen has again,
- 25:42once on that protocol we
- 25:44were just discussing.
- 25:45Wednesday 8 happened in the the
- 25:47investigational drug was added.
- 25:50It becomes an investigational
- 25:51regimen and all adverse events
- 25:53then qualify for SAE reporting.
- 25:57So even if the doctor thinks it's active,
- 25:59they even if they attribute
- 26:00it to one of the other drugs,
- 26:02they still have to report it,
- 26:03because there's no guarantee that
- 26:05it really was could be attributed
- 26:07to that commercial agent.
- 26:08You know what I'm saying?
- 26:09Unless the spear excluded it right?
- 26:12Or it could be like a combination of the
- 26:14the drugs and we wouldn't know unless
- 26:16everyone is reporting right exactly.
- 26:19To be more frequent, it could be great,
- 26:21could be worse severity.
- 26:23It could be worse.
- 26:24So yes, so those so.
- 26:26You know, so I don't want to confuse you.
- 26:27I don't want you to not report things,
- 26:28I just want to know about this community.
- 26:31If it's a new regimen for that.
- 26:34On study diagnosis,
- 26:35then that's always investigational
- 26:36if if it's standard of care plus an
- 26:39investigative investigational agent
- 26:41becomes an investigational regimen.
- 26:43And then it's just like treated just like.
- 26:47If they were just on the
- 26:49investigation one drug so.
- 26:51So there is one question in the chat
- 26:54one of our coordinators just wants to
- 26:57confirm that during a hospitalization
- 26:59that we should be reporting out
- 27:01on all abnormal or all labs.
- 27:04Concomitant medications and AES that
- 27:06occurred during that stay within the EDP.
- 27:10And can you just confirm for us
- 27:12again that grade one adverse or grade
- 27:15one labs during hospitalization?
- 27:16Do those also need to be reported under the.
- 27:23Under the, I can't think of that lab page.
- 27:29An additional lab page or during
- 27:32hospitalization is adjust what's significant.
- 27:34Is it all or just what's been
- 27:36deemed significant? I guess
- 27:37is what I'm trying to place
- 27:38when they're hospitalized.
- 27:39I mean, I think they're gonna
- 27:40have an abundance of labs.
- 27:41I think it needs to be.
- 27:42It definitely needs to like
- 27:44if there's still, you know,
- 27:46being assessed or giving study
- 27:47drug course you have to follow
- 27:49what's on the study calendar and
- 27:51enter all of those time points.
- 27:53And then yes,
- 27:54I would say anything that's
- 27:56you know significant from the
- 27:58hospitalization should be entered.
- 27:59I I. I don't think it's realistic
- 28:02to enter every single lab.
- 28:04That they had ever drawn, but I mean,
- 28:06I think you need to look and see,
- 28:07you know, look through all the
- 28:09labs and if there's changes and.
- 28:12The the values you know if the
- 28:14patient goes from grade one to
- 28:15grade 2 and then the grade 4,
- 28:17you know you need to like come
- 28:19and enter those, but I don't.
- 28:22I've never been told what exactly
- 28:23I've never been asked that before,
- 28:25and I've never really looked to
- 28:27see that every lab is entered.
- 28:28I would look for significant
- 28:30labs and anything.
- 28:32You know that needed it to be
- 28:35reported more so than all the labs.
- 28:38OK, great, thank you so much.
- 28:40I can get more clarification
- 28:42on that if you like but.
- 28:44But yes, I mean. I I don't know my.
- 28:47My experience is that when
- 28:48they're hospitalized,
- 28:49I think they can have multiple
- 28:50draws in a day.
- 28:54Yes, and I know that that was a
- 28:56question that came up during last
- 28:58week's audit was to ensure that we
- 29:00were assessing the abnormal labs.
- 29:02So I I guess I jumped to that
- 29:04conclusion that in a hospital in
- 29:06the case of a hospitalization,
- 29:07we would only then be reporting
- 29:10abnormal labs that were deemed
- 29:12clinically significant by the provider
- 29:14and not all labs that were drawn on
- 29:16that patient for their their stay.
- 29:21Yes, I mean I think I would probably enter
- 29:23all the labs on the day of admission.
- 29:25You know, like I mean like 1 comprehensive.
- 29:28You know CNBC, you know, like.
- 29:30CBC you know and all that kind of stuff.
- 29:33Just have one baseline from
- 29:35when they were admitted,
- 29:36and then maybe like you said,
- 29:37anything that significantly changed
- 29:39throughout the study if they stayed,
- 29:41but they were stable throughout.
- 29:42And those values didn't change their.
- 29:44I don't see a reason to
- 29:45continually put everyone in,
- 29:46but as they have significant changes
- 29:48then I would enter those values.
- 29:51But I think putting the baseline
- 29:52in would be a good idea when
- 29:53they were first hospitalized.
- 29:58And that gives you kind of a baseline.
- 29:59Do that. You're going off
- 30:01up to assess the remaining.
- 30:02You know the remaining blood draws.
- 30:06OK, I think that makes sense if you if
- 30:08there's any other further like written
- 30:09guidance on that, I think that that
- 30:12would be. I'll ask if there's any written
- 30:13guidance or anything that can be, you know,
- 30:15concrete guidance that can be provided. OK,
- 30:18that'd be great. Thank you.
- 30:21And then again,
- 30:22like you're in the protocol,
- 30:23specific requirements reporting,
- 30:24and then the reason for the hospitalization
- 30:27hospitalization is only reported
- 30:29reportable if aney is associated with it.
- 30:31If it was a hospitalization plan plan
- 30:33prior to the study for an elective surgery,
- 30:36then that's not an SAE.
- 30:38If it's a hospitalization because
- 30:40they may have a for some reason,
- 30:43they have to get a port put in or
- 30:45something that's not going to be an SAE.
- 30:46They were just putting the patient in
- 30:48there to have that procedure done.
- 30:50So just some you know,
- 30:53all hospitalizations
- 30:54don't need to be reported,
- 30:55they're only reported if they're
- 30:58related to an adverse event.
- 31:02Just a reminders all information
- 31:04that's on the adverse events in
- 31:06Europe and in the expedited report
- 31:08has to be in source. So just remind.
- 31:13Your investigators to you know.
- 31:14Thoroughly document these adverse events.
- 31:17The protocol Trump's all
- 31:18other reporting requirements.
- 31:19So the protocol says there it's
- 31:22there's an exception to reporting.
- 31:25Or that it needs to be reported
- 31:26then it's reported or not reported?
- 31:28I mean, of course,
- 31:30if the physician feels like.
- 31:33You know has a feeling that
- 31:34this has to be reported,
- 31:35and of course he konesky or she can
- 31:37escalate that to the National Pi and the
- 31:39C type errors and then just you know,
- 31:42consensus consensus on whether
- 31:43it should be reported. Uhm?
- 31:46The expedited reporting CRF in
- 31:48Rave is just a recommendation.
- 31:52It's then you have to still go through
- 31:54that flow chart that I provided.
- 31:57You know the Pi needs to make
- 31:59the final decision.
- 32:00You know,
- 32:01based on the protocol requirements and
- 32:03the attributions of you know of the AE,
- 32:06if it should be reported.
- 32:08So not every time that the
- 32:10expedited reporting CRF says.
- 32:12They recommend reporting
- 32:14doesn't have to be reported.
- 32:16There should only be one
- 32:17estate report per course,
- 32:19so if the patient has even two
- 32:22separate unique SAE's during the
- 32:24same course that have you know one
- 32:25starts and stops and then a whole
- 32:27different SAE starts and stops,
- 32:28it still goes on one report and
- 32:30these first report is just amended.
- 32:33If there are recurrent recurrent
- 32:35adverse events in SAE's,
- 32:37they must be reported on the
- 32:39rave adverse events era.
- 32:40Every occurrence must be.
- 32:43Put on there, unless it's wearing one.
- 32:47That's not required,
- 32:48but recurrent Sae's you do not
- 32:51have to submit another expedite
- 32:53report unless the grade increases
- 32:55or there's a hospitalization
- 32:56associated with the recurring SAE.
- 32:58So with the patient.
- 33:01Had.
- 33:02You know, uh,
- 33:03grade four wheels go with grade 4.
- 33:06B Braun neutropenia or grade.
- 33:083 new brown neutropenia and then it resolved,
- 33:12and then the next course
- 33:13it it started up again.
- 33:14You'd still record that and rave,
- 33:16but you wouldn't have to submit another
- 33:18SAE report unless the grade went up to,
- 33:20like,
- 33:20maybe grade four or they ended up
- 33:23being hospitalized for that event.
- 33:24Lab abnormalities grade two
- 33:26and higher must be entered as
- 33:28adverse baseline symptoms and
- 33:29as adverse events regardless of
- 33:31their clinical significance.
- 33:33If you have any questions about the
- 33:36management of these adverse events in Rave,
- 33:38I would contact data management.
- 33:41But if you have any questions about
- 33:43the submission of an SAE and if a
- 33:45drug if an adverse event is an SAE,
- 33:47I would contact the seat up
- 33:48mirrors desk and they can give
- 33:51you some guidance on that.
- 33:53So for these slides,
- 33:55are there any questions that you have?
- 34:02Does that help at all?
- 34:03You got help you at all. Kind of dumb.
- 34:05Understand the flow of of adverse
- 34:07events and how you assess them. As CS.
- 34:15I think this was extremely helpful.
- 34:18So did you want
- 34:19me to go through? I guess you want
- 34:21me to go then through the UM?
- 34:23Let's say he reporting let's
- 34:24see I can go open that too.
- 34:26So I won't. I won't go through
- 34:28all of this because I think you
- 34:30guys have this PowerPoint already,
- 34:32so there's not unless you want me to.
- 34:34If you want me to, I will,
- 34:35but if you if you.
- 34:38If you want to, I think
- 34:39there are two things that came up last
- 34:42week 'cause we do have this from July
- 34:44and I think last week what we were
- 34:47noticing is when there's multiple
- 34:49SAE's in the same course and then how
- 34:51to like bypass the suggestion like
- 34:54what steps need to be taken when setep
- 34:57errors believe something is an SAE
- 34:59and we've confirmed that it's not.
- 35:02OK, OK so. And you know, so as you know,
- 35:07there's the adverse event in the
- 35:08expedited reporting evaluation,
- 35:10so you know I'll just kind of go
- 35:12through a general introduction and then
- 35:14will so you know, all adverse events
- 35:16are interred on the adverse events.
- 35:17Sierra as soon as you enter them.
- 35:21Then you. Have to go to the expedited.
- 35:28And you have to click send for evaluation,
- 35:30hit save, and then you're going to either get
- 35:33a recommendation to report or not report,
- 35:36and you of course want to look for any
- 35:37errors if there's an error in the submission,
- 35:40then there's going to be some kind
- 35:41of alert up here saying that your
- 35:43form did not get submitted, and.
- 35:45Something is wrong and most likely what
- 35:47is could be wrong is that on the adverse
- 35:50events here a maybe there's some missing
- 35:53information that is required in order
- 35:55to submit it to see to bears for evaluation,
- 35:57and most of the time those are the.
- 36:01Fields with a like a red
- 36:03asterisk or highlighted in red.
- 36:05The only one that may not be his attribution,
- 36:07and that one's definitely required,
- 36:09and they're also cannot be any
- 36:11outstanding system queries.
- 36:12They all system queries must be closed before
- 36:16you can send that form for evaluation.
- 36:19Uhm, let's see.
- 36:22So again,
- 36:22these are all the recommendations
- 36:24that can come back based on sending
- 36:28that form to the rules evaluation.
- 36:31And.
- 36:33So if you have a recommendation for none,
- 36:36so if you.
- 36:38If that's the recommendation you get back,
- 36:39however, you realize the protocol
- 36:42requires you to submit that as an SAE.
- 36:45Then all you have to do is click
- 36:49this to complete the safety report.
- 36:51But you're not going to change this,
- 36:53you're gonna leave that as it is.
- 36:54The recommendation stays none,
- 36:55but you're still going to click this
- 36:57and go ahead and complete the essay
- 36:59report as normal and cite pairs.
- 37:03So that's that.
- 37:05And then if it says to create.
- 37:07Uhm? Then and again,
- 37:10like when you say when there is
- 37:13none right here in this column
- 37:14on the adverse events here,
- 37:15if you're going to see
- 37:17the recommendation is no,
- 37:18and this is a derived field and will not
- 37:20change based on you submitting the report.
- 37:23It will always remain no.
- 37:26So just as an FY I you don't
- 37:27need to go in and change that.
- 37:28It just states that that was
- 37:31the original recommendation.
- 37:32And then if they said to create it,
- 37:34that field gonna say yes and again,
- 37:36even if you override that recommendation,
- 37:38it's always going to say yes in this field.
- 37:40The original recommendation
- 37:41is always going to be there.
- 37:44So then if you wanna override this
- 37:48recommendation, what you have to do
- 37:50is then you do go change this create
- 37:52to none and then that will just.
- 37:55Reverse the recommendation in.
- 37:58The report type, the due date
- 38:00and all that will then disappear.
- 38:03So it's a little confusing
- 38:05because if they don't,
- 38:06if they don't recommend it,
- 38:08you don't change it to create,
- 38:10you just leave it as none.
- 38:11But if they say create you are
- 38:13going to change it to none and then
- 38:14that way this page will no longer
- 38:16have that recommendation on it.
- 38:18And there's a chance.
- 38:19Then, if you ever had to modify the
- 38:21adverse event CRF and you went back
- 38:23and ran the rules evaluation again,
- 38:25it most likely you're gonna end up
- 38:26having to do that a second time.
- 38:31And then you know we don't
- 38:32need to go through all that.
- 38:33I think does that answer
- 38:34your question pretty much.
- 38:38Yes, I believe that does team.
- 38:40Do you guys have any other
- 38:42questions about that report when?
- 38:45It triggers us to report something,
- 38:46but we've gone through those
- 38:47steps that Cynthia went through
- 38:49in the last presentation.
- 38:52OK, no, I guess oh thank you
- 38:55alright. One confirmation
- 38:56I think we got it.
- 38:58I have one question so if it says say we had
- 39:02to change something on just a regular AE,
- 39:05if we had already changed this
- 39:08to none would the database then
- 39:11recommend an amend or create again?
- 39:14If we submitted the ease for review
- 39:16and it still contained the one that
- 39:19it thought needed to be expedited,
- 39:21does that make sense?
- 39:22I hope. I hope it does.
- 39:24Yes, yeah no, it does make sense, right?
- 39:27Yes, I think like if you
- 39:29haven't submitted a report,
- 39:31it'll come back and say,
- 39:32create UM. And. I would.
- 39:38You know that's an interesting question
- 39:40I I would assume if you you amended
- 39:43something that they recommended for
- 39:45reporting but you did not report,
- 39:48I would think that that could trigger
- 39:50the same situation where they might say
- 39:52amend and you really don't amend it.
- 39:54You didn't submit it as an SAE,
- 39:56but that's only if you had already submitted
- 39:59another essay report for a different SAE.
- 40:02In that situation,
- 40:03I think I would call a seat at errors desk
- 40:06and just ask their opinion on on how to.
- 40:09Modify this form.
- 40:10I don't know if that's has that
- 40:12come up for you before where you had
- 40:15submitted an SAE for something else
- 40:17that wasn't a save during that course,
- 40:20but the one of the events that they
- 40:23recommended you did not submit.
- 40:25And
- 40:26yeah, it yeah. So it came up we had
- 40:29a grade for white blood cell count
- 40:32decrease and we reported it on the
- 40:35form and then I had changed it to none
- 40:37originally since it was already reported.
- 40:40And of course, previously, and when I
- 40:42had submitted the changes for review,
- 40:45it then told me again to create.
- 40:47So it just kept telling me to create or.
- 40:51Yeah,
- 40:51but it will continue to tell you to
- 40:53create 'cause it's gonna have the same.
- 40:55It's gonna evaluate it the
- 40:56same as it did the first time.
- 40:57So each time you're just gonna have to
- 40:59keep going in and changing it to none.
- 41:01OK alright, that makes sense.
- 41:02That's easy enough.
- 41:06So that's. Yeah, so that's really dumb.
- 41:10I don't know if there's anything else,
- 41:11but really the setep errors help desk.
- 41:13I think that they're very helpful,
- 41:15very knowledgeable,
- 41:16so it's it's a great resource.
- 41:19And then, of course,
- 41:20the paradox data management when it comes
- 41:23to anything about the data entry INT array,
- 41:26they should be very helpful and you
- 41:27can always reach out to me also.
- 41:29And if I can't answer it,
- 41:30I'll make sure that data
- 41:31management gets back to you.
- 41:36So anyways, is there anything else that
- 41:38you wanted to review during this call?
- 41:42And now I can't remember if
- 41:43there are slides in this one,
- 41:44but just the if there are any slides
- 41:47when potentially like a second,
- 41:49SAE occurs within the same
- 41:51horse in the seat app.
- 41:53I think the problem we were having
- 41:55that arose last week was the
- 41:57the ticket going into the first
- 42:00ticket that we created in the
- 42:02course report or the first SAE
- 42:04to then add on a second SAE.
- 42:08Yeah, so you. So you would still be.
- 42:13However, you would amend that original
- 42:16report is the same way you would
- 42:18go in and then add the new event.
- 42:21So, uhm. At that point,
- 42:25as there is there a link to the to
- 42:27the actual report that was created?
- 42:32'cause if it says amend,
- 42:34here it says. Like edit,
- 42:37then you're still gonna click this.
- 42:39To edit the report so they say
- 42:41that in the directions they say
- 42:43you still click this and it should
- 42:45take you to that report that was
- 42:47created during this course because.
- 42:51My understanding is by doing
- 42:53this integrated system you're not
- 42:55supposed to be able to submit more
- 42:57than one SAE report for course.
- 42:59That was one of the reasons that
- 43:02they created this system. Was.
- 43:08Who? You know, diminish.
- 43:12Over reporting or creating more than one.
- 43:15Like duplicate data entry,
- 43:17minimize overreporting.
- 43:18Make sure that there could
- 43:19only be one essay report.
- 43:20Course was my understanding
- 43:22of why they come.
- 43:24Created the system.
- 43:32So should the system should.
- 43:36And if you find if anybody
- 43:37found that that's correct,
- 43:38then I think maybe contacting C type
- 43:40errors and you could let me know that.
- 43:42But my understanding is that this
- 43:44system should only allow you to
- 43:47submit one SAE report per course.
- 43:52Cynthia, we might wanna follow up with you
- 43:55because we had a few instances where we
- 43:57were able to open up a secondary ticket.
- 43:59And so all work with the teams and better
- 44:02understand like what the like, how that came.
- 44:04Came about because there were there were
- 44:08there was the ability on some of these to
- 44:11have two tickets open for the same course,
- 44:13and that's what we were correct in last week.
- 44:16OK, OK, so yes, if you can look into
- 44:19that and if you can let me know what
- 44:22you find out about that and if you
- 44:24talk to setup errors. If you can ask.
- 44:27How, why that occurred and if, and if,
- 44:30how you can prevent that in the future.
- 44:32And if you can let me know because again,
- 44:34like when you look at the.
- 44:37If you look at the guidelines for
- 44:39the expedited reporting that got
- 44:41that that I also gave you the.
- 44:45It's the.
- 44:49Miss CTS, you resource guide
- 44:51or expedite reporting.
- 44:53That's where I got.
- 44:54You know, a lot of this information,
- 44:55not all of it, but a lot of this
- 44:58information from and so like I said
- 45:00when they say that you have to amend a
- 45:02report or do anything they're directions,
- 45:04say, amend and then you have
- 45:06to click this link again.
- 45:08That would should take you to that report.
- 45:13OK, well we'll do
- 45:15some further investigating on our end
- 45:17and and let you know how that came about.
- 45:21Yeah, that would be good because you know,
- 45:23like I said that that would.
- 45:26The unfortunate it's it's not really.
- 45:29You know easy to identify how to add a
- 45:33second event to a report report versus.
- 45:39You know having the mistake of adding
- 45:41adding a secondary port for that course?
- 45:45I'm also getting some comments
- 45:47that Extensionally might be the
- 45:49difference between prior to the
- 45:51integration and post integration,
- 45:53so we'll just do a take a quick look
- 45:56at that and see if those studies
- 45:57that we have that door reporting
- 45:58during the course was from the.
- 46:01Non integrated or prior to the integration?
- 46:05Yeah and then. And it also it's it's
- 46:10really recommended you can go once you've
- 46:12submitted the report. Ruciane grave.
- 46:17You can go through the regular Ave
- 46:20to see temp errors to complete the
- 46:23narrative or anything that's not
- 46:25contained on the adverse events.
- 46:26Sierra. However, it's recommended
- 46:28that you always go through rave
- 46:31just to ensure that no change.
- 46:33Not that you can actually submit it.
- 46:35'cause if you try to submit a
- 46:36change that's going to field that's
- 46:38on the adverse events here up,
- 46:39it's going to get rejected,
- 46:41so it's advised that you just
- 46:43always go through rate to make
- 46:45any kind of amendments or updates.
- 46:47Never saw that report.
- 46:52Great, thank you.
- 47:00So it's anybody else have any questions or?
- 47:08Team, do you guys have go ahead and
- 47:10put in the chat or just you can unmute
- 47:13and just confirm if there's anything
- 47:15else that you wanted to review today?
- 47:23I'm not in Trisha.
- 47:24I have that flow chart just on an
- 47:26independent individual Word document.
- 47:27If you if you want that separately.
- 47:30You know if that would be helpful at all.
- 47:33I guess if you don't mind that
- 47:35I I really like that flow chart,
- 47:37so I'm hoping we can share that
- 47:39and that can be a useful tool
- 47:41when our teams are making working
- 47:43with the physicians to determine
- 47:45the reporting requirements.
- 47:48Yep, I'll send it to you.
- 47:51OK, well if you know I'm always happy to
- 47:54get it on the phone or answer questions.
- 47:57Go through anything.
- 48:00You know, in rave that you might,
- 48:02you know if I don't know the answer.
- 48:03Of course I will go to somebody
- 48:05and find the answer for you,
- 48:06but I'm always happy to do this.
- 48:08So 'cause I know it's a lot.
- 48:09There's a lot of changes going on.
- 48:11There's a lot of things to
- 48:12keep in mind and the protocols
- 48:14are getting more complicated.
- 48:16So I know it's not not easy.
- 48:21It's not, but it's really helpful when
- 48:23we have your support and the support
- 48:25of setep errors and everyone else
- 48:27that does allow us the opportunity
- 48:29to ask these questions and get
- 48:31answers so that we can continue to
- 48:33improve our reporting processes and
- 48:36the one thing also to remember.
- 48:39If you're not really sure,
- 48:41go ahead and submit the 24 hour report,
- 48:43because if you don't submit the five
- 48:46day report, if you find out after
- 48:47submitting the 24 hour report that
- 48:49you know what now we've come to like.
- 48:50It's a Saturday. We think it's an SAE.
- 48:53We submit the 24 hour report you come
- 48:55in on Monday. You do a little bit.
- 48:57You know deeper look into it and you
- 48:59say Oh no, the protocol excludes this.
- 49:01We didn't have to report it, just don't.
- 49:03So if you don't submit the full
- 49:05report it gets dropped so it wasn't.
- 49:07It never was until you submit
- 49:10the report the full report.
- 49:11It's not.
- 49:12It's not a you didn't report it
- 49:14to C temp errors.
- 49:15You know what I'm saying so you
- 49:17always have that five days to give
- 49:19yourself a little extra time to
- 49:21make sure it actually is an SAE.
- 49:23So in those instances where you know it's.
- 49:27It's a little crazy.
- 49:27It's late at night, you know,
- 49:29it's a weekend,
- 49:29it's whatever and you feel like you
- 49:30think it's an essay and you come
- 49:32in on Monday and realize it's not.
- 49:33It's not the end of the world,
- 49:34you just don't submit the full report
- 49:35and you just you just realized it wasn't.
- 49:37Reportable and it doesn't.
- 49:38You know it doesn't go any
- 49:39further and it doesn't.
- 49:40It's not considered over
- 49:41reporting or anything like that.
- 49:44That doesn't make sense.
- 49:46Gives that again it gives
- 49:47you a little bit extra time.
- 49:49You know better to do that than
- 49:51probably to have a late report.
- 49:53'cause you didn't have time to assess
- 49:54it on the weekend or something,
- 49:55or you thought you know you, you know.
- 49:58And Cynthia, can you confirm as long as
- 50:00we withdraw that before,
- 50:02like an audit type of situation,
- 50:04that would not then be a finding, right?
- 50:07I it would be if it actually got submitted.
- 50:09If you completed the five day report,
- 50:11you know there's a 24 hour
- 50:12report in the five day report.
- 50:14So you submit the 24 hour report and
- 50:15then you get the email saying for it
- 50:17says even I think in rate no, I don't.
- 50:19I hope it changes in rave or not, but it did.
- 50:21You get the email saying the
- 50:23full report is due on this day.
- 50:25If it's not submitted,
- 50:26then the ticket gets dropped from the system.
- 50:29OK, so it's really bad,
- 50:30so it's like really do you submit the
- 50:3224 hour and you don't submit the fold?
- 50:34And that's a fine 'cause it
- 50:35never got submitted.
- 50:36Or if you submit the 24 hour and
- 50:38you realize you know what we didn't
- 50:39have to submit this as an essay so
- 50:41you never submit the full report
- 50:43that they'll never be a record.
- 50:44There's no record of you submitting it
- 50:46like software on your end that you've got.
- 50:49OK, so it's not a submitted SAE because
- 50:50you would never submitted the full report.
- 50:54OK, right, that's very helpful
- 50:5624. Five five days, so you have to
- 50:59submit that full report in order for
- 51:01it to be submitted to see temperatures.
- 51:03Otherwise they drop it in the system
- 51:05after like I think five or seven days.
- 51:09OK, I think that's really helpful.
- 51:16So. Alright, well again,
- 51:20if you have any other rum.
- 51:22Questions about AE
- 51:24reporting or anything else?
- 51:27To do with raise just please let me
- 51:29know and I'm like I said I'm happy too.
- 51:32Get another zoom call and discuss it.
- 51:35Thank you so much Cynthia again,
- 51:36we we really appreciate your time
- 51:38this afternoon and I I think this
- 51:40was extremely helpful to just review
- 51:41some of these sticking points for us,
- 51:43so we will follow up about some of
- 51:46those additional questions that we had
- 51:48and if I I think that the one thing
- 51:50I had written down is just about the
- 51:52the labs during hospitalizations and
- 51:54any more clear or formal guidance that
- 51:56we can have and hope that you'll see
- 52:01improvements at our annual audit this year.
- 52:05I think I will I I know it's a
- 52:06little confusing this new expert
- 52:08value reporting method because
- 52:09it is difficult when you get the
- 52:11recommendation to submit and then it
- 52:13really didn't need to be submitted.
- 52:14That's some little confusing so.
- 52:17You know, but hopefully now you
- 52:19understand that even though they do
- 52:21say that there's they set up these
- 52:23protocol specific reporting evaluation,
- 52:25it's not completely.
- 52:29Protocol specific 'cause it
- 52:30doesn't include all the exceptions.
- 52:34Yeah excellent. Alrighty,
- 52:37well have a great weekend everyone and
- 52:40good holiday if you're off on Monday.
- 52:43Thank you very much. Thank you Cynthia.
- 52:45Thanks everyone for joining Happy Friday.