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Theradex SAE Reporting

March 09, 2022

Presented 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.

ID
7518

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.