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Introduction to Research Administration March 28, 2011 Joy Jurnack IRB Education Analyst http://irb.med.nyu.edu/ Human Research Protections is a Shared Responsibility Institutional Review Board (IRB) Office of Research Compliance and Conflict of Interest Office of Clinical Trials (OCT) Sponsored Programs Administration (SPA) Office of Institutional Liaison (OIL) Principal Investigator and Research Team Our Speakers: • • • • • Tony Carna, Director, SPA Nicky O’Connor, Associate Director, OCT Abram M. Goldfinger, Executive Director, OIL Helen Panageas, Associate Director, IRB Keisha Lightbourne, Director of Research Compliance and COI Introduction to Research Administration (HRPP) Tony Carna, Director Sponsored Programs Administration Month Day Year Introduction to Research Administration (HRPP) Tony Carna, Director Sponsored Programs Administration Month Day Year Role of SPA in HRPP 1. Assure that agreements with external parties who fund research at the University, such as federal agencies, foundations and for-profit corporations, are consistent with University requirements related to the ethical conduct of research. Role of SPA in HRPP 2. Negotiate agreements with external parties who fund research at the University that are consistent with University requirements related to the protection of research participants. Role of SPA in HRPP 3. Guarantee that research grant and contract funds are not expended for human research prior to approval or determination of exemption by one of the NYU IRBs 4. Ensure that clinical trial agreement terms do not conflict with the IRB approved protocols. Other Sponsored Programs Compliance Requirements • Safeguarding all assets • Spending funds in accordance with the authorized purpose • Developing and implementing systems to ensure proper stewardship of funds – – – – – Financial management systems Procurement systems Time & effort reporting systems Monitoring activities Adherence to terms & conditions of award Sponsored Programs Policy Requirements Institutional Policies • Organizational Structure • Purchasing • Accounting/Budgetary Controls • Time and Effort Reporting • Travel • Consulting • Property Management • Ethics/Conflict of Interest NYU School of Medicine Office of Science & Research Administration: Office of Clinical Trials Introduction to Research Administration The Role of the Office of Clinical Trials March 28, 2011 Nicky O’Connor, BSN, MPH, CCRC Associate Director Office of Clinical Trials Office of Science & Research Organizational Structure OSR Administration Division Of Laboratory Animal Resources Institutional Animal Care & Use Facilities Office Of Industrial Liaison Office Of Clinical Trials Institutional Review Board Sponsored Programs Administration Office of Science & Research Affiliates Funding Source Medical Center Information Technology Office of Science & Research RESEARCH PROJECT Department Of Finance Office of Legal Counsel Office of Research Compliance Definition of a Clinical Trial Clinical trials are a subset of clinical research and must include the following factors in order to qualify as a clinical trial: 1. The objective of the study is either: a. testing of drugs, devices, diagnostics, treatments, interventions, or preventive measures including testing for an unapproved indication; OR b. data collection to increase knowledge that would lead to enhanced safety and efficacy of a specified drug or device; AND 2. The study must involve contact with humans or retrospective review of medical records, clinical data or specimens obtained from contact with humans Office of Clinical Trials – Our Role Facilitate clinical research by: – Developing and negotiating clinical trial agreements – Serving as liaison between investigators, administrative and service departments and sponsors – Billing and collecting for industry-sponsored clinical trials – Financial oversight and management of clinical trials – Ensuring billing compliance for trial services Primary OCT Functions • Review clinical trial proposals • Negotiate contracts with industry in conjunction with Legal Counsel • Negotiate trial budgets with Sponsor Organizations • Complete Medicare Coverage Analyses for both industry-sponsored and grant- sponsored clinical trials • Enter Financial and Physical matrix information into InfoEd CTMS Database • Route NYUMC research encounter information to ensure appropriate identification research subjects & procedures, and appropriate billing by NYU Hospitals Center • Invoice sponsor for services (initial and ongoing) • Collect revenue and deposit appropriately, including internal fees Office of Clinical Trials Areas of Expertise ADMINISTRATION PROJECT MANAGEMENT CONTRACTS NEGOTIATION COMPLIANCE REVIEW FINANCIAL ANALYSIS DATA BASE TECHNOLOGY Clinical Trial Agreements • • • • 180 New Agreements annually >600 Active Investigators 1500 Active Research Projects 350 Industry Sponsored/Supported Projects Total annual revenue from clinical trials: ~$8.3 million in FY 09 ~$9.3 million in FY 10 CONTRACT PROVISIONS reflected in the ICF • • • • • • • • Subject Injury Compensation Drug/Device Supply Confidentiality Intellectual Property Inventions Indemnification Insurance Budget Development INSTITUTIONAL COSTS EXPENSES • F&A • IRB Fees • Investigational Pharmacy • OCT Administration • Affiliate Fee Schedules • Research Team T&E • Procedures – Technical & Professional • Correlative • CTSI Office of Clinical Trials – Who we are: • Director: Jean Gatewood • Associate Director – Operations : Nicky O’Connor • Associate Director – Financial Management : Eric Koomen • Clinical Research Management Coordinators: – Ronnie Landis – Erica Epstein – Leah Caropolo – Lena Geffrard – Halley Rogers • Coordinator Clinical Trials: – Taslima Kamal • Financial Services: – Sue Leung • Contract Specialists: – Floyd Berry – Susan Shin Anderson • Compliance Review: – Sumathy Sundarababu • Project Associates: – Sunita Latchman – Rachel Joseph • Administrative Support: – Linda Verlin COMMENTS? THANK YOU Nicky O’Connor, BSN, MPH, CCRC Associate Director – Office of Clinical Trials New York University Medical Center 550 First Avenue – Bldg #VET 10th Floor – West Wing Room 10029W New York, NY 10016 Nicky.O’[email protected] 212 263-4210 – main office http://www.med.nyu.edu/oct/ New York University Technology Transfer at NYU Abram M. Goldfinger Executive Director, Industrial Liaison/Technology Transfer New York University Mission Statement Promote the commercial development of NYU technologies into products to benefit patients and society, while providing a return to the University to support its research and education missions. New York University Activities • • • • • Commercialization of NYU Technologies Research Support from Industry New Business Ventures Material/Data Transfer Agreements Education New York University Academic Technology Transfer • 1980 Bayh-Dole Act • Concerns about U.S. competitiveness. • Universities allowed to retain rights to inventions arising from Federally-funded research • U.S. manufacture, preference for small business • Government license, march-in rights • Activity – Approx. 600 new products introduced, 500 new companies formed, $50B in economic activity each year New York University NYU Patent Policy • Rights assigned to University • University responsible for patenting and licensing • Inventor(s) share in licensing income (42.5%) New York University Commercialization Process • • • • • • Invention Disclosure to Industrial Liaison Evaluate commercial potential Secure intellectual property protection Identify potential commercial partners Negotiate license and/or research agreement Manage ongoing relationship New York University Patents • Right to exclude others from making, using, or selling claimed invention for 20 years from application filing date • Cover new, useful, non-obvious inventions • Prior Art - Publications, abstracts, presentations, etc., prior to filing of patent application • First to invent (keep good notebooks) • Scope of protection (e.g., specific compound vs. class of compounds) • Changes in law New York University Trends • Larger companies interested in later stage technologies • University licensing to smaller or start-up companies who develop and later partner with large companies • Increased need for translational research New York University Applied Research Support Fund • Provides investments of up to $75K each (increased from $50K in FY09) in projects with commercial potential. • 34 investments to date. $1.6M invested. • 10 of 34 funded technologies subsequent licensed. • $15.2M in license income and $9.7M in corporate research funding generated. • Record 54 submissions in FY10. 8 projects awarded. New York University NYU Patenting Activity (Cumulative) • • • • • • 538 U.S. Patents Issued 312 U.S. Patents Licensed (58%) 337 U.S. Patent Applications Pending 286 Active License Agreements 24 Products brought to market 13 Products in clinical trials New York University Start-Up Activity • 50 companies formed • Over $1 billion raised • 6 companies public, 6 acquired New York University Recent Start-Up Companies Company Technology Alveologic Dental Devices Alzicon Alzheimer’s Treatment Atreaon Treatment for Inflammatory Diseases Brainscrope Brain Monitoring Technology Cardium Cardiovascular Gene Therapy Constellation Pharmaceuticals Epigenetics Research CynVec Cancer Gene Therapy HealthC’air CPAP Technology Lycera Treatment for Autoimmune Diseases MET MRI Technology NeuroControl Robotic Control Systems NeuroInterface Brain-Machine Interface Systems Perceptive Pixel Touch Screen Technology Spin Transfer Non-Volatile Memory (MRAM) New York University Multi-touch screen developed by NYU spin-off company Perceptive Pixel used as “Magic Wall” by CNN New York University Invention Disclosures New York University Licenses Signed New York University License Revenue (in millions) New York University Top 10 Universities in License Income (2004-8) (Source: Association of University Technology Managers) 1 New York University $1.3B 2 Northwestern University $896M 3 Emory University $653M 4 Columbia University $640M 5 Stanford University $611M 6 University of California System $579M 7 Wake Forest $305M 8 University of Rochester $294M 9 Massachusetts Institute of Technology $247M 10 University of Washington $229M New York University 2009 TT Activity Per $100M Research Expenditures US Universities NYU % Difference Inv. Disclosures 37.8 38.5 (+2%) Patents Issued 6.4 9.4 (+47%) New Licenses 9.6 12.3 (+28%) New Start-Ups 1.1 1.6 (+45%) $3.5M $36.6M (+646%) License Income New York University Products on Market • • • • • • • • • • • • • 24 products on market Remicade (RA, Crohn’s Disease, AS, UC, Psoriasis) Sutent (Kidney & Stomach Cancer) Zinecard (to reduce chemotherapy side effects) Oracea (Rosacea) HIV Diagnostics Vascular Stent MRI Equipment CPAP device for sleep apnea Hip Prosthesis Anesthesia Monitor Embolism Coil Dental Implant New York University Products in Clinical Trials • • • • • • • • • 13 Products in Clinical Trials DNA-Based Drug for Angina Drugs for Parkinson’s Disease Alzheimer’s Disease Drugs Anti-Cancer Compounds Anti-Addiction Drug Imaging Device for CNS Diseases Malaria Vaccine Wound Healing Compound New York University Conclusions • Activity (invention disclosures, patents, new licenses) has increased significantly in recent years. • Robust technology portfolio for future growth. • NYU research improving patient care. • Welcome opportunity to meet. • Contact us – www.med.nyu.edu/oil, (212) 263-8178. Introduction to the Institutional Review Board Helen Panageas Associate Director Institutional Review Board March, 2011 IRB Review made Simple Overview What is an IRB Review Type Determinations Types of IRB Review Categories of Review Informed Consent and Authorization Historical Events in Human Research 1944 -1980s US Radiation Studies 1932 - 72 Tuskegee Syphilis Study 1930 1935 1940 1945 1939 - 45 German Doctors Experiments Concentration Camp Prisoners 1950 - 1960s CIA Mind Trial 1950 1947 The Nuremberg Code 1955 1961 The Milgram Studies 1960 1956 - 1980s The Willowbrook Study 1966 Henry Beecher NEJM Article 1965 1974 National Research Act 1970 1964 Declaration of Helsinki 1981 DHEW Revises Federal Regulations 1975 1980 1989 NIH Training Required 1985 1979 The Belmont Report Trigger Events Nazi Experiments Holocaust 1933 to 1945 Nazi Doctors Performed Experiments on Concentration Camp Inmates; Without consent, During course of experiments committed the murders, brutalities, cruelties, tortures, atrocities, and other inhuman acts. 23 German doctors charged with crimes against humanity. Ethical Milestones Nuremberg Code Directives of Human Experimentation 1947 1. Voluntary Consent 2. Experiments should yield good 3. Good design and prior research in non-humans 4. Avoid risks when possible 5. No experiments where death is known risk 6. Risk should equal benefits 7. Minimize risks 8. Qualified personnel should conduct research 9. Subject must have right to withdraw 10. Scientist must be prepared to end trial when needed Trigger Event Tuskegee Syphilis Study U.S. Public Health Service 1932 to 1972, Examined the natural course of untreated syphilis in black American men. Impoverished sharecroppers from Alabama, Unknowing participants in the study; Not told they had syphilis, Not offered effective treatment. Ethical Milestone The Belmont Report National Commission for the Protection of Human Subjects • The Belmont Report (1979) • Respect for Persons – Informed Consent • Beneficence – Do No Harm • Justice – Equitable Selection of Subjects • Common Rule – 45 CFR 46 (1991) • Risk are minimized • Risk/Benefit Ratio is favorable • Subject Selection is equitable • Informed Consent • Data is monitored for safety • Protect Privacy and Maintain Confidentiality • Protect Vulnerable Subjects Institutional Review Board Group of Scientist, Non-Scientists and Non Affiliated Individuals Protect Human Research Subjects by Reviewing and Approving Research Required by Federal Regulations What is an IRB An IRB is a group that reviews research to ensure the rights and welfare of human subjects involved in research are adequately protected. There are four IRBs at NYU SoM How is Review Type Determined? Four Basic Questions: 1. Is the Proposed project Research? 2. Does the proposed project involve Human Subjects? 3. What type of Risk is involved in the proposed project? 4. Does the proposed project meet the criteria for the Review Category? Research is defined as a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. Human subject means a living individual about whom an investigator (whether professional or student) conducting research obtains: • • Data through intervention or interaction with the individual, or Identifiable private information. Does Your Study Involve Human Subjects? Risk Minimal Risk is defined as the probability and magnitude of harm or discomfort anticipated in the proposed research are not greater, in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests. Types of IRB Review Exempt Expedited Full Review Category? There are Different Categories within each Review Type. The Project must Fall within One of the Categories Full Review Project is NOT minimal risk. Project is Minimal Risk BUT does not meet EXEMPT or EXPEDITED CATEGORIES Informed Consent and Authorization Required Reviewed by a Full Convened Board Full Board Review Required Ongoing Annual Review Expedited Research Minimal Risk HHS regulations define - seven categories Informed Consent and Authorization – required or waived Reviewed at any time Full Board Review - Not necessary All criteria required for Full Board review Ongoing Annual Review Exempt Research HHS regulations define - six categories No requirement to obtain informed consent. Reviewed at any time Full Board Review - Not necessary Ongoing Annual Review - Not required (unless the research is changed so that it no longer meets the exemption criteria) Informed Consent on the Review Continuum Risk: Low Minimal Higher Review: Informed Consent: Exempt Expedited Full None May be Waived Required Criteria for IRB Approval Risks are Minimized Risks are Reasonable in Relation to Benefits Selection of Subjects is Equitable Informed Consent will be Sought Informed Consent will Be Documented Monitoring the Data Collected to Ensure Safety Protection of Privacy and Confidentiality is Maintained Protection of Vulnerable Subjects Consent Form Elements Statement that the study involves research Research is described Description of Risks Description of Benefits Disclosure of Alternatives Confidentiality If more than minimal risk, compensation and/or medical treatment Participation is voluntary Whom to Contact Waiver of Consent • Are waivers allowed? – Waiver of Informed Consent Minimal Risk Research, Waiver will not adverse effect rights, It is impracticable to obtain IC, When appropriate info will be shared – Waiver of Documentation of Consent Minimal Risk Procedure involved does not require written ICF OR Written ICF is only link to subject Other IRB Reviews Continuing Review Amendments Reportable Events Unanticipated Problems involving risk Safety Reports that indicate potential risk Noncompliance Incarceration of Subject Study Closure Q&A QUESTIONS? Contact Us IRB Main Office Location: 423 East 23rd Street, VA Building, 10th floor, West Wing Office Hours: Monday - Friday, 8:00 am - 5:00 pm General Information: [email protected] Phone: 212-263-4110 Fax: 212-263-4147 Exploring Research Compliance Issues Human Subjects Research at NYU Langone Medical Center Presented by: Keisha A. Lightbourne, JD, MHA, CHC Director, Office of Research Compliance Director, Conflict of Interest Management Unit Objectives Getting to Know ORC Understanding what ORC does at NYULMC Understanding Research Compliance Concepts for Human Subjects Research Agenda General Principles for Performing Research at NYU Managing Research Data Responsible Conduct of Research Conflicts of Interest Board of Trustees Dean/CEO Annette Johnson General Counsel Nancy Dean VP Of Audit & Compliance Director of Research Compliance Conflicts Management Unit Office of Research Compliance Responsibilities Oversight of all offices that deal with Research Programs at NYULMC IRB SPA Post Award Finance Research Misconduct Environmental Health & Safety Radiation Safety IACUC DLAR IBC ESCRO Operational administration of the CMU Performing Research At NYU Langone Medical Center Research performed by NYU School of Medicine (not NYU Hospitals Center) NYU School of Medicine is separate from New York University for sponsored research purposes Research administered by Office of Science & Research via SPA Principal Investigator responsible for the compliant conduct of research. General Principles of Performing Research Research is intended to impart knowledge enlarge humanity’s store of knowledge. Results of research must be made available to the general public on a nondiscriminatory basis. NYU does not conduct secret or classified research. Investigators must be able to publish research results without prior approval of sponsor. **Failure to adhere to these rules could put non-profit status at risk and/or put tax-exempt status of NYU’s bonds at risk** Managing Data Retention & Access to Research Data Under Medical Center’s Policy on Retention of and Access to Research Data: • Research data means any recorded, retrievable information, necessary for the reconstruction and evaluation of reported results of Research Some examples include: laboratory notebooks case history records filed specimens computer files or other electronic data software programs and databases cell lines Managing Data Retention & Access to Research Data Under Medical Center’s Policy on Retention of and Access to Research Data: • Principal Investigator is responsible for collecting and maintaining research data • Research Data must be retained for AT LEAST from: three years after the final project close-out or five years after the final reporting or publication or may be longer per policy • Data owned by NYU • Transfer of data from NYU requires approval Managing Data Freedom of Information Act (FOIA) FOIA defines federal agency records subject to disclosure upon public request, outlines mandatory disclosure procedures and grants nine exemptions. FOIA applies for records related to federal sponsored research. Nine categories of records exempt from mandatory disclosure; some of which apply to research. Managing Data HIPAA Privacy Protected Health Information (PHI) is not accessible for RESEARCH without the patient’s written authorization Unless PHI access is “preparatory to research” Use or disclosure is solely to view PHI necessary to prepare a research protocol or similar purposes to prep for research The PHI cannot be removed from the premises in the course of the review The PHI for which use or access is requested is necessary for the research Options – De-Identified data ≠ PHI Limited Data Set & Data Use Agreement Research on Decedents (not Human Subjects’ Research) Managing Data HIPAA Security Make Passwords Strong & NO sharing Walking Away? Remember to Log Out…Each Time! Save PHI data on shared drives (not local ones) Do not email PHI outside of NYULMC (without secure messaging) Do not leave paper records containing PHI out and accessible Double check fax # before faxing PHI Use NYU OnsiteHealth to access PHI when away Encrypt USBs, Laptops & SmartPhones For potential violations call 1-800-PHI-LOSS Responsible Conduct of Research Research must be conducted and results published with the highest standards of ethical conduct, truth, and accuracy, and must be free of appearance of impropriety or conflict of interest. Public Health Service Policies on Research Misconduct at 42 C.F.R. 93 • NYU policy, research misconduct means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. • Purpose: Protect the accuracy, reliability, and integrity of the research Responsible Conduct of Research A finding of research misconduct requires Significant departure from accepted practices Committed intentionally, or knowingly, or recklessly Proven by a preponderance of evidence • Four phase process for Review Assessment Inquiry Investigation Adjudication which may lead to sanctions up to and including disbarment Responsible Conduct of Research The responsible conduct of research requires careful consideration of the following: Responsible Authorship The Mentor-Trainee Relationship Responsible Data Management Responsible Collaboration Conflicts of Interest For more information, see the Office of Research Integrity’s Guide: http://ori.dhhs.gov/documents/rcrintro.pdf Conflicts of Interest Research at the Medical Center must be free of the appearance of conflict Under Medical Center’s Policy on Conflicts of Interest in Sponsored Research and Sponsored Programs: A conflict of interest in research may occur whenever an investigator has a personal financial interest in a party affected by the research. All investigators in all studies must complete disclosure form. All disclosed interests will be reviewed for all studies. When the financial interest is significant, review will be made by a faculty Research Conflicts of Interest Committee (RCOIC). The RCOIC will permit the conflicted investigator to participate in the research only if compelling circumstances are present and the research is subject to a plan which effectively manages the conflict. Conflicts of Interest – The Mechanics Annual Disclosure using http://eresearchadmin.nyumc.org At submission of a grant application/IRB using the Investigator Financial Disclosure Form and the Supplemental Form if “yes” checked on the Investigator Form Both can be found at http://cimu.med.nyu.edu Conflicts of Interest Institutional Under Medical Center’s Policy on Institutional Conflicts of Interest in Human Subjects Research: • an institutional conflict of interest (ICOIC) occurs if NYU or the Medical Center has an equity interest in a research sponsor of, or an IP interest in an investigational product being used in, a human subjects’ research project. • If an ICOI exists, the research will not be permitted to proceed without a compelling circumstances finding by the RCOIC. Institutional Conflicts of Interest- The Mechanics Proactive review is the best way to avoid ICOI Creating a protocol that uses NYU IP? To find out request access to the master list at http://cimu.med.nyu.edu/policies/conflicts-interestresearch-/institutional-conflicts-interest-list Questions? Keisha Lightbourne, JD, MHA, CHC 212-404-4070 REPORT COMPLIANCE VIOLATIONS TO 1-866-NYU-1212