Health Canada published two guidance documents aimed at improving clinical trials for medical devices and medicines during the COVID-19 pandemic.
New trials
To reduce regulatory burden, Health Canada has developed a new regulatory pathway, the interim order for clinical trials for medical devices and drugs relating to COVID-19. Sponsors of clinical trial applications for COVID-19 must indicate if they are filing the application under this new pathway:
- in the cover letter and
- on the revised 3011 form
Ongoing trials
Sponsors of a current trial must document the measures they took to stop or lower the risk of becoming infected with COVID-19. Any changes to the protocol or status of the study should consider:
- the burden on resources due to the COVID-19 pandemic
- whether participants are at high risk of contracting the virus and
- whether these changes still allow adherence to public health recommendations
Plans to add extra study sites and recruit more people may need to be halted.
Sponsors who cancel a trial or temporarily stop or halt recruitment should:
- note the reasons for doing so in the study records
- inform Health Canada using a clinical trial application notification (CTA-N)
- retrain trial staff if the trial is halted for a few months
Monitoring
Assess whether other safety assessment methods are possible when participants are unable to come to the investigational sites as specified in the study protocol.
If alternative monitoring is done, careful documentation will be required to capture:
- the reason why it was done
- the method used to collect the information
- the types of data that were collected
- who provided the information
- how the source of the information was verified
You will not need to submit a protocol amendment.
Protocol deviations
For clinical trial sites:
- ensure there is a system in place to identify, document, assess and report all protocol deviations to the sponsor and research ethics board in accordance with their own requirements
- document these deviations to make it easier to analyze the study findings in the future
For sponsors:
- define and identify the protocol deviations to be reported (you will not have to report these to us individually unless the deviations may place participants at risk)
- consider alternate methods to prevent protocol deviations and document the reasons for these deviations
- submit a clinical trial application amendment when changes to the protocol meet the definition of a clinical trial amendment (don’t file repeated deviations)
- consider submitting at regular intervals a cumulative list of deviations occurring in a particular study, rather than individual notifications
For detailed guidance on complying with the regulations, please see Health Canada guidance for Part C, Division 5 of the FDR “Drugs for Clinical Trials Involving Human Subjects” (GUI-0100).
For more information, please visit the Health Canada website.
Meditrial can help, Contact us now
Meditrial has developed rapid workflows to conduct risk assessment, implement rescue plans and execute solutions for ongoing clinical trials:
- Identify patients requiring follow-up
- Conduct investigator and study nurse calls for training to address the situation
- Obtain authorizations for decentralized data collection
- Support to patients for alternative access to needed care
- Prepare procedures and worksheets for remote collection of patient clinical data
- Monitor work instructions and trainings for site support and remote monitoring
- EDC and ePRO solutions to enable study continuity
- Privacy protection measures
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