Proposal for HIQA’s role as Ethics Committees Supervisory Body (under the clinical trials legislation)

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    Proposal for HIQAs role as

    Ethics Committees Supervisory Body

    (under the clinical trials legislation)

    Grace CunninghamResearch Ethics Manager

    Health Information and Quality Authority

    12 March 2013

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    Draft plan for role of Authority as Supervisory

    Body of RECs under the clinical trials legislation

    Draft plan only stakeholder feedback being soughtat this stage

    Various models of research ethics governanceanalysed

    There has been some consultation on the draft plan

    to date with the Department of Health, the IrishMedicines Board, the Research Ethics AdvisoryGroup and with the 13 Recognised Committees

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    Overview of legislation relating to clinical trials

    A. Existing clinical trials legislation

    Statutory Instrument (SI) 190 of 2004 transposed European Directive2001/20/EC (this has since been amended with several amending SIs)

    Minister of Health is Supervisory Body of RECs

    B. Expected Statutory Instrument to amend the existing legislation

    Transfer of role of Supervisory Body to HIQA Timeline for implementation of Statutory Instrument ~ Q3 2013

    C. European Commissions proposal for a new Regulation on ClinicalTrials (repealing 2001/20/EC Directive)

    Timeline for implementation 2016

    HIQA to commence preparatory work during Transition Phase

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    Two phased plan

    Because the clinical trials legislation is now expectedto change twice over the next 3-4 years, the

    Authoritys plan for clinical trials involves 2 separate

    phases: Transition Phase - to begin with the Authority

    taking on the role of Supervisory Body via anamending Statutory Instrument to the existing

    legislation, and lasting ~18-24 months Phase 2 - to be in operation in advance of

    commencement of the new Regulation

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    Overview of legislation relating to clinical trials

    A. Existing clinical trials legislation

    Statutory Instrument (SI) 190 of 2004 transposed European Directive2001/20/EC (this has since been amended with several amending SIs)

    Minister of Health is Supervisory Body of RECs

    Transition PhaseB. Expected Statutory Instrument to amend the existing legislation

    Transfer of role of Supervisory Body to HIQA Timeline for implementation of Statutory Instrument ~ Q3 2013

    Phase 2C. European Commissions proposal for a new Regulation on Clinical

    Trials (repealing 2001/20/EC Directive)

    Timeline for implementation 2016

    HIQA to commence preparatory work during Transition Phase

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    Transition phase

    This will be first legal remit for Authority in this area

    Proposing a simple system initially:

    13 RECs to continue to receive applications directly duringtransition phase

    Co-operation / info sharing between RECs and HIQA

    HIQA to track applications HIQA as point of contact for communication between RECs

    & IMB

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    Preparing for the Transition Phase with the

    existing 13 Recognised RECs

    Authority to engage and collaborate with each of the13 currently recognised RECs

    Obtain information, e.g. REC composition, meeting schedules etc Prepare together for go-live with HIQA taking over role of

    Supervisory Body

    Provisional / transitional recognitions (i.e. the13 RECs will automatically be recognised by HIQAinitially)

    with provision for HIQA to subsequently revoke recognition asprovided for in the existing legislation

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    Process map of Transition Phase

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    Phase 2 overview (continued)

    Phase 2 has not yet been scoped in detail. However, thefollowing are some main points in relation to the generalplan for Phase 2:

    the Authority (potentially using an appointing panel) willestablish a pool of ~ 40 individuals from whom an

    appropriately constituted committee can be establishedon a ~ weekly basis

    it is hoped that the expertise on the existing committeeswill be retained by encouraging current members to join

    the pool the Authority will provide facilities and administrative

    support for the committee meetings

    the Authority will communicate with both the IMB and the

    sponsor (where appropriate) on behalf of the REC.

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    Further details of proposed Phase 2

    Training and education sessions for REC members

    Standard operating procedures (SOPs) to be developed

    System for appeals to be implemented

    System for site-specific assessments to be addressed

    European Commission beginning process of developmentof an information system (portal) for clinical trials, incollaboration with Member States

    Potential developments discussed at recent EFGCPmeeting include a European-wide system foraccreditation of sites and investigators

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    Next Steps

    Receive feedback from stakeholders on the draft two-phasedplan

    Continue meetings with the Department of Health in relationto content and timelines of forthcoming legislation

    Continue meetings / collaboration with the IMB

    Continue participation in relevant national and Europeanmeetings and workshops

    Collaborate with each of the 13 recognised RECs

    Develop the necessary IT functionality to support proposedmodel

    Enactment of Statutory Instrument -go-live TransitionPhase

    Prepare for Phase 2

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    Please note that this proposed model relates to clinicaltrials only and does not include other research at this time

    However, it is expected that HIQA will take on a regulatoryrole in research ethics in relation to other health and socialcare research involving human subjects, under the HealthInformation Bill (except for research involving Medical

    Devices) - the timeline for this is not yet known. It is also thought that HIQA could take on a role similar to

    Supervisory Body in relation to RECs which review researchinvolving medical devices (currently awaiting clarificationfrom the Department of Health on if / how this could come

    under the remit of HIQA). In the current draft of the Human Tissue Bill there is

    provision that approval for research under the Bill may needto be given by an approved REC this could potentially be aHIQA-approved REC.

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    Questions/Comments?

    Feedback on the Authoritysdraft 2-phase plan sought from all

    stakeholders.

    Please submit comments to

    [email protected] 8 April 2013