Following the receipt of clarification from the MHRA on access to the investigator TMF, the Q&A document that was generated following the European TM Summit has been revised. The document has been updated as follows.
“Slides were based on the draft of the TMF guidance at that time. The Q&A question 27 answer is compatible and clarifies why remote access to such information would not be acceptable. The guidance since then has been subject to some revisions. For remote access, the following is now stated:
‘Remote access by sponsor or CRO personnel to the investigator TMF should only be possible to the documents where personal data that enable the data subjects to be directly identified (i.e. direct identifiers of trial subjects) is not present or has been pseudonymised’.”
The full Q&A document is available to download from our Resources page.
Final reminder that our next free Exchange Mechanism Standard (EMS) webinar is on Thursday December 13 at 7am PT, 10am ET, 3pm UTC, 4pm CET, kindly hosted by Wingspan Technology (an IQVIA company). Learn about the key success factors facing life sciences professionals in embracing the emerging TMF Exchange Mechanism Standard.
Register directly by clicking HERE.
We are delighted to announce the launch of version 1 of the eTMF Exchange Mechanism Standard to support eTMF transfer during the DIA Annual Meeting in Boston, USA.
To mark this occasion, DIA have kindly provided facilities during the DIA Annual Meeting in Boston. Paul Fenton, Elvin Thalund and Karen Roy will be presenting the TMF Reference Model and the eTMF Exchange Mechanism Standard. The TMF vendor community involved in the eTMF Exchange Mechanism Standard will also be present and have kindly agreed to contribute towards drinks and snacks!
The meeting will be at 5.30 pm until 7.00 pm on Tuesday June 26 in the Otis Room at the Westin Boston Waterfront Hotel. This meting is not restricted to conference attendees; anyone with an interest in the Exchange Mechanism Standard is welcome to attend.
So that we have an idea of likely attendance, please let us know using the form below if you are interested in attending this launch event.
The TMF Plan Template Subgroup of the TMF Reference Model Project is pleased to announce that the TMF Plan Template version 1.0 is now available for use. You can download this free of charge from our Resources web page.
The purpose of a TMF Plan is to leverage TMF expectations between sponsors and relevant TMF stakeholders (e.g., CROs/vendors) to ensure delivery of a high quality TMF, and that what is expected from all concerned parties (CROs, vendors and sponsors) is clearly defined. The complexity of the TMF is an all too familiar reality in clinical trial conduct. The delegation of varied responsibilities to CROs/vendors, each with their unique internal procedures, necessitates careful planning for managing TMFs. What is the structure of the TMF and where will it be located? What is the procedure for filing essential documents and how will access to the TMF be granted to those who need it? These are just some of the questions that we hope can be answered by adopting the TMF Plan template. Rather than attempting to create your TMF Plan from a blank page, the TMF Reference Model Project are making available this template that you can use as your starting point.
It is important to note that this TMF Plan Template has been written to cover both sponsor and investigator TMFs but is easy to adapt if your organization has separate, documented procedures for each type of document.
The template includes green text which is there to provide guidance to the user on how to best adapt the TMF Plan depending on the type, size, complexity of the clinical trial. As such, it should be taken as a recommendation on how the template can be used, rather than how it should be used. Users of the template are highly encouraged to adapt the document to complement their needs and to cross-reference internal SOPs or other written procedures rather than duplicating the text within this plan.
Whereas many questions have been considered, and hopefully addressed, we are well aware that this first version of the template may not be perfect and can be improved based on your feedback as you begin using it. This is the start of a conversation and we really want to hear your feedback as you begin using it.
To provide feedback please use the form that you can access at the following link: https://goo.gl/forms/fX2xmD1ACOJSCiVy2. This link is also published on our Resources page.
It was recently noted by one of our very observant users that the Milestones worksheet included eight artifacts for which milestones were not suggested! Once we were made aware of this gap, the milestones team very rapidly reviewed these eight artifacts and assigned milestones. The revised worksheet (v1.1) has now been approved by the Steering Committee and is available to download from the Resources page.
Many eTMF systems now included milestone assignments for each artifact so you should find this tool helpful to check your system configuration. In addition, the worksheet can be extremely helpful to assist with manual QC and completeness checks of paper TMFs. We have seen a great example where a sponsor has created trial, country and site level checklists for each milestone, based on the TMF Reference Model worksheet. These provide an invaluable tool to study team members who need to know which documents to check for at each filing level and at each milestone.
The DIA Document & Records Management Community completed an initiative in 2012 to define a Framework for the Destruction of Paper. The results have been widely published and used by many companies to define policies and SOPs for document retention, retrieval and destruction. Many colleagues on the TMF Reference Model project participated in this initiative. We have noticed that some rules within the regions have changed over the past 5+ years (e.g. what is a certified copy) and we feel it is time to Review, Assess, and Update the current recommendations and provide a new version of the framework. Understandably, we are curious about the experiences that you/the industry have had with the Framework. We would like to understand where it has been a success, and where changes should be made to make that Framework more useful.
An effort is being organised to accomplish these objectives to be conducted during 2018. At this point, we anticipate the effort will include 3 phases:
1. Survey our experience and progress to date
2. Upgrade the Framework to include regulatory and best practices updates and other desirable changes.
3. Formulate recommendations and a toolkit for implementation.
Each of these phases have an expected timeline that overlaps the others to some extent. We would like to initiate the survey phase in January and complete it by the end of March. We welcome members to join the initiative and participate in one, two or all 3 of the phases dependent upon your availability and expertise. It is possible you were involved in the original project and it would be great to have you back on board, either on the same sub-team or perhaps a different sub-team this time round. If you weren’t previously on the team, it would also be great to have you on board too!
The teams will be organized according to the following areas. Please respond with your choices of where you would like to participate.
- Survey (assess experience to date and future needs)
- Records Management
- Legal Requirements
- Implementation Toolkit
Please respond via the Contact Form below. Thank you.
Please note: the scope of this initiative is not limited to trial documents but is shared here as it will be of interest to the TMF Reference Model community.
The eTMF Exchange Mechanism Team – a sub-group of the TMF Reference Model project – has been working on a standard1 for the transfer of TMF data between different eTMF systems for around three years. The objective is to define a simple standard that could be used in a number of scenarios:
- Final export of eTMF content for archiving;
- Interim transfer of eTMF to a central eTMF or other document repository;
- Migration of eTMF during mergers/acquisions;
- Migration of eTMF for system upgrades or change;
- Final transfer of eTMF content from third party (e.g. CRO) to sponsor.
We are very pleased to announce that the draft standard is now ready for industry review (see schedule – click for larger image).
A technical team has already been established for the technical review of the standard. This comprises representatives from companies such as Veeva, TransPerfect, Phlexglobal, Montrium, MasterControl, Arisglobal, Wingspan/IQVIA, goBalto, OpenText and Navitas. This team will be focussed on reviewing the metadata structure, XML definitions and structure, and adaptability and utility from a technical perspective.
The Exchange Mechanism team are now looking for volunteers to participate in a business review of the standard, looking at how well the specification as a whole would satisfy business needs. Volunteers will be invited to a one hour orientation meeting in December to get insights on the review and feedback process. The estimated total effort for the meeting, your review and submission of feedback is four to six hours over a 6 – 8 week period.
To join the team and become a business reviewer, simply register online and select “Exchange Mechanism” from the list of active work groups. You must have the time available to participate; there will be other opportunities for you to have visibility of the draft specification if this is your only reason for joining!
1Standard: the term is used here in its general sense i.e. “used or accepted as normal or average; viewed as authoritative and so widely read”. Currently, the specification will not be authorized or published by a recognized standards body, though this may be considered at a future time. Following the closure of the OASIS eTMF Technical Committee prior to finalization of an eTMF standard, this is the only eTMF technical standard under development at this time and has the support of all major eTMF vendors.