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Tougher HIPAA Rules around HITECH

BayBiotech.NET The Health Information Technology for Economic and Clinical Health Act ( HITECH), intended to promote adoption of information technology for maintenance of electronic health records and incorporated into the American Recovery and Reinvestment Act of 2009, was signed into law on Feb. 17, 2009. The key points of the provisions are: 1. Tracking the medical information disclosure: According to the new legislation, physicians will be required to track any disclosure of a patient's medical information. Previously regulations allowed physicians to disclose patient information for the purpose of treatment, billing or health care, but they were not required to track when that information was disclosed. This provision kicks in for current users on Jan. 1, 2014, and then patients will be able to request an accounting of disclosures of their electronic personal health information three years from the date of the request, potentially dating back to 2011. 2. Rules regarding s

Globalization of Clinical Trials

BayBiotech.NET When ICH was conceived in 1999, it was for a good cause understanding that it will have harmonization on guidelines for conduct of a clinical trial worldwide as it brought together European Union, United States and Japanese experts together to draw a set of standards that would streamline the clinical research globally. Out of thirty-eight topics (Guidelines) originally identified, only the ICH E6 document relates to the standards of Good Clinical Practice. Since, the EU Directive were set in place for conducting a clinical trial in UK and European member states it is not only ICH E6 but also EU GCP Directive 2001/20 and 2005/28 that is required to be followed which gives a higher standard than ICH E6 alone. Apart from these directives, member states of the European States have their local laws that are also incorporated into the GCP conducts. This further complicates the conduct of clinical trials and acceptance of global data because if a member state selects a site

Conducting Audits for Contract Research Organizations (CROs)

BayBiotech.NET Performing site visits to your CROs for compliance audits at certain time intervals ensures the integrity and quality of data you are receiving for the clinical research. Sponsor audits also set stage for engaged CROs to prepare for direct FDA audits and leads to increased chances of success. Audits may be either routine audits to check the facilities for compliance or may be based on the performance or any non-compliance issue that may have come in the highlight during the course of the study. In either case an audit provides CROs with timely opportunity to take corrective and preventive action measures and makes the CRO facility aware of sponsor’s vigilance leading to compliance on their part as well as best outcomes of financial investment for the sponsor. Before performing an audit, an audit plan must be drafted by the auditor specifically preparing a check list of the items or issues that are recognized as critical steps of the procedures performed at CRO sites.

Implementing Quality Management Systems for FDA Environment

BayBiotech.NET A quality management system (QMS) is a collective term for a management framework comprising of policies, plans, practices, and the supporting infrastructure by which an organization aims to reduce, eliminate and maintain non-conformance to specifications, standards, and customer expectations in the most cost effective and efficient manner. Quality management systems are relevant especially for healthcare/ Biotech/Pharmaceutical industry that are regulated by FDA. All organizations whether large or small, public or private, manufacturing or service oriented are benefited by implementing a quality management system. Although a small company may have an in-house developed QMS system to manage the compliance and meet the production specifications for internal as well as external regulatory requirements, eventually it becomes difficult to manage the same in larger companies or multinationals. As it is obvious that for best results QMS must be implemented globally in an or

What to include in Traditional 510(k) Filing for Medical Devices

BayBiotech.NET A 510k is a premarket submission made to FDA to demonstrate that a medical device to be marketed is at least as safe and effective, that is, substantially equivalent, to a legally marketed device. A Traditional 510(k) submission must include the required elements as per 21 CFR 807.87 (Information required in a premarket notification submission):  the name of device, (the trade or proprietary name), if any, and the common or usual name or classification name of the device.  description of the device, include device specifications and reference applicable guidance documents, special controls, or standards; photographs or engineering drawings should be supplied, if applicable.  comparison with a predicate device(s), indicating similarities and/or differences accompanied by data, as appropriate; this information may include an identification of materials, design considerations, energy expected to be used or delivered by the device, and a description of the operatio

Nanotechnology Interest Group

BayBiotech.NET As per definition of National Technology Initiative, nanotechnology is the understanding and control of matter at dimensions between approximately 1 and 100 nanometers. Encompassing nanoscale science, engineering, and technology, nanotechnology involves imaging, measuring, modeling, and manipulating matter at this length scale. According to NTIG at this scale unusual physical, chemical, and biological properties can emerge in materials and the properties may differ in important ways from the properties of bulk materials and single atoms or molecules. Recognizing a great potential for this technology for drug delivery/ device in medicine, in July 2007 FDA issued a press release outlining the regulatory challenges that the implementation of the technology will have for the agency and geared up towards developing guidance as well as regulations to address the benefits and risks of drugs and devices using nanotechnology. As it is obvious, development and Implementation of

International Compilation of Human Research Protections 2009 Edition

BayBiotech.NET Office for Human Research Protections (U.S. Department of Health and Human Services) has compiled a list of 1,100 laws, regulations, and guidelines governing human subject’s research in 92 countries, as well as standards from a number of international and regional organizations. This 85 pages list has been developed for IRBs/Ethics Committees, researchers, sponsors, and others who are involved in international research with a purpose to help these groups familiarize themselves with the laws, regulations, and guidelines where the research will be conducted, to assure those standards are followed appropriately. The 2009 Edition is the latest updated version that includes numerous additions and updates to the 2008 Edition, and further includes the laws, regulations, and/or guidelines for 7 new countries: Burma (also known as Myanmar), Egypt, the Gambia, San Marino, South Korea, the Sudan, and Vietnam. If you are clinical research personnel and would like to get the l