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Protocol deviation waiver request process

Introduction

A protocol deviation is a subject specific variation from the study design or procedures defined in the approved protocol. It is not implemented or intended as a systematic change. A protocol deviation waiver can be defined as the sponsor's approval for a prospective protocol deviation. Such deviations often involve (but may not be limited to) the recruitment of a subject who does not meet all eligibility criteria as detailed in the protocol.


Waiver Request for a Protocol Deviation

This protocol deviation process exists of different steps:

Request a

protocol deviation

waiver (Site)

If the result for an eligibility test is false, a PI can request a waiver for that subject. 

To do so, a reason must be provided. Then click the 'Request a Protocol Deviation' button.

The request is submitted to the sponsor. The PI can still:

    • Add more information to the request by pressing the 'Add Message' button;
    • Or discontinue the request while request, while it is still in consideration with the Sponsor, if the deviation becomes obsolete. A reason has to be provided.


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Answer on a

protocol deviation waiver 

Waiver Request (Sponsor)

The tab 'Protocol Deviations' in the Clinical Data module is designed to have an overview of all requested waivers.It  It lists all protocol deviation waiver requests for all Studies studies in which the user has the right to manage protocol deviation waivers in different statuses:view/manage the eCRFs.

The different sections are

  • Outstanding protocol deviations (waiting an answer from the Sponsorsponsor);
  • Protocol deviations waiting site confirmation;
  • Closed protocol deviations;
  • Discontinued protocol deviations.

The sponsor can take for each false criterion one of the following decisions:

  • The protocol deviation waiver can be acceptedgranted;
  • The protocol deviation cannot be acceptedwaiver can be declined;
  • More clarification can be requested.

If all false criteria are overridden, the general result is also overridden.

After that the confirmation by the Sponsorsponsor, the Site site will see the decision taken in the corresponding activity in the Study Flow.

Confirm the protocol deviation waiver (Site)

If the waiver is granted ('false' result overridden), the Site site is able to decide with which result they continue.

  • The granted deviation can be accepted by the Sitesite. The Subject subject can then continue as if the result was true.
  • In some situations, it might be in the benefit of the Subject subject to continue with the 'false' result, even if the waiver was granted. The Site site then declines the deviation granted; a clarification will be needed.
    (green star)Based on new information, received after the waiver, the Site site decides it is in the benefit of the patient to start other treatment.

View protocol deviation requests

For users with ClinicalData.StudyRead rights, it is possible to see a list of protocol deviations by Study, Subject and status of the waiver (outstanding, waiting site confirmation, closed or discontinued).

All protocol deviation requests of Subjects in Studies a user has read access to will be shown. The list can be filtered on Study.

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Information

  • Outstanding protocol deviations are those waiver requests that are requested by the Site, but for which the Sponsor did not take any decision yet;
  • Protocol deviations waiting Site confirmation are those waivers that are decided (granted or not) by the Sponsor, but for which the Site did not acknowledge or decline yet;
  • Closed protocol deviations are waivers that are acknowledged by the Site;
  • Discontinued protocol deviations are waivers that the Site declined.