E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials E-Consents 101 – The Why, How and Watch-Outs of Moving to Electronic Consent for Clinical Trials E-Consents 101 – The Why, How and Watch-Outs of Moving to Electronic Consent for Clinical Trials Timothy J. Kelly, MS, MBA Vice President Dialog Medical, a Standard Register Healthcare Company Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 1 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Electronic Consents Does(do) the facility(ies ) that you are associated with automate their clinical consents? • Survey question – Yes – 5% Unsure – 2% 2012 ACRP No Conference Yes Parrington DJ, Kelly TJ. Automate Consent to Enhance Safety and Efficiency of Clinical Trials. ACRP 2012 Global Conference. Orlando: April 16, 2012. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL No – 93% Unsure N=43 Page 2 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Why Consider Moving to an Electronic Consent Process for Clinical Trials and Research Studies? Benefits of an E-Consent Process Background: Clinical Consents • A review of 540 written consent forms, from 157 hospitals, found the necessary elements of informed consent (purpose, risks, benefits, & alternatives) in only 26% of the documents. Bottrell MM, et al. Archives of Surgery. 2000;135:26-33. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 3 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Benefits of an E-Consent Process Background: Clinical Consents • A review of 89 written consent forms for radical prostatectomy: – The potential need for blood transfusion was disclosed on 88.8% of the consent forms. – HOWEVER, proper consent for blood products was ONLY obtained in 25.8% of the cases. – 92.1% of patients ultimately received a transfusion. Issa MA, et al. The Journal of Urology. 2006;176:694-699. Benefits of an E-Consent Process Automating Clinical Consents Percent of Consents Meeting Each Criteria Traditional 100% (paper) consent process 80% Automated consent process 40% 100% 100% 100% 88% 60% 20% 0% O’Hara R. Electronic Support for Patient Decisions – Automating and Integrating the Informed Consent Process. TEPR ’05 Annual Conference. Salt Lake City: May 17, 2005. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL 92% 6% Consent in the EHR Accurate Note in the EHR Treatment Description Present Page 4 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Benefits of an E-Consent Process Automating Research Consents Percent of Consents Audit of 2,768 research consents completed 1/1/08 through 5/31/11 Parrington DJ, Kelly TJ. Automate Consent to Enhance Safety and Efficiency of Clinical Trials. ACRP 2012 Global Conference. Orlando: April 16, 2012. 100% Observed issues with paper consents Expected results with an automated process (not measured) 97% 100% 100% 89% 95% 100% 80% 60% 40% 20% 0% Consent in the EHR Accurate Note in the EHR Consent is Error-Free Benefits of an E-Consent Process What is the total issue rate with your research consents – include form deficiencies, filing issues and problems with any supplemental notes? • Survey question – 40% N=38 30% 2012 ACRP 20% Conference Parrington DJ, Kelly TJ. Automate Consent to Enhance Safety and Efficiency of Clinical Trials. ACRP 2012 Global Conference. Orlando: April 16, 2012. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL 10% 0% <5% 10-15% 20-25% 5-10% 15-20% >25% Unsure Page 5 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Benefits of an E-Consent Process Automating Clinical Consents • No missed sections – Data fields – Signatures – Dates/times • Access limited to appropriate personnel Benefits of an E-Consent Process Ability to Deliver Collateral Material • Brochures • Images • Video • Links to interactive websites Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 6 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Benefits of an E-Consent Process Sharing and Storage Flexibility • Print • Email • Save to EHR and/or other systems Benefits of an E-Consent Process Support “Green Initiatives” The VA’s automation of clinical contents and patient education materials saved 1,600 trees in 2011… Blum-Eisa L. Executive Insight. Posted 2/13/2012. http://healthcare-executiveinsight.advanceweb.com/Features/Articles/TheGreen-Side-of-Patient-Safety-Efficiency.aspx. (Accessed 2/28/2013). Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 7 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Benefits of an E-Consent Process Support “Green Initiatives” …Automating clinical trial consents would be equivalent to saving an additional 500 trees each year. Parrington DJ, Kelly TJ. Automate Consent to Enhance Safety and Efficiency of Clinical Trials. ACRP 2012 Global Conference. Orlando: April 16, 2012. E-Consent Options Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 8 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials E-Consent Options Home-grown Systems • Word / SharePoint • Adobe Professional / Secure Server1 1 Goldsmith L. An (Almost) Paperless, (Almost) Free Clinical Trial Management System. ACRP 2012 Global Conference. Session S027. April 14, 2012. [See also S006, Monday at 2:45pm.] E-Consent Options E-Forms Solutions Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 9 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials E-Consent Options Automated Informed Consent Solutions E-Consent Options Electronic Health Records • 405 EHR Vendors Source: Green C. Numbers Don’t Lie – The EHR Market Must Consolidate. The Health Care Blog. August 6, 2012. thehealthcareblog.com/blog/20 12/08/06/numbers-dont-liethe-ehr-market-mustconsolidate/ (Accessed 2/28/13). Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 10 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Watch-Outs Watch-Outs: Adoption of HIT Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 11 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Watch-Outs: Adoption of HIT Hospital Adoption of EHR Systems has more than Tripled Since 2009 Charles D, King J, Patel V, Furukawa MF. “Adoption of Electronic Health Record Systems among U.S. Nonfederal Acute Care Hospitals: 2008-2012,” ONC Data Brief, no 9. Washington, DC: Office of the National Coordinator for Health Information Technology. March 2013. Watch-Outs: Privacy and Security HIPAA Complaints Lodged with OCR (Through Jan. 31, 2013) 1,100 1,000 900 800 700 600 500 400 300 200 100 N D 2010 J F M A M J J A 2011 S O N D J F M A M J J 2012 A S O N D J 2013 HIPAA & Breach Enforcement Statistics. Produced by Health Information Privacy/Security Alert. Melamedia, LLC. www.melamedia.com/HIPAA.Stats.home.html (Accessed 2/28/13). Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 12 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Watch-Outs: Privacy and Security Top Reasons for HIPAA Breaches Under HITECH • Theft • Unauthorized Access/Disclosure • Loss • Hacking/IT Incident Source: Health Information Privacy/Security Alert Analysis of HHS Office for Civil Rights Data as of February 17, 2013. www.melamedia.com/HIPAA.Stats.home.html (Accessed 2/28/13). Watch-Outs: e-Signatures Electronic Signatures • Ensure date and time stamps • Verifiably bound to document • Complete audit trail • Full document security • Consider hand-drawn signatures for subjects Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 13 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Watch-Outs: e-Signatures Electronic Signatures • Witness/attestation signatures may be helpful • System must have the technical controls for 21 CFR Part 11 compliance Watch-Outs: Subject Understanding • Meta analysis of 30 articles involving consent for clinical research found adequate understanding of: – Aim in 54% of the studies (14 of 26) – Voluntarism in 47% of the relevant studies (7 of 15) – Withdrawal in 44% of the relevant studies (7 of 16) – Risks in 50% of the relevant studies (8 of 16%) Falagas ME, Korbila IP, Giannopoulou KP, Kondilis BK, Peppas G. Informed consent: how much and what do patients understand? Am J Surg. 2009;198:420-425. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 14 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead Looking Ahead: Subject Understanding NQF Safe Practice 5 • Ask each patient or legal surrogate to “teach-back,” in his or her own words, key information about the proposed treatments or procedures for which he or she is being asked to provide informed consent. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 15 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead: Subject Understanding Latest Evidence for “Teach-Back” • A prospective, randomized, controlled trial of “teach-back” (“repeat-back”) – 575 subjects – 7 sites Fink AS, Prochazka AV, Henderson WG, et al. Ann Surg 2010;252:27-36. Looking Ahead: Subject Understanding Teach-Back Study: Results • Significantly higher patient comprehension in the group exposed to repeat-back • Majority of providers also reported a belief that use of Safe Practice 5 improved patient understanding • The repeat-back process took only 2.6 additional minutes on average Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 16 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead: Subject Understanding Implementation of Teach-Back for a clinical trial consent Looking Ahead: HITECH Certification ONC Certification • Certifies privacy and security requirements • Ensures that eligible providers and hospitals can attest to meeting Meaningful Use requirements Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 17 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead: HITECH Certification ONC Certification • Privacy and security criteria: – – – – – – – – Access control Emergency access Automatic log-off Audit log Integrity Authentication General encryption Encryption when exchanging health information Looking Ahead: Meaningful Use Stage 1 Stage 2 Stage 3 2011-2013 Data Capture and Sharing 2014-2015 Advance Clinical Processes 2016Improve Outcomes Source: HealthIT.gov. EHR Incentives & Certification. Meaningful Use Definition & Objectives. www.healthit.gov/providers-professionals/meaningful-use-definition-objectives (Accessed 2/28/13) Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 18 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead: Meaningful Use Hospital Capability to Meet MU Objectives Charles D, King J, Furukawa MF, Patel V. “Hospital Adoption of Electronic Health Record Technology to Meet Meaningful Use Objectives: 20082012,” ONC Data Brief, no. 10. Washington, DC: Office of the National Coordinator for Health Information Technology. March 2013. Looking Ahead: Meaningful Use Percent of non-federal acute care hospitals with capability to meet the Patient List Stage 1 objective 2011 70% 2012 89% Change 27% Charles D, King J, Furukawa MF, Patel V. “Hospital Adoption of Electronic Health Record Technology to Meet Meaningful Use Objectives: 2008-2012,” ONC Data Brief, no. 10. Washington, DC: Office of the National Coordinator for Health Information Technology. March 2013. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 19 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead: Meaningful Use Stage 1 – Menu Objective • Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach Stage 1 Measure • Generate at least one report listing patients of the EP, eligible hospital or CAH with a specific condition. Looking Ahead: Meaningful Use Stage 2 – Core Objective • Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach Stage 2 Measure • Generate at least one report listing patients of the EP, eligible hospital or CAH with a specific condition. Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 20 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead: MU Stage 3 • Certification Criteria: Capability for EHR to query research enrollment systems to identify available clinical trials.1 • EHR could use the infobutton standard to identify patient-specific clinical trials.2 1 Department of Health and Human Services. Office of the National Coordinator for Health Information Technology. Health Information Technology; HIT Policy Committee: Request for Comment Regarding the Stage 3 Definition of Meaningful Use of Electronic Health Records (EHRs). 2 Meaningful Use Workgroup Subgroup 2. Christine Bechtel, Chair. September 26, 2012. Looking Ahead: Subject Recruitment Identifying Subjects • Ability to identify potential study subjects via the EHR or other systems Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 21 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Looking Ahead: Subject Recruitment Identifying Subjects • For example, inquire if the subject is interested in learning more about a study • Subject to IRB concurrence E-Consent Checklist Yes No Version control? Access Control? Hierarchical? Audit Capability? Security? Hardware support? Easy to read as paper? Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Yes No Can the patient easily get a copy of the signed consent? Enhance recruitment? Interface with other systems? Compatible with IRB process/systems? Page 22 E-Consents 101 – The Benefits and Potential Obstacles Associated with Electronic Consent for Clinical Trials Questions? Tim Kelly timothy.kelly@standardregister.com tkelly@dialogmedical.com Dialog Medical, a Standard Register Healthcare Company www.standardregisterhealthcare.com www.dialogmedical.com www.engagingpatients.org Session S030 Room W231 A-C April 13, 2013 4:00pm ACRP 2013 Orlando, FL Page 23
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