webinar: how to ace your saas-based edc system validation for sponsors and cros

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How to Ace Your SaaS-based EDC System Validation For Sponsors and CROs PRESENTED BY: AND

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Page 1: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

How to Ace Your SaaS-based EDC System ValidationFor Sponsors and CROs

PRESENTED BY: AND

Page 2: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Webinar Housekeeping

Slides and recording will be distributed to all registrants Use mic & speakers or call in Submit questions via chat Poll throughout presentation

Page 3: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Introductions

Chris Wubbolt, Principal, QACV Consulting 25+ years specializing in

Data integrity, computer system validation, compliance GCP audits and training Quality system development

Quan Doan, Associate Director, EDC Solutions, SDC 15+ years specializing in

Clinical data management and clinical programming CDMS selection, implementation, and software validation

Page 4: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Agenda

What auditors want to see in your validation documentation Focus on intended use validation Best practices for implementing EDC validation Key takeaways to ace your audit Q&A

Page 5: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

What Auditors Want To See in Your Validation

Documentation

Page 6: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Data Integrity & Data Quality

Data integrity refers to the completeness, consistency, and accuracy of data

The fundamental elements of data quality are ALCOA:ALCOA+EnduringCompleteConsistentAvailable

ALCOAAttributableLegibleContemporaneousOriginal (or a true copy)Accurate

Page 7: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

What is Computer System Validation?Why Validate? What?

Documented evidence which provides a high degree of assurance that a system consistently performs according to its predetermined specifications and quality attributes.

Why? 21 CFR Part 11.10: “to ensure accuracy, reliability, consistent intended

performance, and the ability to discern invalid or altered records.”

Page 8: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Identify intended

use

Specify, Design,

Implement SystemSystem

Specifications

Electronic Data Capture

Study Setup

Verify Edit Checks

DataEntry

Data Reconciliation

Database Lock

Test Plans / Scripts

Test/Verify that the System

Meets Specifications

Manual System > Automate

User Requirements Specification

What is Computer System Validation

Page 9: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

SaaS-based vs. Internal Validation

Validation PlanRequirementsFunctional SpecificationsConfiguration SpecificationInstallation QualificationSystem TestingUser Acceptance TestingTraceability MatrixValidation Summary ReportStandard Operating Procedures

Internal Validation Vendor

SDLC Deliverables

Software

Page 10: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

SaaS-based vs. Internal ValidationSaaS Validation Vendor

SDLC Deliverables

Software

Validation PlanRequirementsUser Acceptance TestingTraceability MatrixValidation Summary ReportSOPs

Functional SpecificationsConfiguration SpecificationInstallation QualificationSystem TestingTraceability MatrixSOPsRelease Management

Quality Agreement

Page 11: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Focus on Intended Use Validation

Page 12: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Perception vs. Reality

Perception Reality

Validation is vendor driven Intended use validation must be completed by the user

Business processes are not validatedValidation is based on business

processes, including the use of the computerized system

Focus is on functional testing Focus is on risk to data integrity and the ability to meet user needs

VS.

Page 13: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Regulatory Guidance: FDA

A workflow is an intended use of a computer system to be checked through validation

If you validate the computer system, but you do not validate it for its intended use, you cannot know if your workflow runs correctly

Validation of “Workflows”

Page 14: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Regulatory Guidance: MHRA

Requires an understanding of the computerized system’s function within a process For this reason, the acceptance of vendor-supplied validation data in isolation of

system configuration and intended use is not acceptable In isolation from the intended process or end user IT infrastructure, vendor

testing is likely to be limited to functional verification only, and may not fulfill the requirements for performance qualification (or UAT)

Validation

Page 15: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Best Practices for Implementing EDC

Validation

Case Study: SDC’s Intended Use Validation of iMedNet eClinical

Page 16: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Four Phases of Validation

Validation Phase Deliverable

Validation Planning Validation Plan Validation Training Materials

Requirements Analysis System Requirement Specification

User Acceptance Testing Test Scripts Traceability Matrix Detailed Test Results, Objective Evidence, & Test Incident

Reports

Release and Implementation

Validation Summary Report Final Test Incident and Resolution Logs System Release Memo

Page 17: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

1. Validation Planning

Determine the scope of the validation Which components will you be using? Can all components be validated by an end user?

Determine key stakeholders & participants Process Owners End Users Quality Assurance

Risk-BasedMonitoring

Reporting

InventoryRandomization

Dashboards CTMS

ePRO

Medical Coding

EDC

CEC Role-Based Security

z

IRB Tracking

Page 18: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

2. Requirements Analysis

Develop clear, verifiable, concise and discrete requirements

State “what” not “how”Business Requirements

User Requirements

System Requirements

High-level

Detailed

Ensure regulatory requirements are included

Page 19: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

2. Requirements Analysis

The system shall prevent users from accessing the system upon 3 failed logon attempts

The system shall complete CRF saves within 2 minutes.

The system shall provide an audit trail with timestamps for inserts, updates and deletions.

The system shall prevent users from accessing the system upon multiple failed logon attempts

The system shall complete CRF saves quickly.

The system shall provide an audit trail.

Page 20: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

3. User Acceptance Testing (UAT)

Develop robust test cases for each requirement Include positive and negative testing, if applicable Test cases should be written in a manner such that a person who has never used the system

before would be able to complete Create traceability matrix between test cases and system requirements Ensure testers are properly trained in GDP and Validation Plan Ensure objective evidence is captured Failures should undergo root cause analysis

Develop mitigation plan(s) depending on risk level

Page 21: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

4. Release and Implementation

Validation Summary Report should summarize UAT results and all incidents Processes developed for use of the system should be implemented at this time Build a standard regression suite to test high risk items for system updates

Page 22: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

4. Release and Implementation (for future releases)

Does vendor allow you to opt out of new

versions?

Validation is unaffected when

opting out; no need to re-validate

You must upgrade and evaluate re-

validation

Does vendor provide time and

environment for proactive testing of

changes?

Try to do re-validation within test

window

Consider a timeframe post-release for re-

validation

YES

NO YESNO

Page 23: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Key Takeaways to Ace Your Audit

Page 24: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Key Takeaways

Intended Use Validation User-driven Based on business processes Focused on risk to data integrity Required per FDA and MHRA

industry guidance

Best Practices for Implementation Only validate what you plan to use Ensure your requirements are

verifiable Review new releases for validation

impact

Page 26: Webinar: How to Ace Your SaaS-based EDC System Validation for Sponsors and CROs

Thank YouChris Wubbolt

Principal, QACV [email protected]

Q&A

Quan DoanAssociate Director, EDC Solutions,

[email protected]