PI General Guide _121406_

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PI General Guide _121406_ Powered By Docstoc



  Updated November 2009
                                                     Principal Investigator‟s Guide
                                                          Table of Contents

      1. General information about DCI ................................................................................... 2
      2. Protocol Templates – Web Site .................................................................................. 2

      3. When is it necessary to write a protocol? ................................................................... 3
      4. Principal Investigator/Medical Monitor responsibilities ............................................ 4
      5. Minimal vs. Greater than Minimal Risk Human Studies .......................................... 5
      6. Preparation of a new research protocol ...................................................................... 5
      7. Preparation of a consent form ..................................................................................... 7
      8. Submission of a new protocol ..................................................................................... 7
      9. Funding Sources: Intramural vs. Extramural .............................................................. 7
     10. Advertisement for volunteers ...................................................................................... 10
     11. Review and approval process of a research protocol .................................................. 10
     12. Animal Use Protocols .................................................................................................. 11

     13. Retrospective Chart Reviews, Existing Specimens, Public Behavior ......................... 12

     14. Modifying An Existing Approved Protocol – Submitting an amendment .................. 13
     15. Changing the Principal Investigator of an ongoing study ........................................... 13
     16. Exception to Policy – Study period extension beyond 5-year limit ............................ 14
     17. Submitting an annual progress report ......................................................................... 15
     18. Maintenance of Research Records ............................................................................. 16
     19. Reporting Adverse Events and/or Protocol Deviations ............................................... 16
     20. Ordering consumable supplies; CEEP and MEDCASE equipment ............................ 17
     21. Applying for TDY funds to present results of an approved protocol ......................... 18

      22. How to obtain a one time use of an investigational new drug ................................... 18

     23. When is publication clearance necessary and how is it obtained? ............................. 19

      A. Telephone Directory ……………………………………………………….                                   21
      B. DCI Web Site Home Page

 Revised: NOV 2009                                                  1

1.   General Information about DCI

                                   DCI MISSION STATEMENT

 Striving to Help All Researchers, from Planning to Publication (SHARPP) by directing, supporting,
 and reviewing medical research and education programs with related activities throughout WRAMC,
                        the North Atlantic Region, and the European Region.

       DCI is located in the Borden Pavilion (Bldg. 6), 4th floor. The department is divided into 4
services headed by the Office of the Chief:

          Office of the Chief (OOC) has overall responsibility for the DCI mission, publication
           clearance, and provides teaching programs to residents, fellows and staff concerning
          Research Review Service (RRS) oversees the protocol submission and approval process,
           the conduct of ongoing studies including protocol amendments, adverse event reports and
           annual progress reports.
          Research Administration Service (RAS) oversees budget, gifts, contracts, CRADA‟s,
           supplies/equipment, TDY funding, and the computer resource lab.
          Clinical Studies Service (CSS) provides research education and training, conducts audits,
           coordinates adverse events and deviations, and acts as liaison with NNMC, USUHS, NIH,
           other institutions and the biostatistics support section.
          Research Operations Service (ROS) consists of basic science and clinical research
           laboratories and provides services and training in chemistry, immunology and molecular
           biology for DCI-approved protocols.

Visit the DCI Website http://www.wramc.amedd.army.mil/Patients/healthcare/dci/Pages/default.aspx
for further information about each DCI service and to obtain a phone directory of points of contact
(POC). A copy of the phone directory is included in the back of this guide.

2.   Protocol Templates

         DMRN Web site - Protocol template forms can be easily downloaded from the DMRN web
site, https://www.us.army.mil/suite/page/596540. AKO or DKO access is required. In the far right-
hand column, select WRAMC Templates & Guides. The templates are available in Word format.
For any technical problems, contact: DCI Computer Lab, Bldg. 6, 4th Floor, (202) 782-7884 or
(202) 782-7889.

Revised: NOV 2009                                  2

3.   When is it necessary to write a protocol?

A protocol is required prior to the beginning of any research at WRAMC. Research is defined as a
systematic investigation designed to develop and contribute to generalized knowledge. Any study in
which the data are intended for publication or public presentation, or involves an investigational
procedure, drug, or device, constitutes research and must undergo review through the appropriate
institutional process.

Types of studies:

         -Exempt from IRB regulations (see item 13 of this guide)

There are three categories of protocols. The first is Exempt Protocols. These studies do not
require formal IRB review. However, they do require Exempt Committee and institutional
approval. Exempt research does not require a full protocol or consent form. The investigators
must complete the template EXEMPT protocol and submit it to the DCI Research Review
Service via IRBnet PRIOR to commencing the work.

         -Non-Exempt Minimal risk (see item 5 of this guide)

The second type of protocols are Non-Exempt Minimal Risk Protocols. These protocols are full
protocols that always meet minimal risk standards as defined by DoD and Federal regulations.

         -More than minimal risk (see item 5 of this guide)

The final category of protocols is greater than minimal risk studies.

All Non-Exempt Minimal Risk and Greater than Minimal Risk research requires a full protocol:

        A full protocol needs to be generated and submitted to DCI for the Clinical Investigation
Committee (CIC) and/or Human Use Committee‟s (HUC) review and approval. The following Table
provides some guidance regarding when a WRAMC protocol and/or consent form are required for a
study. For purposes of this guide, the definition of WRAMC is inclusive of all MTF’s and
installations where WRAMC is considered the DCI and IRB of record. See SOPs (in our web
site) for a current list.

         Table – Guidance regarding when WRAMC protocol and/or consent form are required for a study.
Principal           Associate          Subjects/    Facilities/         WRAMC      WRAMC
Investigator (PI)   Investigator (AI) Patients      Study Location      Protocol?  Consent Form?
1. WRAMC             -                WRAMC         WRAMC                Yes          Yes

2. WRAMC                  -               Other Institution     Other Institution          No*             No

3. Other Institution WRAMC                WRAMC                 WRAMC                      Yes             Yes

4. Other Institution WRAMC                Other Institution     Other Institution          No              No

*Unless funded by WRAMC. If WRAMC approval is not required, the protocol may be submitted to DCI for courtesy review.
The protocol needs approval at the site where study is conducted. Items 1, 2, and 3 are self-explanatory. Examples for item 3 are
GOG, COG, and CALGB studies.

Revised: NOV 2009                                                   3
4.   Principal Investigator (PI)/ Medical Monitor Responsibilities

A Principal Investigator is:

     -    A physician or other person assigned to or employed by WRAMC, or assigned to Walter Reed
          Army Institute of Research, US Army Dental Activity, and Uniformed Services University of
          the Health Sciences who has professional privileges at WRAMC within the scope necessary
          for the conduct of the study. Army Regulation 40-38 precludes non-WRAMC contractors
          from serving as PIs on WRAMC studies. Studies enrolling WRAMC subjects and involving
          WRAMC investigators as collaborators, but for which the PI is not assigned to WRAMC must
          have a designated WRAMC billeted investigator as the WRAMC PI.

     -    A resident or fellow in a National Capitol Consortium program with clinical responsibilities at
          WRAMC may serve as a WRAMC PI provided a fully qualified staff member serves as an
          Associate Investigator (AI).

     -    The PI has overall primary responsibility to ensure that the study is conducted in a manner
          that is in accordance with the federal, Army and local guidelines and regulations that govern
          research at WRAMC. For a complete listing of the responsibilities, refer to the FULL
          HUMAN USE PROTOCOL template. When the Principal Investigator submits the protocol
          application, his/her electronic signature constitutes acceptance of this responsibility.

     -    If a PI leaves WRAMC for greater than 30 days, an acting PI must be designated in writing.
          See section 15.

     -    It is the PI‟s responsibility to ensure that all members of his/her research team involved in the
          conduct of research obtain WRAMC required research education and training.

     -    AR 40-38 does not preclude government contractors from serving as PIs on Clinical
          Investigation Program protocols. However eligibility for PI status will be determined on a
          case by case basis by the Commander, Walter Reed Health Care System, and formally
          approved by him/her in writing.

The Medical Monitor:

        All greater than minimal risk studies (see definition in section 5) must have a Medical Monitor.
The Medical Monitor must be independent of the research study, i.e., is not an investigator of the
study. The Medical Monitor cannot be a subordinate in the PI‟s rating scheme because of a potential
for command influence type conflict of interest.

          The Medical Monitor has the following responsibilities:

     1)       To monitor the conduct of the protocol and ensure protection of human subjects. This may
              involve periodic review of medical records of enrolled subjects, as well as the research
              files being maintained by the Principal Investigator;
     2)       To keep abreast of adverse events and protocol deviations that occur during the
              research; (all adverse events, including deaths and serious or unexpected side effects, are
              reported to the Medical Monitor via the Principal Investigator.
     3)       If there is concern about the welfare of enrolled subjects, the Medical Monitor has the
              authority to terminate an individual volunteer's participation in the study or to suspend the
              entire study for review by the WRAMC Human Use Committee (HUC) at any time.

Revised: NOV 2009                                     4
     4)     Notification of suspension or termination actions must be forwarded to the Department of
            Clinical Investigation within one (1) working day of receipt of knowledge prompting
            human subject welfare concerns.
     5)      Medical Monitors will be required to co-sign all adverse event reports, protocol deviation
            memoranda, and Annual Progress Reports (APRs) generated by the PI of the study
     6)      The Medical Monitor must keep current the WRAMC required research ethics Human
            Subjects Training every 3 years.
     7)      If a Medical Monitor leaves WRAMC for greater than 30 days, a substitute Medical
            Monitor must be reported to DCI via a memorandum for a change of Medical Monitor.
            This is a PI responsibility.
     8)      If the Medical Monitor is expected to be away for more than 14 days but less than 30,
            then the PI or Medical Monitor must designate an acting Medical Monitor.

5.   Minimal vs. Greater than Minimal Risk Human Studies

        Minimal Risk Human Use studies are those studies in which the probability and magnitude
of harm or discomfort anticipated in the research is not greater than that encountered in daily life or
during the performance of routine physical or psychological examinations or tests [see 32 CFR
219.102i]. Some of the examples of minimal risk studies are small amount of blood draws from a
healthy individual, exercise, behavior, and voice recordings/hearing testing.

       Greater than Minimal Risk human studies include all studies that do not fall into the
category of minimal risk.

6.   Preparation of a New Research Protocol

        The research protocol is comprised of several different documents. Some of these documents
are essential and need to be included in all protocols while others are included only if applicable to the
study to be conducted. Templates for all of these documents, as well as instructions, can be
downloaded from the DMRN web site. Refer to section 2 of this guide for further information on
templates. Please submit all documents electronically using the IRBnet system accessible at the
Defense Medical Research Network (DMRN) https://www.us.army.mil/suite/page/596540.

Important documents

       The following is a list of the important documents typically required for a new protocol
(excluding Exempt protocols). Each of these documents requires one or several signatures as indicated

Document name                                           Required signatures
FULL HUMAN USE PROTOCOL                                 PI, Svc & Dept. Chief, (Med. Monitor)
Impact statement - General                              Svc., & Dept. Chief, Other Impact Svc.
Consent Form with HIPAA                                 As appropriate

        The two major documents of a protocol are the application and the consent form. Begin by
writing the protocol application where you will carefully describe the details of your study and why it
should be conducted. There are several specific sections to this document. Refer to the template form
for guidance and instructions. If you are conducting a prospective human study you will also need to
write a consent form where you explain the study to the research volunteer in simple language (8th
grade level). Refer to the next section of this document to learn more about preparing the consent

Revised: NOV 2009                                   5
form. Once these two major documents have been completed, prepare any supplemental documents
that pertain to your study.

       If your study will be collecting any of the 18 HIPAA personal health identifiers (see HIPAA
Research Roadmap on the DCI website), and your study involves use of a consent form, then you will
need to use a consent form with incorporated HIPAA authorization.

        To complete the protocol packet, submit a 2-page abbreviated CV from each investigator
(principal and all associates).

Intramural Laboratory Research

       Laboratory studies of DCI-funded research will be performed in the DCI Research Operations
Service (ROS), at the discretion of ROS. Laboratory studies require a full protocol by institutional
convention but often can be approved through an expedited process. Provide a draft copy of your
proposal to the Research Operations Service.

       POC: Chief, Research Operations Service, Bldg. 7, (202) 356-1243

Supplemental Documents:

       If you plan to ADVERTISE FOR VOLUNTEERS on bulletin boards, CHCS, or in a
newspaper such as the WRAMC Stripe, you need to submit the form ADVERTISEMENT to Recruit
Human Subjects. Refer to section 10 of this guide for further information on advertising for

       If you are receiving a gift, loan or outside funding, each investigator must complete a
CONFLICT OF INTEREST document. Refer to section 9 of this guide for more information
regarding funding.

        If your study involves gene therapy please refer to the following documents in the DMRN
website: Adverse Events, IBC WRAMC Training, IBC Internet Resources, IBC Investigator
instructions, IBC NIH Guidelines-App M and IBC WRAMC SOP. If your study involves genetic
testing, refer to the Genetic Policy on the DRMN website.

        If your study involves the support of Department of Pathology, including tissue banking, you
need to prepare a Pathology Impact Statement (WRAMC form 731997 Rev 9/13/04). Under section
IV. „Laboratory Support Cost Analysis‟ of this form, list the name and number of tests that will be
requested for research purpose only. All other information, i.e. cost and CAP units will be provided
by Pathology. Take the protocol and this impact statement to Dept of Pathology on the 2nd floor, Bldg.
2 for review and signature by the Chief, Dept. of Pathology.

       If your study involves dispensing drugs you will need a Pharmacy Impact statement. ALL
drugs must be delivered to and dispensed by Pharmacy. Take a copy of your protocol to Pharmacy
Administration located on the 2nd floor, Bldg. 2. There is no specific template for this impact
statement. Pharmacy will prepare a statement signed by the Chief and give it to you to include in your
protocol packet.

       If your study involves nursing personnel paid by WRAMC, you will need to obtain a Nursing
Impact Statement. Take a copy of your full protocol to Nursing Research Service, Building 1, Room

Revised: NOV 2009                                 6
A251, with a note that a Nursing Impact Statement is needed. Nursing Research Service will prepare
the statement, using a specific format, for the signature of the Deputy Commander for Nursing.

       Similarly, if your study impacts or involves resources from any department, you will need to
include relevant signed impact statements from the respective Chiefs.

7.    Preparing a Consent Form

        If you are prospectively enrolling human subjects, you will need to prepare a CONSENT
FORM. The consent form should be written in simple (8th grade level) language. The consent form is
comprised of several subsections, some of which are model statements used in all consent forms while
other subsections are written for the specific study. Start by downloading a consent form template
from DMRN. Follow the guidelines and instructions written in red letters to provide the appropriate
information under each subsection. Be sure to delete all red lettering and wording after preparation
and then save the consent form as your own personal file and upload it into IRBnet.

8.    Submission of a New protocol

      POC for full protocol submission and scheduling: DCI Protocol Coordinators, RRS, Bldg. 6,
4 floor, Room 4043, (202) 782-7828 or (202) 782-7864.

        All documents should be submitted electronically via IRBnet.

9.    Funding Sources: Intramural vs. Extramural


POC: Chief, RAS, DCI, Bldg. 6, (202) 782-7859

        In planning a research study, it is important to determine what resources and funding will be
needed to conduct the study. DCI has a limited amount of funds available to help Investigators (full
time WRAMC staff or participants in WRAMC or consortium GME) conduct smaller-scale studies.
The Clinical Investigation Committee (CIC) makes the decision about intramural funding awards.
Because requests for funds typically exceed the available resources, the following restrictions apply:
    Funding is limited to $7,500 per fiscal year per protocol for a maximum of $15,000 for two
       years with up to $1,000 earmarked for travel. Funding is based on availability at the time of
    Funding is also limited to two protocols per Principal Investigator per fiscal year.

Investigators are requested to submit their proposed budget request in the following manner:

CATEGORY                            FY                     FY                     TOTAL
(Itemize each supply

Revised: NOV 2009                                  7
TOTAL                       $                       $                         $

The application should include a Budget Justification for each budget category.

Consumable Supplies:
        All consumable supplies need to be itemized, providing quantity, unit cost and total cost per
item, per fiscal year.

       Funds may be applied to the purchase of small clinical or laboratory equipment essential for
completing the study. Funds may not be used, however, to purchase computers, furniture, postal
services, publication charges or reprint material. The PI needs to provide an Impact Statement signed
by the Department Chief stating that the Department cannot support the research project by providing
the equipment.

         The proposal will include an equipment disposition plan:
        Clinical equipment: The Service and/or Department Chiefs certify in the proposal that they
         will accept the equipment at the conclusion of the study.
        Laboratory equipment: At the discretion of DCI, the equipment will revert to the DCI

Equipment from a non-WRAMC source will be designated by the source as either a loan or a gift.
Follow the prescribed regulatory procedures for accepting gifts (for instructions on gifts/loans see
section on CRADA).

       Funding requests of up to $1,000 per TDY per protocol may be approved for intramural
protocols for full time WRAMC staff or participants in WRAMC or consortium GME. Utilization is
contingent on the availability of funds and on a first-come, first-served basis. Funds are intended for
only one trip by the Principal Investigator to present research findings.

To access travel funds, complete the MOA and submit to DCI.


POC: Chief, RAS, DCI, Bldg. 6, (202) 782-7859

It may be necessary to seek resources outside of WRAMC to accomplish your research goals.
Resources provided by non-WRAMC sources are considered extramural. They may include money,
equipment, medical or non-medical supplies, drugs or medical devices. A brief statement is required
in the budget section of the protocol stating type of resource(e.g. cash or drugs, etc.), source and what
intermediary organization will be coordinating the receipt and management of these resources (e.g.
Henry M. Jackson Foundation). A separate budget page, written on the intermediary organization‟s
letterhead and signed by an official, is required in the protocol package.
Revised: NOV 2009                                   8
The PI needs to consult one of the intermediary foundations (Henry M. Jackson Foundation, Geneva
Foundation or TRUE Foundation) to prepare a Cooperative Research and Development Agreement
(CRADA). A CRADA is the means for accepting extramural resources for use in a WRAMC study. A
CRADA is a legal agreement between an intermediary organization and the Clinical Investigation
Regulatory Office (CIRO) for accepting and accounting of all resources offered by a non-WRAMC
source to the research study. All CRADAs are approved by CIRO. While CIRO reviews and
approves CRADA documents simultaneously with the protocol, each document receives separate

A CRADA is required for the following situations:

       1. To receive equipment, money, supplies, services or drugs donated from a Non-Federal
       organization (e.g. pharmaceutical company, manufacturer of medical devices or services of
       assays done by a private lab). Consult one of the foundations who will prepare all documents
       and route them to DCI.

       2. When federal funding is received and managed by an intermediary organization (e.g. TRUE
       Foundation) a CRADA is required.

       3. When equipment loaned for the duration of a study from a non-federal agency can only
       come to WRAMC through a CRADA. If no cash is offered with the loan, a non-cash CRADA
       can be prepared to accept the loan. Both the Henry M. Jackson Foundation and Geneva
       Foundation have graciously agreed to waive their customary fees and will prepare the non-cash
       CRADA at no cost to the company offering the loan.

While the CRADA process is the least time-consuming means for obtaining outside resources, a PI
may seek approval from DoD. Typically, the request is processed through the JAG, MEDCOM, and
the OTSG for gifts (cash and non-cash resources) valued from $1,000-20,000. Amounts in excess of
$20,000 require additional approval (e.g. Assistant Secretary of the Army for Health Affairs). This
process takes 9 to 12 months to complete all signatory levels.

NOTE: DCI does not prepare nor process federal grant applications. The PI should contact the funding
source for information.

10. Advertisement for Volunteers

         POC: Continuing Review Coordinator, RRS, Bldg 6, (202) 782-7861/7829

          An advertisement is defined as any information given or presented to potential human
research subjects through printed, electronic or World Wide Web media with intent for recruitment
into a research study. If you would like to advertise, for examples, in the Stripe, Pentagram,
Washington Post, CHCS, Outlook MAIL, handouts, any web site, or on a bulletin board for
volunteers, the written advertisement must be reviewed and approved by the Human Use Committee
(See ADVERTISEMENT to Recruit Human Subjects for more guidance). The placement of the
advertisements should be approved by the appropriate authority (e.g., Executive Office for the
Revised: NOV 2009                                   9
WRAMC Hospital, Executive Office for the WRAMC installation). Funding for advertisements or for
compensation to volunteers is not provided by DCI.

              TO REQUEST APPROVAL:
           -    Complete the advertisement request form found on the DMRN website
                ADVERTISEMENT to Recruit Human Subjects
           -    State the advertisement to be used verbatim and include all information as noted
           -    Indicate if web advertisement using the DCI site is requested
           -    Have the form signed by the Principal Investigator (PI).

        - Submit this form via IRBnet as a document of the initial submission packet or as a
          subsequent submission for your approved study.
        - Once the appropriate committee approves the content of the advertisement, the PI must
          obtain approval from the appropriate authority, such as the Executive Office for the
          WRAMC Hospital, for placement of the advertisement.

               - The Principal Investigator receives a written letter of approval from DCI.
               - Approval from the appropriate authority where advertisement is to be placed.

11. Review and Approval Process of a Research Protocol

       POC: IRB Administrator, RRS, DCI, Bldg. 6, (202) 782-7829

       A protocol is reviewed and approved by one or more committees prior to approval, depending
upon the type of study to be conducted. The majority of protocols only require local approval by
WRAMC Clinical Investigation Committee (CIC) and/or Human Use Committee (HUC). Protocols
involving the use of an IND/IDE or extramural support require local and higher-level approval by
CIRO and other regulatory offices.

        Minimal risk studies that qualify for expedited review [see 32 CFR 219.110, 21CFR 56.110,
AR 40-38, Appendix H] are approved by a subcommittee of the HUC at the meeting of the CIC and
are reported to the WRAMC HUC. Minimal risk studies that do not qualify for expedited review
(example: a study that involves withdrawing large amounts of blood) must be reviewed and approved
by both CIC and HUC. Greater than minimal risk human studies require review and approval from
both CIC and HUC.

       a. DCI Administrative Review – When a protocol is submitted to DCI, it is entered into the
DCI database. PI is sent a memorandum acknowledging receipt of the protocol. Then a DCI protocol
coordinator does an Administrative Review to assure completeness of documents and signatures. The
most common deficiencies found on Administrative Review are: lack of signatures, missing
documents (all protocols must have a general impact statement), or incomplete information such as
missing sections in the application or consent form. The DCI coordinator sends the Administrative
Review to PI, listing deficiencies, and the date that the protocol is scheduled for committee review.

          b. Clinical Investigation Committee (CIC) – All new protocols, except for group oncology
study protocols (GOG, COG, CALGB, etc.) and most IND studies, are reviewed by the CIC. This
committee consists of 12 people of diverse backgrounds and areas of expertise from WRAMC. In
general, the CIC assesses the scientific merit, use of resources and budget of the study. The CIC
usually holds a closed meeting on the first and third Tuesdays of each month in the DCI conference

Revised: NOV 2009                                    10
room. The PI will be notified of the date and time their protocol will be reviewed. It is important that
the PI or a representative be present to answer any questions the committee may have. Once the
committee reviews the protocol, a vote is taken to approve, table, or disapprove the protocol.
Protocols disapproved by the CIC are forwarded to HUC for final decision. The PI is notified of the
committee‟s decision when he/she telephones the Protocol Coordinator the following day.

          c. Human Use Committee (HUC) – The HUC consists of approximately 15 people who
review the protocol for human use issues, specifically focusing on the risk to benefit ratio, ethics, and
rationale for conducting the study. The wording of the consent form is carefully reviewed to ensure
that the study is fully explained using simple words and concepts. Similar to the CIC meeting, the
HUC meeting is a closed meeting usually held on the second and fourth Tuesdays of each month in the
DCI Conference room. After the meeting, the PI is notified of the committee‟s decision when he/she
telephones the Protocol Coordinator the following day.

         d. Formal Approval – PI must not start the study until all the required revisions are
submitted to DCI for verification and further notification with a DCI approval letter to begin the
study. Required revisions to the protocol or consent form by CIC and/or HUC must be submitted to
the RRS Protocol Coordinator within 60 days from the time of committee approval.

       e. Administrative Termination – If a final updated version of the approved protocol with
required revisions is not submitted to the DCI within 60 days after the committee approval, the
protocol may be administratively terminated. During the process, PI will receive notification by DCI
Protocol coordinator of such deadline.

12. Animal Use Protocols

          POC: Protocol Coordinator, RRS, Bldg 6, (202) 782-7864
          Any protocol involving the use of animals needs to be reviewed and approved by the
Institutional Animal Care and Use Committee (IACUC) of the institution where the study will be
conducted, (WRAIR, USUHS, AFRRI). WRAMC does not have an IACUC. If the study requests
DCI support, i.e., funding, statistical or computer support, it also needs to be reviewed by the
WRAMC CIC. If the study involves humans and animals, the protocol needs to be reviewed and
approved through WRAMC CIC and HUC and an IACUC. All animal studies involving non-human
primates, marine mammals, dogs, or cats, will require further review and approval by the Army
Clinical Investigation Regulatory Office (CIRO) at San Antonio, Texas.

   To prepare and submit an animal use protocol to WRAMC DCI:

          Download the ANIMAL USE PROTOCOL forms and instructions from the DMRN
          Once all documents have been prepared, obtain signatures of PI, Service & Dept. Chiefs,
           impacting Service Chief, the biostatistician and the veterinarian.
          Complete the required literature search (see instructions).
          Submit these documents electronically using IRBnet.

         To receive a final approval letter from the DCI, a copy of the approval letter from the
IACUC is required. If support will be provided by a federal facility (e.g. USUHS), a MOU is
required specifying the services and costs to be required. If any support will be obtained from a
non-federal institution (e.g. Johns Hopkins), a letter from the institution indicating the nature of
the support is required. If funding is to be paid to the non-federal institution for such support, a

Revised: NOV 2009                                  11
contract needs to be set up between WRAMC and the institution prior to initiation of study.
(Consult DCI, Chief, Research Administration Service, DCI.)


    POC: Exempt Protocol Coordinator, RRS, Bldg 6, (202) 782-7880

          Certain types of research, including retrospective chart reviews, may qualify for Exempt
review. Request for exemption from HUC/IRB review may be made for the following exemption
categories under 32 CFR219.101b:
1 Educational strategies, curricula, or classroom management methods
           Research conducted in established or commonly accepted educational settings, involving normal
           educational practices. Note: FDA-regulated research does not qualify for this exemption.
2 Educational tests, surveys, interviews, or observation of public behavior
    (includes Health Care Delivery and Epidemiology studies)
           Note: (1) When the research involves children as subjects this exemption must be limited to
           educational tests (cognitive, diagnostic, aptitude, achievement) and observation of public behavior.
           (2) Research that involves observation of public behavior when the investigators participate in the
           observed activities cannot be granted an exemption. (3) FDA-regulated research does not qualify for
           this exemption.
4 Existing Records and Specimens
           Sources are publicly available or the investigator intends to record information in such a manner that
           subjects cannot be identified directly or indirectly.
           Note: (1) Enclose a description of all data variables to be collected and/or a copy of the data
           collection sheet (2) To qualify for this exemption, the data, documents, records, or specimens must
           be in existence before the project begins (3) FDA-regulated research does not qualify for this

Other Exempt Categories (3) Educational tests, surveys, interviews, or observation of public behavior of
public officials or when identifiers required by federal statute, (5) Research on public service programs,
(6) Taste and food quality research

           An HUC/IRB Exemption Certification Application must be completed and submitted to the
POC listed above; please see EXEMPT protocol for instructions and application form. A PAD
impact statement is required if the project involves review of medical records. A DOIM impact
statement is required for projects that involve use of the Internet and/or e-mail for patient recruitment
and/or data collection. Funding for Exempt projects is limited to travel (one TDY trip for a full time
WRAMC staff or participant in WRAMC or consortium GME for the purpose of presenting the results
of the research, currently $1,000). This funding is only available for the study PI. No other support or
resources from DCI will be available; however, extramural funding may support Exempt protocols. If
a given Service intends on repeated query of their existing clinical databases normally approved via
exempt procedure, a prospective database registry protocol will be required.


14. Modifying An Existing Approved Protocol – Submitting an Amendment

          POC: Amendment Coordinator, RRS, Bldg 6, (202) 782-7861/7829

       All modifications to protocols must be formally reviewed and approved either by an expedited
review process or by the CIC/HUC prior to conducting the revised study. To obtain the specific
Revised: NOV 2009                                      12
guidelines on when and how to submit an amendment to an existing protocol refer to the Subsequent
Study Submission Training link on the DMRN page

           In submitting an amendment, REMEMBER TO:
            -    Include the revised consent form
            -    Obtain signature of the medical monitor if applicable

           SUBMIT the documents via IRBnet


            -   Minor modifications to a protocol may qualify for expedited review by the Human Use
                chairperson or his/her designate.
            -   More extensive modifications require formal review and approval by the CIC and/or
                HUC. The PI will be notified of the type, date and time of review of the amendment.
            -   Once the amendment is approved, an approval memo and stamped new consent form, if
                applicable, will be sent to the PI and the revised study can be conducted.
            -   If changes proposed by the amendment are extensive, the committee may require
                submission of a new protocol.

15. Changing the Principal Investigator (PI) of an Ongoing Protocol

           POC: Clinical Studies Technician, RRS, Bldg 6, (202) 782-7896

          If the principal investigator of an ongoing study is leaving WRAMC, e.g., transfer of duty
station or retiring, deployment greater than 30 days, a new principal investigator (or acting PI) needs
to be designated through DCI to continue the study.

           TO DESIGNATE A NEW PI/ACTING PI, the current PI submits a request form,
            including the required supporting documents, ADDENDUM – PI change. During the
            transition, the current PI needs to transfer all research records and administrative
            documents of the research study to the new PI/ acting PI. The new PI/acting PI needs to
            sign this document, which includes the „Responsibilities of PI Statement‟ and „Investigator
            Compliance Memorandum‟. The new PI/ acting PI must be eligible to be a WRAMC PI.

           REMEMBER TO:
            - Indicate Title and Work Unit # (use all digits, e.g., 00-0000) of Protocol
            - Include all requested information concerning current and new/acting PIs
            - Obtain signatures of current PI and Service Chiefs
            - Change cover sheet of consent form, if applicable, to reflect name of new PI/acting

      SUBMIT THE REQUEST FORM and updated consent form, if applicable, via IRBnet.

            - DCI will confirm the designation of the new/acting PI with a memo to the current and
              new/acting PI.
            - If applicable, the updated consent form will be stamped by DCI and returned to the PI
              to use for enrollment of subsequent research subjects.
            - The PI change will be reported to the HUC.

Revised: NOV 2009                                  13
16. Exception to Policy – Study period extension beyond 5-year limit

           POC: Editorial Assistant, RRS, Bldg. 6, (202) 782-7848

          Generally, a protocol can be re-approved through the Annual Progress Report for up to 5
years to complete the study including data analysis. However, if an ongoing study is productive but is
not completed by the end of the 5-year limit, the Principal Investigator can request an extension in the
study period. In general, the approval is good for one additional year. If a study is open for follow-up
only for monitoring subjects through their life time and enrollment is closed, a protocol extension is
not required.

           To Extend The Study Time Of An Active Protocol Beyond The 5-Year Limit:
            - Prepare an amendment by completing the Exception to policy form in DMRN
            - Submit new impact statements as required in the original protocol submission, if the
               study is still enrolling new subjects.

           REMEMBER TO:
            - Give Work Unit # and Title of active protocol
            - Summarize status/progress of protocol to date
            - Obtain signatures from PI, Service & Department Chiefs

           SUBMIT THE COMPLETED FORM and other required documents via IRBnet as a
            Subsequent Study Submission

           REVIEW PROCESS:
            - Depending upon the nature of the study, the request for extension will undergo
              expedited or full review by CIC and/or HUC. The PI will be notified of meeting
              date/time, if applicable.

17. Submitting an Annual Progress Report (APR)

           POC: APR Coordinator, RRS, Bldg. 6, (202) 782-7848

           The Annual Progress Report (APR) is part of continuing review of ongoing research that is
mandated by federal regulations for protection of research subjects. All ongoing research studies are
required to be reviewed and re-approved at least once annually by an expedited review process, the
CIC and/or the HUC.

      NOTIFICATION/REQUEST OF AN APR FROM DCI - Once a year, up to two months
       prior to the protocol‟s anniversary date of the initial approval, DCI will initiate a request for an
       APR by sending the Principal Investigator an Outlook message with the necessary forms and
       instructions attached. These forms and information can also be obtained from the DMRN web
       site under filename APR for human or animal use study as appropriate.
           - A Detail Summary Sheet (DSS)
           - Continuing Review of Research
           - List of Publications

           TO PREPARE AN APR:

Revised: NOV 2009                                   14
           -   Use the APR forms to complete the 3 enclosures. Be sure to read the cover page for

          IMPORTANT TIPS:
           - For enclosure 1, check the “Ongoing” status if the study is in one of the following
             conditions: subject accrual, follow-up, data collection, or data analysis. If the study
             has completed the data analysis and is in the process of reporting/presentation, you may
             check the “Complete” status. In the “Progress” section, be sure to include the number
             of subjects enrolled for the year and the total enrollment to date; also indicate any
             adverse events. State “no adverse events” when there are none.
           - Make a copy of enclosure 2 and sign your (i.e., PI) name on the signature block or affix
             your electronic signature. If the protocol has a medical monitor, obtain his/her
           - Fill the publication page (i.e., enclosure 3) according to the suggested format.
           - Do not miss the submission deadline for the HUC review and approval.

          SUBMIT the required documents via IRBnet as a Subsequent Study Submission


           -   The APR will be first reviewed by a Primary reviewer from the HUC membership and
               then be approved by expedited procedure or forwarded to the HUC for its review and
           -   Upon the HUC approval and the receipt of all required revisions, resolutions and
               clarifications, PI will receive the APR with WRAMC IRB approval stamp.
           -   For ongoing studies with subject accrual, the PI will also receive a stamped new
               consent form(s), which expires in one year.
           -   PI can not enroll new subjects until the receipt of stamped approval of the DSS and the
               updated consent form(s).


           -   Abeyance: Failing to complete an APR on or prior to the due date will result in the
               protocol being placed in abeyance by the HUC. The abeyance means that you may not
               enroll any new subjects. In addition, you may not continue any research in presently
               involved volunteers, unless the withdrawal of medication or intervention could be
               deleterious to the subjects. No funding will be approved, and data collected cannot be
               used for publication. Abeyance status may be lifted upon receipt, review and
               acceptance of the delinquent APR by the approving authority or relevant committee.
           -   Administrative termination: A protocol with an abeyance status for more than 60 days
               may be administratively terminated by the HUC and no further research activities are
               permitted for the study including data presentation and/or publication. At this time DCI
               will also notify your Department Chief, the Medical Monitor, and, if an interventional
               study, the DCCS, the WRAMC Commander, and any Sponsor, if applicable.

18.    Maintenance of Research Records

       Federal regulations require the PI to maintain a Study File for three (3) years following
completion of the study if no IND/IDE used (32 CFR 219.115(b)). If IND medication or IDE
appliances are used, the file must be kept for 2 years after FDA approval and can then be destroyed; if
no application is filed or approved, until 2 years after the study is discontinued and FDA notified
Revised: NOV 2009                                  15
(21CFR 312.62(c)). The records, to include original hard copy consent form(s) and source documents,
must be kept in a secure location with the Department/Service where the research took place (AR 40-
38). If you PCS or ETS, you are required to give the research records to a new Walter Reed PI or your
Department/Service Chief. You will not receive final installation clearance from DCI until you
have resolved all outstanding matters related to your study.

19. Reporting Adverse Events (AE) and/or Protocol Deviations (PD)

       POC: DCI Research Associate, CSS, Bldg 6 (202) 782-7830


An adverse event (AE) is defined as any occurrence of injury, dysfunction, disease or abnormality of
any organ or tissue that occurs in a research subject enrolled in a clinical protocol. This event can be
related or unrelated to the research protocol. Serious adverse events (SAE): Adverse event that are
fatal, life-threatening, permanently disabling, require inpatient hospitalization, or result in congenital
anomalies, cancer, or overdose. Unexpected adverse events (UAE): Adverse events that are not listed
as potential risks in the approved WRAMC consent form. All such events need to be reported to the
Institutional Review Board. Refer to the Adverse Events Instruction on the DCI templates entitled
adverse events instruction memo.doc for further information about adverse event reporting

           REPORTING TIME – Depending on the type of adverse event:
            - Serious adverse events (resulting in hospitalization, birth defects, disability, or death)
              whether related or unrelated to the study and whether expected or unexpected need to
              be reported within 24 hours.
            - Non-Serious Unexpected adverse events are reported to the WRAMC Human Use
              Committee within 10 working days.
            - Non-Serious Expected adverse events (those listed under „Possible Risks‟ in the
              consent form(s), are reported on the Annual Progress Report.

       -    TO REPORT AN SAE or a Non-Serious UAE - Complete an adverse event report. The
            template is on the DMRN website.

           REMEMBER TO:
            - Complete all information on the form
            - Attach pertinent medical documents
            - Obtain protocol Medical Monitor‟s signature as required on the AE or PD form and
              provide a copy of the report to the Medical Monitor
            - Keep a copy for the protocol file

           SUBMIT THE REPORT TO the POC listed above who will record the report and
            forward it to the Human Use Committee.

Revised: NOV 2009                                   16
        Any variance or departures from the protocol are defined as a protocol deviation. Examples of
deviations included but are not limited to procedural variances from the treatment schedule for an
individual patient, failure to use the most current consent form(s), and/or incomplete or lost research
records. They may be of minor or major significance. They must be reported in a manner similar to
adverse events. The deviation report must be co-signed by the Medical Monitor if applicable.

            TO REPORT A PROTOCOL DEVIATION-Complete a protocol deviation
             memorandum. The template for reporting a protocol deviation can be found under filename
             deviation.doc. Submit the protocol deviation report to the POC listed above who will
             record the report and forward it to the Human Use Committee.

20. Ordering Expendable/Consumable Supplies

          POC: DCI Supply Coordinator, RAS, Bldg. 6, (202) 782-7820

        Once a protocol is approved, supplies itemized in the „BUDGET‟ section can be ordered
through DCI. All purchase requests must have the original signature of the PI of the protocol. Orders
less than $2,500 will be paid for through government credit card, if the vendor accepts credit cards.
Vendors who don‟t accept government credit cards and/or orders costing over $2,500 will be
electronically routed through Contracting by DCI. This routing may take longer to process.

            TO SUBMIT a purchase request for consumable supplies, provide the information to
             include vendor name, address, phone number and catalogue information to the POC listed

            The information can be faxed to 202-782-3881 or submitted in person to Bldg 6. The PI or
             designee will be called when the items arrive. HOURS OF OPERATION: Monday thru
             Friday, 0700 – 1530. For further information, contact the POC at 782-7820.

            REMEMBER TO:
             - Give specific source, description and an actual quote of the pricing information to
               ensure the correct item is ordered.
             - Provide protocol work unit number on the request
             - Have form signed by Principal Investigator
             - Keep a copy of the paperwork for your files
             - Incomplete information will delay processing; request will be returned to PI
             - Subject to funds availability

21.    Applying for TDY Funds to Present Results of an Approved Protocol at
       A National Meeting

             POC: Chief, RAS, DCI, 782-7859 or Grants Manager 782-7810

             DCI will reimburse up to $1,000 of travel expenses for presentation of research findings
      related to a DCI approved protocol. This is limited to one TDY per approved protocol and only
      the PI (full time WRAMC staff or participant in WRAMC or consortium GME) can use the funds
      for TDY. If your TDY is expected to exceed $1000, you will need to obtain the remaining funds
      and provide the information on your TDY request.

Revised: NOV 2009                                   17
           - Attach the following documents to the TDY request:
             - A copy of the protocol approval memo
             - Abstract publication clearance
             - Invitational letter to present work
             - Meeting brochure with registration fee
             - Have Service/Department Chief initial TDY request
           - The DCI Travel Coordinator will prepare the TDY orders (DD1610) and notify the
             traveler for pick up of orders.
           - DCI policy allows $1,000 per protocol or three-day travel (arrival, present, and return
             days) whichever is less.

          WHEN THE TDY IS COMPLETE, the traveler needs to:
           - Submit form DD 1351-2 with original receipts to the NCOIC, DCI within 5 working
             days after travel.
           - These documents will be forwarded to the finance office in San Antonio, Texas.
           - NOTE: the traveler should keep copies of all documents with receipts.

**For information on Invitational Travel Orders or Proffer Letters to fund TDY, contact, Chief, RAS,
DCI, (202) 782-7859.

22.   Emergency One-Time Use of an Investigational New Drug (IND) or Device (IDE)

       POC: DCI Research Associate, CSS, Bldg. 6, (202) 782-7830

        Specific guidelines and information concerning emergency one time use of an IND are given
on the DMRN web site. A physician who wants to use an IND in an emergency situation must be to
take the following steps:

          Contact Chief or Asst. Chief of DCI for local clearance and authorization to contact CIRO
           who makes final approval. Have the following information available: Patient name,
           diagnosis, SSN, drug name, dose, length of use and source of drug, IND number of the
           drug [an IND number must be obtained and is usually accessible through the manufacturer
           or through the medical officer processing the IND application at the FDA; FDA phone #
           (301) 827-2000], and name of the staff physician.
          Obtain the patient‟s volunteer informed consent by having patient sign standard DA form
          Document date and time of clearance from DCI and from CIRO.
          Contact Pharmacy on incoming investigational drug and DCI, RRS for incoming devices.
          Complete within one day an initial request form found on DMRN web site and submit to
           DCI via IRBnet. Complete a follow-up report including the outcome of the use of the IND
           within 10 days of the end of treatment or 6 weeks after initiating the treatment. The
           follow-up form is also found on DMRN.

23. Obtaining Publication Clearance

Revised: NOV 2009                                 18
           POC: Clinical Research Associate, Clinical Studies Service, DCI, Bldg 6,
           (202) 782-7823

           All written materials, clinical or research related, including manuscripts, abstracts, power
point presentations, case reports, and book chapters reflecting the WRAMC affiliation must be cleared
through the Public Affairs Office and the Department of Clinical Investigation. If the document to be
cleared is related to combat or military operations, it must also be submitted to the WRAMC Brigade
S3, OPSEC (Building 14, Room P101). The following publications and abstracts require WRAMC
           --Reports involving WRAMC patients
           --Reports citing WRAMC in the title or byline
           --Reports of WRAMC approved clinical investigation research projects
           --Reports of research performed by WRAMC assigned personnel
           --Reports by WRAMC assigned personnel involving military operations.

               Proper clearance must be obtained before the publication appears in print in a journal, book,

          FOR SPECIFIC GUIDELINES refer to the Publication Clearance documents on DMRN.
           For research related publications, specific information should be included in the Materials and
           Methods or Acknowledgement section of all publications.
              - Complete the form found on the DMRN Web site.

           -    Include the Requester‟s Name, Rank, phone number, and fax number.
           -    Indicate whether the publication is an abstract, case report, paper, etc.
           -    Indicate whether the publication was related to a WRAMC approved research protocol
                             -If so, provide the work unit number and title.
           -    If this research was completed under an approved protocol at another institution, please
                specify the institution, protocol title, protocol number, and if this publication has been
                cleared for publication at that institution.
           -   If the publication has not been cleared at that institution, please provide an explanation.
           -   Indicate the specific journal, conference, etc. in which the manuscript is being submitted.
           -   Have Principal Investigator or primary author (if not research related), sign and date the
           -   Attach a copy of the publication with the clearance form.

              - Have your service chief and/or department chief review and sign the publication
                clearance form.
              - The form should then be forwarded to OPSEC if applicable, then to the Public Affairs
                Office (PAO) located on the 1st floor of Bldg 1 (opposite side of the building from the
                US Post Office and the small shoppette) for review and initial.
              - The clearance form will then be forwarded to DCI by PAO. For research related
                publications, DCI will verify that the research has received the appropriate institutional
                approval. Additional approval by the Directorate of Telemedicine may be required for
                Web publications.
              - Once the publication clearance has been reviewed and approved by DCI, it will be
                returned to the PI. This clearance should be kept in the Protocol Administrative Binder.
                If the publication is related to a WRAMC research protocol, this document should be
Revised: NOV 2009                                       19
              placed in the PI Protocol Administrative Binder, provided by the DCI at the time of
              receiving the DCI approval letter to begin the study.
          -   DCI keeps a master database of all publication clearances processed.

Revised: NOV 2009                                 20
                         DCI POINT-OF-CONTACT LISTING

                      ACTIVITY                     LOCATION     PHONE #
   Amendments/ Study Modifications                   Bldg 6   782-7861/7829
   Annual Progress Report                            Bldg 6     782-7848
   Adverse Events/Reports/Audits                     Bldg 6     782-7830
   Biostatistician                                   Bldg 6     782-7878
   Biostatistician                                   Bldg 6     782-6390
   Biostatistician, Chief                            Bldg 6     782-7840
   Clinical Studies Svc, Chief                       Bldg 6     782-7840
   Computer Operations, Team Leader                  Bldg 6     782-7884
   Computer Operations                               Bldg 6     782-7889
   DCI Chief                                         Bldg 6     782-6389
   Exempt Review Protocol                            Bldg 6     782-7880
   Extramural Funding                                Bldg 6     782-7859
   Grants/CRDA                                       Bldg 6     782-7810
   Investigational Drug Use                          Bldg 6     782-7830
   Medcase/CEEP                                      Bldg 6     782-7859
   NCOIC, DCI                                        Bldg 6     782-6391
   NCOIC, RRS                                        Bldg 6     782-7102
   Protocol Coordinators                             Bldg 6     782-7866
   Protocol Submission                               Bldg 6     782-7828
   Animal/Human/Lab                                  Bldg 6     782-7864
   Publication Clearance/CITI Course Cert.           Bldg 6     782-7823
   Research Review Svc, Chief                        Bldg 6     782-7858
   Asst Chief, RRS/IRB Administrator                 Bldg 6     782-7829
   Research Administrative Svc, Chief                Bldg 6     782-7859
   Research Operations (Labs)                        Bldg 7     356-1243
   Secretary to Chief, DCI                           Bldg 6     782-6389
   Supplies Requests                                 Bldg 6     782-7820
   TDY Orders (for protocol related travel)          Bldg 6     782-6391
   Time Extensions                                   Bldg 6     782-7848
   Fax                                               Bldg 6     782-3881

Revised: NOV 2009                             21