Clinical Research Governance
The Melbourne Children’s brings together four organisations; The Royal Children’s Hospital Melbourne (custodians of clinical care), the Murdoch Children’s Research Institute (custodians of research), the University of Melbourne, Department of Paediatrics (custodians of education) and The Royal Children’s Hospital Foundation at a single, purpose-built and multi-award winning campus in the city of Melbourne. This mutually beneficial relationship results in the delivery of high-quality clinical services underpinned by research and education.
Collectively, these independent entities contribute to a paediatric health sciences precinct which is greater than the sum of the parts. The presence of each benefits the other, ensuring the primary focus of each entity is achieved. The delivery of innovative, high quality paediatric care is unsustainable without the input of research and education. World class research into paediatric diseases and education of medical students/other health care professionals in paediatric health is not possible without access to a paediatric clinical environment. Hence the interdependence of the four partners.
Purpose
The purpose of this Clinical Research Governance and Support Handbook is to provide an overview of the current governance arrangements for clinical research undertaken at MCRI and RCH. It provides descriptions of the roles involved in the different governance, approval, or regulatory functions across the two organisations and, in doing so, informs the research workforce in understanding the relevant roles and governing bodies that support the clinical research they are doing.
This document is supported by policies and standard operating procedures (SOPs)/procedures.
Scope
The governance arrangements described in this handbook are limited to clinical research. For this document, clinical research is defined as:
- Research involving the study of people (participants), or their data/samples, to understand human health and disease.
- Research undertaken by RCH and MCRI staff and students on campus with RCH patients, research participants, and consumer partners.
Clinical research therefore includes clinical trials and other participant facing research happening on campus.
Additional governance sign-off and/or requirements not articulated in this handbook may be necessary for research occurring outside the campus including community, external health services, education providers, and overseas clinical research.
NOTE: This handbook does not cover governance arrangements for animal or basic science research (as defined by the NHMRC).
There are several binding instruments between institutional partners of Melbourne Children’s and external groups that impact research governance, including but not limited to:
- Melbourne Children’s Relationship Agreement (Melbourne Children’s Campus Partners)
- MoU for Centralised Ethical Review (RCH & DHHS, on behalf of the State of Victoria)
- MoU for the Melbourne Children’s Trials Centre (RCH & MCRI)
- Shared Funding Agreement for Research Ethics & Governance (Melbourne Children’s Campus Partners)
Research has the potential to create life-changing advances in treatments, prevention, and better health outcomes for all. Through research we can prioritise the care that matters most, in the areas of prevention and early detection, better care, and health services and systems research.
This Handbook is one of the documents (along with the relevant agreements, policies, and procedures) that supports compliance with applicable laws, regulations, standards, codes, and guidelines including, but not limited to: the National Statement on Ethical Conduct in Human Research (National Statement), the Australian Code for the Responsible Conduct of Research (The Code), the National Clinical Trial Governance Framework (NCTGF), and the ICH Guideline for Good Clinical Practice (ICH-GCP). Research ethics and governance compliance includes the ethical and scientific review of research, contractual and financial management of research, and research authorisation by the relevant authority.
It is the responsibility of all Melbourne Children’s researchers undertaking or assisting with clinical research to be aware of and apply the principles and processes outlined within this Handbook. This includes all related policies and procedures, guidelines, standards, general and specific legal obligations (statutory or otherwise), including updates, that occur from time to time.
Support Offices for Clinical Research
Ensuring good governance of research and compliance with all relevant laws, codes, guidelines, and regulatory areas is everyone’s responsibility.
The Melbourne Children’s has a number of departments set up to support clinical research and clinical trials. These Support Offices have a unique role to play in clinical research/clinical trial governance. They are administered by different entities across the Melbourne Children’s Campus, but work collaboratively to help Principal Investigators and Clinical Leads deliver the best possible care.
The table below provides a high-level summary of the key role of these groups. A full description of the function of each of the Support Offices is described below.
Department |
Summary of Function |
RCH Research Ethics & Governance Office (REG)
|
Manages and supports the Human Research and Ethics Committee (HREC). Research and Ethics Governance Officers provide the initial contact and assistance with the application process. This team provides ethics approval and/or governance (SSA) authorisation for human research. |
RCH Research Operations
|
Leading the development of the RCH Research Strategy, setting direction, leading change, and representing RCH internally, state-wide, nationally, and internationally. |
Melbourne Children’s Research Unit (MCRU) |
The Melbourne Children’s ReseaRCH unit (MCRU) is a dedicated clinical research space in the RCH. Located on level 2 West, its primary use is for clinical trials run by staff of the Melbourne Children’s Campus, with a particular focus towards facilitating commercially sponsored clinical trials. The Clinical Nurse Consultant Research & Trials (CNC) manages MCRU and is supported by the MCRU Ward Clerk. |
Melbourne Children’s Trials Centre (MCTC)
|
Responsible for facilitating a campus ecosystem supportive of high-quality clinical trials. Supports clinical trial design, protocol development, implementation, conduct, and trial workforce development. Can directly coordinate and manage select trials. Supervises the operations of clinical research space for low acuity trials and other participant facing research. Provides advice, assistance, and mentorship in all aspects of Investigator Initiated Trials (IIT) including design and conduct Facilitates the process of sponsorship for MCRI Investigator Initiated Trials (IIT) including ongoing quality assurance Supports selection, finance, resourcing and conduct of Commercially Sponsored Trials (CST) Prepares and support campus for advanced therapies and other capacity building initiative Prepares and support campus for NCTGF standards implementation and inspections
|
MCRI - Clinical Research Development Office (CRDO)
|
The trusted source for advice, guidance and support in relation to clinical research conduct and to provide resources, education and training that develops and supports a highly skilled, competent workforce. |
MCRI Research Support and Operations |
Research Support and Operations (RSO) manages the ongoing corporate operations of the MCRI. The department includes the following teams: Operations, Finance, Information Technology, Environmental Health and Safety, Legal, Cyber Governance, Scientific Services, and Risk and Compliance. MCRI Privacy Team Privacy hub to help researchers incorporate privacy-by-design into projects. Provide advice related to privacy matters including consent, privacy risks, data access requests. Manage data breaches and privacy complaints. MCRI Risk Management Team Responsible for managing risk, compliance, and insurance for the MCRI & VCGS. MCRI Legal Team Manages MCRI agreements and contracts. All MCRI agreements must be signed off by the Legal team. Responsible for advice and guidance on a wide range of legal matters. |
MCRI Office of Research
|
Houses research-specific areas such as Data Management & Governance, Research Grants, Research Performance, and Research Quality and Integrity. |
MCRI Office of the Director
|
Manages the institutes research strategy, major projects, government relations, consumer and community involvement, and research impact. |
MCRI Data Office |
Provide governance and support to the MCRI data ecosystem by supporting data governance policies and procedures, application and tools, data management planning, and safe data transfers. |
Melbourne Children’s Campus Consumer Involvement |
RCH Support and empower RCH staff and consumers to work in collaboration with each other to develop and deliver programs and initiatives that support better health outcomes for children and young people. Manage the RCH’s external consumer advisory groups and internal networks. Partnerships and Consumer Engagement MCRI Support capacity, capability and culture for consumer and community involvement in research at MCRI and across the Melbourne Children’s Campus, with a focus on research governance, the provision of training and coaching, Communities of Practice, and centering the voices of children. Working as a Campus These RCH and MCRI teams have made a commitment to partner on partnering with consumers and community members. Together they work to enable streamlined partnership opportunities, providing support for staff and consumers, and sharing resources and learnings for the Campus. |
Detailed Role and Function of Support Offices
RCH Research Operations
The RCH Research Operations department sits under the Division of Medical Services and reports to the Executive Director Medical Service and Chief Medical Officer. The Melbourne Children’s ReseaRCH Unit (MCRU) and Research Ethics & Governance (REG) Office are divisions within Research Operations.
Research Operations is responsible for leading the development of the RCH Research Strategy, setting direction, leading change, and representing RCH internally, state-wide, nationally, and internationally.
It is responsible for the overview and management of elements of research governance relating to compliance with legislation, directives from regulatory bodies, guidelines, and codes of practice.
Website: Research Ethics and Governance
Melbourne Children’s ReseaRCH Unit (MCRU)
Melbourne Children’s ReseaRCH Unit (MCRU), is a specialty outpatient day ward in which all high acuity clinical trials are conducted at RCH. The MCRU team is responsible for ensuring adherence to all policies relevant to the work occurring within MCRU, and provides professional oversight and support to trial teams who conduct trials within MCRU.
Research Ethics & Governance Office
The Research Ethics & Governance (REG) Office manages and supports the operations of the HREC and its subcommittees, in accordance with the applicable laws, regulations, standards, codes, and guidelines including the National Statement, Code, and GCP, as well as the relevant RCH policies and procedures.
The Research Ethics Managers, supported by the Research Ethics & Governance Officers, are the initial contact for the HREC and its subcommittees. They provide high level advice and timely responses to ethics and governance enquiries from researchers, clinicians, students, and health service practitioners in a paediatric and child health setting.
The REG Office reviews all applications for Human Research Governance Authorisation (SSA – Site Specific Assessments), and coordinates authorisation by the Director of Research Operations, as a delegate of the RCH Chief Executive and MCRI COO, of research studies to commence at the RCH and MCRI. This includes supporting researchers in obtaining supporting department sign off. They coordinate and oversee the processing of site-specific approvals, with the integration of ethical approvals from external organisations under the National Mutual Acceptance (NMA) scheme.
The REG Office also provides advice in areas concerning compliance with ethical guidelines and requirements, the monitoring of adverse events, and amendments to Protocols. They evaluate Progress Reports and Final Reports for research approved by the Human Research Ethics Committee (HREC), ensuring adherence to established protocols and approvals. As well as monitoring of adverse events, they implement periodic monitoring and audit initiatives to verify compliance with all applicable laws, regulations, standards, codes, guidelines (including the National Statement, the Code, and GCP), and institutional research policies. Monitoring and auditing frequency and methods are tailored based on the level of risk to participants, promoting ongoing researcher education in ethical research practices.
The REG Office facilitates review of all Research Contracts (in consultation with RCH and MCRI Legal Services) in relation to new research, amendments, confidentiality deeds, research collaborations, and funding agreements (with MCRI Grants). The RCH Director Research Operations, who leads the REG Office, has Level 5 delegation to review and approve research contracts in accordance with the RCH delegation of authority.
Website: Research Ethics and Governance
Melbourne Children’s Trials Centre (MCTC)
The MCTC is a collaboration between The Royal Children’s Hospital (RCH), Murdoch Children's Research Institute (MCRI), The Royal Children’s Hospital Foundation and the University of Melbourne, Department of Paediatrics.
MCTC is built on the principles of quality, efficiency, and innovation, facilitating clinical trials ranging from trialing novel therapeutic agents through to large public health prevention trials. MCTC invests in innovative trial designs and use of new technologies. MCTC enables researchers to bring new and novel therapies to children, and generates knowledge to improve healthcare for all children.
MCTC provides mentoring and support for externally sponsored trials run by clinical trial teams embedded within RCH and MCRI departments (Trial Nodes). This includes feasibility, budget and contract negotiations and ethics submissions. These activities are facilitated by the MCTC Business & Operations Manager and the Clinical Trial Nurse Lead.
MCTC also conducts commercially sponsored trials for a number of RCH Departments where the trial activity is insufficient to warrant the development of a specific Trial Node. These activities are conducted by a small team of experienced Research Nurse Coordinators who are responsible for the study visits, data entry, close-out, and archiving activities for each trial.
The centre also supports the development and implementation of high quality MCRI Investigator Initiated (IIT)- trials through involvement in the MCRI Sponsorship Committee, and mentoring, and advice to all members of the trial team at all stages of the trial from planning, through conduct, to sharing results. An experienced team of Clinical Trial Managers supports a small portfolio of MCRI-sponsored IITs run both locally and overseas. This team can be expanded as required and as funding permits. The centre is also responsible for managing communications/notifications to the Therapeutic Goods Administration, and registrations with trial registry provider ClinicalTrials.gov..
MCTC also has a key role supporting implementation of actions to comply with the National Clinical Trials Governance Framework, thereby supporting accreditation of RCH for both clinical service and clinical trial service provision. This work is supported by a dedicated NCTGF Implementation Lead, who works across both organisations to ensure harmonisation of systems and processes with the clinical service.
MCTC’s collaborations with the Clinical Research Development Office (CRDO), Clinical Epidemiology and Biostatistics Unit (CEBU), and leading health economists at the University of Melbourne support these initiatives.
Website: https://www.mcri.edu.au/research/core-facilities-services/melbourne-children-trials-centre
Clinical Research Development Office (CRDO)
CRDO is funded by the Murdoch Children's Research Institute. It works in close collaboration with the Melbourne Children’s Trial Centre, Clinical Epidemiology and Biostatistics Unit (CEBU), RCH Research Ethics and Governance (REG) Office, MCRI Legal, MCRI Privacy, and MCRI Data Office.
CRDO provides education, training, and support to clinical research staff at Melbourne Children’s campus. This includes a suite of regular workshops, educational fora, and the development and maintenance of a large portfolio of Standard Operating Procedures designed to assist research teams to build quality by design into their projects as well as meet their responsibilities to various stakeholders including research participants, the HREC, the RCH Research Ethics & Governance team, trial Sponsors, and the Therapeutic Goods Administration. CRDO also provides mentoring to researchers at all stages of their project, from planning through conduct, analysis, and dissemination of results.
The CRDO Lead/Quality and Regulatory Manager is responsible for the development and implementation of the strategy for CRDO that supports the delivery of high-quality clinical research. This position is supported by the CRDO Training and Development Coordinator and the MCTC Sponsorship and Regulatory Binder Coordinator.
The Qualitative Research Lead sits within CRDO and is responsible for improving MCRI’s capacity to provide high quality qualitative and mixed methods research by building capacity through training and professional development, developing resources, and maintaining the Qualitative Research Community of Practice.
Website: Clinical Research Development Office
MCRI Research Support and Operations
Headed up by the Chief Operating Office of the MCRI, Research Support and Operations (RSO) manages the ongoing corporate operations of the MCRI. The department includes the following teams: Operations, Finance, Information Technology, Environmental Health and Safety, Legal, Cyber Governance, Scientific Services, and Risk and Compliance. RSO is also responsible for the ongoing operations of MCRI and MCRI research.
In the context of clinical research, RSO is responsible for providing infrastructure and resources. They also authorise contractual and indemnity arrangements, privacy and cyber governance obligations, and delegation of authority for senior level management and governance authorisations.
The below outlines the key teams within MCRI Research Support and Operation who have a substantial role in providing support for governance of clinical research (as defined in this handbook).
MCRI Risk Management
The risk management team identifies, assesses, and mitigates risks related to operations, research, and finances. They are responsible for the development and implementation of risk policies and frameworks to support decision making and ensure regulatory compliance. Overall, they work to protect the institute’s assets, support reliable research outcomes, and maintain safety and compliance.
MCRI Legal
MCRI Legal provides advice and guidance on a wide range of legal matters including insurance, intellectual property, privacy, confidentiality, conflicts, material transfer, biobanking, and marketing initiatives.
The Legal team manages a wide range of agreements and contracts, including Materials Transfer Agreements, Confidentiality Agreements, Contractor/Services/Consultancy Agreements, Collaboration (Research) Agreements, Licence Agreements, Non-NHMRC Funding Agreements, Placement and Student Agreements, Amendment and Variation Agreements, Memorandums of Understanding, and Letter Agreements. They also manage MCRIs Insurance portfolio including work related travel insurance, international clinical trial cover, insuring equipment, cover for risks associated with medical treatment, professional advice and public liability, certificate of currency requests, managing claims, and providing advice on insurance coverage across partnerships and collaborations.
All MCRI agreements must be signed off by the Legal team. These agreements establish enforceable obligations and provide valuable rights so as to limit MCRI’s legal and financial exposure.
MCRI Privacy Team
The Privacy team supports privacy training, self-education, and advice on how to incorporate privacy-by-design into the research projects lifecycle. In collaboration with legal, ethics & data, and IT teams, they provide advice related to privacy matters including consent, privacy risks, and data access requests. The team also staffs the role of Data Protection Officer and Privacy Officer for MCRI ensuring the provision of: privacy advice on the development of new initiatives that have a potential privacy impact, the general application of privacy law to research activities, safeguarding the privacy of participants and support, and Privacy Impact Assessments. The team are also responsible for managing data breaches and privacy complaints.
MCRI Office of Research
The MCRI Office of Research houses research-specific areas such as Data Management & Governance, Research Grants, Research Performance, and Research Governance and Integrity. The Office of Research, headed up by the MCRI Deputy Director, is responsible for the oversight of research data, grants, research integrity processes (including compliance with the Australian Code for the Responsible Conduct of Research), analysis of research performance, student onboarding and support, researcher development, and prizes and awards.
MCRI Office of the Director:
The MCRI Office of the Director, led by the Director of MCRI, manages the institutes research strategy, major projects, government relations, research impact, and engagement. The office is responsible for setting the strategic directions for campus research, facilitating government and consumer engagement, and research impact.
MCRI Data Office
MCRI's Data Office is led by Chief Data Officer. The team's purpose is to optimise the data ecosystem by supporting data governance across the research lifecycle. It is responsible for developing policies, application and tools, and data management planning, to support good data governance across the MCRI. The data team also manages the CAB: Data stream which reviews and approves certain data transfers.
Partnering with consumers at Melbourne Children’s Campus
- RCH Partnerships and Consumer Engagement Team: Support and empower RCH staff and consumers to work in collaboration with each other to develop and deliver programs and initiatives that support better health outcomes for children and young people. Manage the RCH’s external consumer advisory groups and internal networks.
- MCRI Research Impact and Consumer Involvement Team: Support capacity, capability and culture for consumer and community involvement in research at MCRI and across the Melbourne Children’s Campus, with a focus on research governance, the provision of training and coaching, Communities of Practice, and centering the voices of children
- A Campus approach to consumer engagement: These RCH and MCRI teams have made a commitment to partner on partnering with consumers and community members. Together they work to enable streamlined partnership opportunities, providing support for staff and consumers, and sharing resources and learnings for the Campus.
Governance Committees
This section introduces the various governance committees across the campus and includes their scope, role, and responsibilities.
Clinical Trials Governance Committee
The RCH is committed to delivering clinical trials for its patients with its campus partners.
The purpose of the Committee is to ensure appropriate governance and risk management in clinical trials involving RCH patients, and to monitor compliance with relevant clinical research standards and guidelines including the Therapeutic Goods Administration (TGA)’s Australian Clinical Trial Handbook, The National Clinical Trials Governance Framework (NCTGF), ICH Guideline for Good Clinical Practice (ICH-GCP), the National Statement on Ethical Conduct in Human Research (National Statement), organisational policies and procedures, and international regulatory agencies where applicable.
The committee will provide clinical governance, risk and compliance oversight, and strategic and advisory functions to the relevant Executive committees, clinical researchers, clinical research support staff, and other stakeholders as needed.
Chair: Co-chair RCH Executive Director Medical Services and Clinical Governance and MCTC Medical Director
Frequency: Quarterly
Reports to: RCH Executive Clinical Quality and Safety Committee
Campus Council
Campus Council was established by the May 2008 Deed of Undertaking between The Royal Children's Hospital, The Royal Children's Hospital Foundation, Murdoch Children's Research Institute, and the University of Melbourne. Campus Council provides strategic leadership and advocacy for paediatrics and child health generally. It enhances the collaboration and co-operation of the campus partners to achieve a world renowned paediatric academic health centre. Campus Council assists each campus partner in their pursuit of excellence, whether it be in prevention, clinical service delivery, fundraising and philanthropy, child health research, or the training of clinicians, researchers, and educators.
Chair: MCRI Director
Frequency: Quarterly
Campus Research Committee
The Campus Research Committee is an advisory committee of the Campus Council.
The Campus Research Committee strengthens and maximizes research opportunities on Campus for discovery, knowledge creation, and translation into quality care for children and young people.
Their functions include: Maximise child and adolescent health research on campus; Identify high-level strategic priorities for campus-wide research for consideration by Campus Council; Advise Campus Council on appropriate performance measures for research on campus; Encourage effective communication between researchers and clinicians; Provide Campus Council with feedback on campus research issues; Oversee and advise on ongoing conduct of joint strategic initiatives.
Chair: MCRI Director
Frequency: Quarterly
Reports to: Campus Council
Human Research Ethics Committee and Drug Trials Subcommittee
The purpose of the Human Research Ethics Committee (HREC) and the Drug Trials Subcommittee (DTS) review the ethical and scientific validity of proposed research projects; including RCH and MCRI research conducted in other states and overseas. The role of the HREC and supporting team is to ensure clinical research happening on campus meets the National Statement on Ethical Conduct in Human Research.
The HREC acts in a consultative and advisory capacity with researchers to ensure that all clinical, research, and management practices are conducted in an ethical and scientifically robust manner, and to promote and foster ethical and good clinical/health research practices that are of benefit to the community.
The HREC Chair provides leadership to the HREC and DTS and ensures that the HREC is functioning in accordance with all applicable regulations and standards. The position promotes compliance with Commonwealth and State regulations, sponsor and institutional policies and procedures regarding the safety and welfare of human participants involved in research studies, and provides advice on human research ethics matters as they arise.
Chair: Human Research and Ethics Committee– appointed by the RCH Board. Chair of DTS is the Lead Clinical Trials Pharmacist
Frequency: 11 meetings a year
Reports to: RCH Board
Terms of Reference – Human Research and Ethics Committee
RCH Research Innovation & Improvement Committee (and Research Leads)
The purpose of the Research Innovation and Improvement Committee (Research Lead) role is to foster and support engagement with clinical research, both within their RCH department and with their associated MCRI Group(s). The primary focus of the Department Research Lead is to support members of their clinical department to engage in, and foster, clinical research to provide the best possible evidence-informed care for patients.
Chair: Co-chairs: Research Lead (rotate 2 yearly), appointment by ED Medical Services and Director Research Operations
Frequency: Monthly or as required.
Reports to: Clinical Quality and Safety Committee
Terms of Reference: Research Innovation and Improvement Committee
MCRI Sponsorship Committee
The Sponsorship Committee’s responsibilities apply to all clinical trials where MCRI is proposed as the Sponsor. MCRI will only sponsor trials where the lead Investigator, herein known as the Sponsor-Investigator, is either a paid employee of MCRI or RCH. RCH employees must either be an employee of MCRI or hold an MCRI honorary position. The Sponsorship Committee does not have any oversight of trials sponsored by an external organisation, e.g. pharmaceutical company or collaborative group, public/private hospital, medical research institute or university).
The Sponsorship Committee reviews applications asking MCRI to sponsor clinical trials, to ensure that institutional risks are identified and acceptable, and appropriate reduction/mitigation strategies are in place or planned.
The Committee provides approval (initial and ongoing) for MCRI to sponsors a trial once satisfied that risk-proportionate processes have been implemented that manage the safety of trial participants and the reliability of the trial data throughout the trial life cycle. The Committee fulfills MCRI’s sponsor responsibilities for trial oversight for the trials they approve for MCRI Sponsorship.
Chair: Medical Director MCTC
Frequency: Monthly (or as required)
Reports to: Campus Clinical Trials Governance Committee
Institutional Biosafety Committee
All research conducted with Genetically Modified Organisms (GMOs) and genetic manipulation must carried out in accordance with the legislation outlined in the Gene Technology Act 2000, Gene Technology Regulations 2001, and subsequent amendments.
In accordance with this legislation, the MCRI Institutional Biosafety Committee (IBC) has been established to oversee that work of this nature conducted within the Melbourne Children’s campus conforms to these legal requirements.
Research involving GMOs must be approved by the MCRI IBC before work commences. The IBC reviews and approves all applications before work commences, including performing human clinical trials involving GMOs on the Melbourne Children’s campus. The RCH uses the MCRI IBC.
Chair: Shireen Lamade
Frequency: Monthly (or as required)
MCRI Data Transfer - Change Advisory Body
MCRI has implemented the Data Transfer - Change Advisory Body (DT-CAB) to ensure that appropriate governance and information security measures are considered when dealing with MCRI data. This includes clinical research data, and is supported by robust data governance frameworks, data management policies, and training across the whole data lifecycle.
DT- CAB provides oversight and final approval of data transfer proposals in order to optimise the efficiency and effectiveness of the transfer, while minimising risk, and ensuring visibility. They do this by bringing together Privacy, Legal, Cybersecurity, IT, Data Office and researchers at committee meetings. The committee actively reviews the nature of the data (classification, type, volume, format, cybersecurity), the method of transfer (data flows, tools, and systems), nature and access of involved entities (people or organisations), and location of data (start and end).
Any transfer of data into or from MCRI is within scope for the DT-CAB. Transfer that involves only publicly available data or are wholly within MCRI/VCGS are outside scope.
Chair: MCRI Research Data Manager
Frequency: Weekly (as required)
Terms of reference: CAB Data Transfer Stream
Operational Requirements for Clinical Research Governance
The operational requirements come under the following headings. A detailed description of the roles & responsibilities under each heading is included below.
Collaborations and Contracts
Collaborative research between institutions can take various forms, include research partners in industry, government, and not-for-profit sectors, and research team members from multiple countries.
Collaborative research can pose a range of challenges, including the need to accommodate specific research methodologies, different research practices in different research institutions, variations in regulatory and legal systems, institutional funding arrangements, organisational structures, and differing research cultures. These challenges should not be seen as a barrier to collaborative research, but as elements to be managed through normal risk management processes.
Agreements must cover (but is not limited to) sharing of research funds, intellectual property, data privacy, confidentiality and copyright issues, sharing, commercial returns, insurance, responsibility for ethics and safety clearances, and reporting to appropriate agencies. It should address the protocols to be followed by the partners when disseminating the research outcomes, and the management of primary research materials, and research data.
Campus research is supported by Australian public funding, so the Collaborative research guide that accompanies the Australian Code for the Responsible Conduct of Research is also to be followed.
Grants and Funding
Organisations involved in research projects and clinical trials are required to undertake Good Stewardship of Public Resources used to conduct research, and ensure that research funds are managed in accordance with relevant funding arrangements, legislation, and RCH/MCRI policies and procedures.
Research grant funding is awarded to researchers working on individual research projects, for the purpose of advancing research in their field of expertise with that project.
The MCRI Grants team within the Office of Research is the registered administrative contact for external peer‐reviewed granting agencies and MCRI internal competitive funding schemes.
All competitive research funding applications at the RCH and MCRI must be prepared in consultation with the Grants Office.
Research Approvals
All RCH and MCRI clinical research must have the appropriate approvals in place prior to the commencement of the research. The RCH and MCRI has various approval processes in place to ensure they support research that is ethical and safe. The approvals required depends on the type of research being conducted. These include:
- If the research involves patients and/or their families, or other community participants, tissues, cells, or data from the RCH, the application to conduct research must be approved by the RCH HREC or another NMA participating reviewing HREC.
- All clinical research must also seek governance authorisation from the RCH Research Ethics and Governance (REG) office. Further information can be found at the REG website.
- The Human Research Ethics Application (HREA) provides the mechanism for ethics approval of human research, to ensure it is conducted ethically and in accordance with the National Statement.
- The Site Specific Assessment (SSA) provides the mechanism for governance authorisation of clinical research to commence at RCH and MCRI. It ensures RCH and MCRI has the appropriate resources to support and facilitate the research, and that the contractual, risk, and financial management of the research has been authorised. SSA is the local institutional due diligence process by which the suitability of a clinical research study to take place in the context of the specific facility is assessed.
- Sponsorship committee approval provides MCRI institutional approval of MCRI-led investigator initiated clinical trials to ensure risks associated with trial sponsorship are appropriately managed.
Risk & Regulatory Compliance:
Clinical Research / Trials undertaken at Melbourne Children’s should sit within the Institute’s risk appetite and require the appropriate levels of risk assessment / mitigation and regulatory compliance. This includes (but not limited to):
- Risks associated with clinical research on patients, participants, staff, the community, the environment, and the MCRI and/or RCH.
- MCRI/RCH has the appropriate oversight, indemnity, facilities, and resources to support and facilitate the research.
- All clinical research / trials comply with relevant RCH/MCRI policies, procedures, and standards, as well as all other applicable laws, regulations, standards, codes, and guidelines.
- Clinical research activity is appropriately insured and the relevant risks are appropriately managed by the study team, with support from the MCRI Risk Management team.
Monitoring:
Monitoring is the act of overseeing the progress of a research study/clinical trial and checking it is conducted, recorded and reported in accordance with the protocol, relevant Standard Operating Procedures (SOPs), and applicable regulatory requirements and local policies/procedures.
The purpose of monitoring is to:
- Protect the rights and wellbeing of the research participants.
- Ensure the data are accurate, complete and verifiable
- Ensure recruiting sites conduct the study according to the approved protocol and ongoing legal and regulatory requirements.
All clinical trials conducted under a CTN/CTA must implement a risk-based monitoring program. Monitors are appointed by the Sponsor of the trial. For MCRI-sponsored trials, the Sponsor-Investigator is responsible for appointing a Monitor(s). Monitors must be independent of the Sponsor-Investigator and the Central Trial Coordinating Team. For clinical research that is not a trial, monitoring may be used as part of the study risk mitigation/monitoring strategy.
Supporting Policy/ Procedure: MCTC046 SOP | Monitoring Visit Activities for Clinical Trials of Investigational Products
Internal Audits
Internal audits assess compliance with defined standards at a given moment in time. Internal auditing is distinct from ‘monitoring’, which refers to the research team’s continuing research oversight and quality control measures.
National and international guidelines outline the role and responsibilities of both Research Institutions and Clinical Trial Sponsors for auditing human participant research projects.
There is a requirement to audit research practices to assess compliance to the study protocol, GCP, SOPs, and all applicable legal and regulatory requirements, as a part of a quality management system.
The purpose of the Internal Audit Program:
- Evaluate trial conduct and ensure researchers’ compliance with the protocol, SOPs, GCP, regulatory requirements, and MCC policy.
- Ensure participant and staff safety.
- Ensure participant rights, welfare and well-being are being adequately protected.
- Assess data quality and integrity.
- Improve research systems and data quality.
- Prepare researchers for external audit processes.
- Demonstrate robust research processes to external funders and industry.
- Review reports from independent agencies.
Data Governance
Good data management is the foundation of good research. When data are properly organised, preserved, and well documented, and their accuracy, validity, and integrity is controlled at all times, the result is high quality data, efficient research, outputs based on solid evidence, maximised potential for future research, and reduced waste of resources of value to researchers and the wider community.
All clinical research / trial data must be managed in accordance with the MCRI Data Governance Framework.
Research must adhere to the NHRMC Guidance: Management of Data and Information in Research: A guide supporting the Australian Code for the Responsible Conduct of Research, and the relevant institution of Melbourne Children’s data and records management policies and procedures (e.g., RCH, MCRI).
Data breaches (any incident in which data is compromised, disclosed, copied, communicated, accessed, removed, destroyed, stolen, lost, or used by unauthorised individuals, whether by accident or intentional) involving MCRI/RCH data must be notified to the Research and Ethics Office and MCRI as per the Data Breach Response Plan.
Supporting Policies MCRI Data Breach Policy
Quality & Safety Improvement Systems
Safety monitoring and reporting in the form of adverse events, incidents and breaches of good clinical practice is essential for patient safety and integrity of clinical research. It helps to create a culture of quality improvement by using lesson learnt to drive continuous improvement.
The responsibility for safety monitoring and reporting requirements lies with the sponsor of a clinical trial, defined as ‘an individual, organisation or group taking on responsibility for securing the arrangements to initiate, manage and finance a study’.
All clinical research/trials adverse events/incidents and GCP breaches are to be managed in accordance with the MCC Safety Monitoring and Reporting Procedure
Researchers must adhere to the NHMRC safety Monitoring and reporting in clinical trials involving therapeutics goods.
The Safety Monitoring and Reporting Adverse Events Procedure below provides a road map as to what, how and when adverse events are to be reported on campus.
Supporting Policies Procedure: Safety Monitoring and Reporting Procedure for MCRI-Sponsored IITs of Medicine / medical Devices.
Clinical Trial Workforce Roles and Responsibilities
Based on the ACQSHC Fact Sheets
Role |
Role Definition |
Governing Body |
A governing body is an individual or group that has ultimate responsibility for strategic decisions affecting safety and quality in a health service organisation. It may be a board, chief executive officer, organisation owner, partnership. It is the highest level of governance. |
Sponsor
Related: Contract Research Organisations (CRO) |
All clinical trials conducted in Australia must have a trial sponsor that is an Australian entity. Sponsors of trials under the Therapeutic Goods Administration’s Clinical Trial Notification (CTN) or Clinical Trial Approval (CTA) schemes may include individuals, companies, institutions, or organisations. At the Melbourne Children’s Campus, the MCRI is the Sponsor for Investigator-Initiated Trials led by researchers from RCH or MCRI. |
Sponsor Investigator |
An individual who both initiates and conducts, alone or with others, a clinical trial, and under whose immediate direction the investigational product is administered to dispensed to or used by a subject. The responsibilities of a sponsor-investigator include both those of a sponsor and those of an investigator. |
Coordinating Principal Investigator |
The Coordinating Principal Investigator (CPI) is a Principal Investigator in a multi-centre trial who takes on additional responsibilities for coordination of the study across all sites in a region (as specified in the Lead Ethics Approval Letter). They have overall responsibility for coordinating the administrative processes of the ethical review of a multi-centre trial. This includes communicating the outcome of the single ethical review to site Principal Investigators and coordinating the ongoing reporting of the ethical progress of the research project to the HREC and Sponsors. |
Site Principal Investigator Associate Investigator/Sub-Investigator |
The site principal investigator is the person responsible, individually or as a leader of the clinical trial team at a site, for the conduct of a clinical trial at their site. As such, the site principal investigator supports a culture of responsible clinical trial conduct in their health service organisation, in their field of practice. They are responsible for adequately supervising their clinical trial team, and ensuring they are conducting the clinical trial as per the ethically approved protocol and their site-specific approval. The site principal investigator may share and / or delegate their responsibilities to an Associate Investigator/ Sub Investigator. Clinicians working on clinical trials are responsible for their own professional practice as required by their professional codes of conduct. |
Clinical Trials Manager / Coordinator
|
A clinical research manager / coordinator has a critical role in planning, facilitating, supporting, and coordinating clinical research activities. This could be at site level or, in the case of IITs, at Sponsor level (with purview across all sites) (depending on the scope of their role). |
Site Specific CT Staff
|
Site-specific clinical trial staff who manage and conduct the day-to-day activities of clinical trials/ research. They work under the direction of the Principal Investigator who will delegate specific clinical trial related tasks to specific staff members. |
Clinical Trials workforce includes:
|
Clinical trial staff work within and are supported by health service organisations and trial sites (including MCRI) to deliver high-quality clinical trials in a safe environment. Clinical trial workforce staff communicate, and work, with their governing body, clinical and non-clinical managers, clinicians, clinical trial team members, participants, consumers, and sponsors to implement the Governance Framework. |
RESPONSIBILITIES
THE GOVERNING BODY |
A governing body is an individual or group that has ultimate responsibility for strategic decisions affecting safety and quality in a health service organisation. It may be a board, chief executive officer, organisation owner, partnership. It is the highest level of governance. |
GENERAL
PARTNERING WITH CONSUMERS
|
WIDER CLINICAL TRIALS WORKFORCE
All staff involved in any aspect of developing, conducting and supporting clinical trials are considered as part of the ‘Clinical Trial Workforce’ and therefore have the following responsibilities:
ALL MEMBERS OF THE CLINICAL TRIAL WORKFORCE |
Clinical trial workforce staff work within and are supported by health service organisation and trial sites to deliver high quality clinical trials in a safe environment. |
GOVERNANCE LEADERSHIP AND CULTURE
SAFETY AND QUALITY IMPROVEMENT SYSTEMS
CLINICAL PERFORMANCE AND EFFECTIVNESS As relevant to the scope of their role and delegation:
SAFE ENVIRONMENT
PARTNERING WITH CONSUMERS
DATA MANAGEMENT
|
CLINICAL TRIAL TEAM MEMBERS
The roles listed below have additional responsibilities based on their position in the Clinical Trial team.
CLINICAL TRIAL SPONSORS |
All clinical trials conducted in Australia must have a trial sponsor that is an Australian entity. Sponsors of trials under the Therapeutic Goods Administration Clinical Trial Notification (CTN) or Clinical Trial Approval (CTA) schemes may include individuals, companies, institutions, or organisations. For investigator-initiated trials, the health service organisation or trial site that is the approving authority may also be the trial sponsor. The below applies equally to external sponsors (eg pharmaceutical companies) and sponsor-investigators for investigator-initiated trials. |
GENERAL
Trial sponsors, or their delegate, are also required to:
Acknowledge those who have contributed to the clinical trial, and cite and acknowledge other relevant work appropriately and accurately*. * Principally relates to commercially sponsored clinical trials.
SAFETY AND QUALITY IMPROVEMENT SYSTEMS
CLINICAL PERFORMANCE AND EFFECTIVENESS – IF THE HEALTH SERVICE IS THE SPONSOR If the health service organisation is the sponsor of a clinical trial, they have a responsibility for monitoring the conduct of a clinical trial for compliance with relevant regulations and requirements, and should ensure they have sufficient resources to meet all of their monitoring obligations. At the Melbourne Children’s Campus, the MCRI is the Sponsor for Investigator-Initiated Trials led by researchers from RCH or MCRI. In this case, the health service organisation should:
|
COORDINATING PRINCIPAL INVESTIGATORS |
The Coordinating Principal Investigator is the person responsible, individually or as a leader of the clinical trial team at all sites, for the conduct of a clinical trial at all sites. |
GENERAL
|
CLINICAL TRIAL MANAGERS / COORDINATORS |
A clinical research manager / coordinator has a critical role in planning, facilitating, supporting, and coordinating clinical research activities. This could be at site level or, in the case of IITs, at Sponsor level (with purview across all sites) (depending on the scope of their role). In this document, we use the term “Clinical Trial Manager” for a person performing Sponsor-level activities, and “Clinical Trial Coordinator” for a person performing Site-level activities. The list of responsibilities below covers both of these, but which ones you are specifically responsible for will depend on the scope of your role. |
GOVERNANCE LEADERSHIP AND CULTURE
COLLABORATION AND CONTRACTS
GRANTS AND FUNDING
RESEARCH APPROVALS
MONITORING/AUDITING/INSPECTING
SAFETY AND QUALITY IMPROVEMENT SYSTEMS
PARTNERING WITH CONSUMERS
|
PRINCIPAL INVESTIGATORS |
The site principal investigator is the person responsible, individually or as a leader of the clinical trial team at a site, for the conduct of a clinical trial at that site. |
GENERAL Ensures adequate clinical cover is provided for the trial.
CLINICAL PERFORMANCE AND EFFECTIVENESS
COLLABORATION AND CONTRACTS
GRANTS AND FUNDING
RISK AND REGULATORY COMPLIANCE
TRIAL CONDUCT
SAFETY OF TRIAL PARTICIPANTS
REPORTING
CLINICAL LEADERSHIP
MONITORING/AUDITING/INSPECTING
SAFETY AND QUALITY IMPROVEMENT SYSTEMS
PARTNERING WITH CONSUMERS
AUTHORSHIP
* Principally relates to investigator initiated clinical trials. |
This document undergoes rolling reviews. For any updates or feedback please contact [email protected]