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Remote trial activities: mapping responsibilities by procedure

Adding home visits or telehealth does not automatically simplify trial responsibilities.

Cover image for: Remote trial activities: mapping responsibilities by procedure
Photo: National Center for Advancing Translational Sciences from Bethesda, MD · License: Public domain · Cropped and resized.
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Adding home visits or telehealth does not automatically simplify trial responsibilities. Sponsors and investigators can map each remote procedure to its safety communication and data pathway before asking sites or participants to use the proposed approach.

Separate procedures from delivery methods

FDA guidance on decentralized elements provides recommendations for activities outside traditional sites. Whether a procedure is suitable for remote delivery depends on the product, protocol, participant and clinical assessment needed. Grouping every visit under a technology label can hide important clinical differences between procedures.

Map the safety pathway

For each procedure, identify the performer, medical oversight, location of source records and route to the investigator. Clarify who assesses an abnormal measurement taken at home and when. A system sending a message does not by itself prove that an appropriate clinical review occurred.

Test practical feasibility

Review local healthcare-provider activities for training, competence and record access. Measurement technique and device consistency can affect endpoint comparability. Participants’ home circumstances and accessibility needs determine whether the proposed visit is practically achievable, even when the technology meets its technical specification.

  • Assign a performer and source-record location to each procedure.
  • Test investigator access for an abnormal finding.
  • Define a site alternative for unsuccessful remote procedures.

Plan interruptions and exceptions

Create separate routes for lost connectivity, device failure and a clinical emergency. Provide a site alternative for procedures that cannot be completed remotely. During a pilot, follow a safety message from collection through investigator assessment and assign owners to failed handoffs before broader implementation.

Frequently asked questions

Does a remote visit remove investigator oversight?
No. Responsibilities and appropriate oversight must be explicitly planned.
Can one platform resolve every interruption?
No. Technical outages, clinical emergencies and unsuccessful measurements need different response pathways.

Sources

  1. FDA — Conducting Clinical Trials With Decentralized Elements
  2. eCFR — 21 CFR 312.60