This is generally covered (or should be) under the special consent forms
that participants sign to join the trial.  The clinical trial consent should
be adapted to cover the scope of the trial, as well as the additional
disclosure requirements for: Monitor review/audit of the patient records;
FDA adverse event notifications.  The bulk of the trial data is
de-identified anyway for statistical and regulatory submission purposes.
However, I have not done a careful comparison between the ICH GCP, the FDA
21cfr11, and HIPAA Privacy for conflicts and overlaps yet. Additionally, the
Business Associate and Trust Agreement issues need to be explored.  But
clearly, there is an issue here for more exploration relating to how HIPAA
reacts in the tighter trials environment.  Also I foresee training to be an
interesting issue too!

I would be happy to discuss this further offline.  My email address is
[EMAIL PROTECTED]  FYI, I have many years of clinical trial
software and applications development experience, as well as trial process
re-engineering under FDA & ICH regs.  Please feel free to contact me
regarding the above issues.

Regards,

Tim McGuinness, Ph.D.
President
HIPAA Help Now Inc.  (www.hipaahelpnow.com)
[EMAIL PROTECTED]
phone: 305-753-4149

-----Original Message-----
From: Vishnevsky, Jacob [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, July 16, 2002 1:38 PM
To: '[EMAIL PROTECTED]'
Subject: Patience Diaries
Importance: High


Could anybody comment on any latest development in area of patience diaries
and clinical trials,
in other words, there are obvious ambiguities in terms of the need for
disclosures authorizations and general information protection during dairies
review process and so on,
Any comments are welcome

Jacob Vishnevsky
Stelex-TVG
Two Greenwood Square, Suite 310
3331 Street Road
Bensalem, PA 19020
phone: (215) 352-1133
cell:(215) 421-8539
fax: (215) 638-9333
email: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]>



-----Original Message-----
From: Angie Lehman [mailto:[EMAIL PROTECTED]]
Sent: Monday, July 15, 2002 4:26 PM
To: '[EMAIL PROTECTED]'
Subject: RE: please remove me from your listserv



Thank you

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