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Terri P. Kelly, RN, MSQA, CQA President and Principal ... - FDA News

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Sponsor Warning Letters<br />

•[21 CFR 812.43(c)]Failure to obtain a signed agreement from<br />

each participating investigator, which must contain a<br />

commitment from the investigator to promptly update the<br />

financial disclosure information if any relevant changes occur<br />

during the course of investigation <strong>and</strong> for one year following<br />

the completion of the study.<br />

•Response: SOPs instituted to monitor investigator financial<br />

involvement<br />

•<strong>FDA</strong> Response: Provided SOPs inadequate; do not include<br />

provision of monitoring, whereby investigators are required to<br />

provide a financial interest update following changes in their<br />

financial interests in the company for one year following the<br />

completion of the study.

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