Transcript Clinical Trial Budgets for Fiscal Managers

Clinical Trials 1
Darlene Kitterman, MBA, Director,
Investigator Support & Integration Services (ISIS),
Oregon Clinical & Translational Research Institute
(OCTRI)
Audience

This course is intended for “department
administrative staff”—including clinical research
coordinators, department administrators, division
managers, department fiscal managers,
department effort coordinators, etc.
Introduction
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This course follows the financial life cycle of a
clinical trial up to clinical trial implementation:
Policies and guidance
Budget preparation
Payment schedules
Set-up of Accounts
Third party payer approvals
What is a Clinical Trial at
OHSU?
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Clinical Drug/Device Investigation
Mission code 54
A study of a drug (device, or diagnostic) where it “…is
administered or dispensed to, or used involving, one or more
human subjects.” and is a "prospective biomedical or
behavioral research study of human subjects that is designed
to answer specific questions about biomedical...interventions
(drugs,... devices, or new ways of using known drugs...or
devices).”
Translation: A drug or device intervention into a person
Clinical Trial Financial
Policies and Guidance
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Research Study Rate Request, Account(s) Setup And
Billing Of Clinical Services (ADM 05.17)
Charges For Research Support (ADM 2.17)
Use of Devices in Patients and Research Subjects
(ADM 05.18)
Sponsored Projects Budgets and Cost Coverage (No.
04-40-020)
ORIO Enrollment Incentive Policy
Research Documentation in the Integrated Health
Record (HC-CLN-IHR-P005)
Clinical Trial Financial
Tools
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OHSU Hospitals and Clinics Research Rates, Accounts, Registration,
Admission, and Charging Processes and Forms
Webpage: http://ozone.ohsu.edu/research/rates/index.shtml
Clinical Trial Budget Templates
 Industry: http://ozone.ohsu.edu/research/rates/budget_template.xls
 Federal: http://ozone.ohsu.edu/research/rates/federalbudget.xls
Clinical Trial Budget Checklist:
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OHSU Hospital Services Charging Process For Research Studies:
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Clinical Study Billing Table:
http://ozone.ohsu.edu/research/hscs/billingtable.doc
Medicare Advantage Tools:
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http://www.ohsu.edu/research/crp/docs/budgetchecklist.doc
http://ozone.ohsu.edu/research/rates/researchaccount.pdf
 http://ozone.ohsu.edu/research/rates/Medicare_Advantage_Patient_Handout.pdf
 http://ozone.ohsu.edu/research/rates/Procedure_to_assign_guarantor.pdf
Budget Preparation
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Analyze costs
Identify standard of care vs. research procedures
Minimum: all research costs must be covered
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All tests and procedures
Salary support (investigator, study coordinator, other)
Professional fees (if not already getting salary support)
Other invoicable costs (informed consent translation, IRB initial and
continuing review fees*, pharmacy**, shipping, storage, subject
reimbursement, supplies, advertising, etc.)
If clinical services, complete Clinical Study Billing
Table
• Submitted with to IRB with application
• Submitted to PBS with Research Rates Request Form
*Required if industry sponsored, **Required if study of drug
Budget Preparation
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Determine rates
 Hospital Services
• Technical Fees
– Obtain from Clinical Department Contact or Research Rates Database
– Federal:
» Must use research rate
» Hospital price X Research Rate % = Research price
– Industry sponsored:
» Budget for full price if possible
» Will be charged research price (see below)
– Budget for ~10% increase per year
– Route Research Rate Request Form to obtain research rate (DHHS
negotiated rate)
• Professional Fees
– Obtain from Clinical Department Contact or Research Rates Database
– Standard discount ($75/RVU) reflected in database
– Invoice from UMG reflects discount
Budget Preparation
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Determine rates (cont.)
 University service
• Service center rate
• Contact manager of service center
 Outside vendor
• Commercial vendor services: Agreement through Logistics
• Outside organization involved in study: Subcontract through RGC
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Apply Correct Indirect Cost Rate (IDC)
 Industry: 25% Total Cost
• 20% institutional F&A
• 5% Department Assessment
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Some departments don’t assess, stays in account
Some departments assess more, must add line item in budget
Some divisions assess in addition to department assessment, must add line item in budget
 Non-industry: 33.5% Modified Total Direct Cost, excludes
• Patient care costs
• Equipment
• Tuition, etc.
Unallowable Costs
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Industry
Finders fees
Referral fees
Enrollment incentives
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Federal
All industry unallowable above
Also unallowable costs per A-21
• Administrative
• Preparatory to research , etc.
Industry Sponsored Clinical Trial
Payment Schedules
Specified in contract text or budget
 Assure appropriate payment milestone and
schedule used (based on work performed)
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Visits performed
Visit CRFs collected
Patients enrolled
Patients completed
Study milestones
Industry Sponsored Clinical Trial
Payment Schedules
Should not accept long intervals without payment (not >
quarterly)
 Should not accept withhold of large % at end of study
(not >20% of study budget)
 If milestone tied to monitoring:
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Need to specify monitoring frequency
Need to include ability to get paid if monitoring outside of
specified frequency
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Include penalties for late payment (10% for > 60 days)
Industry Sponsored Clinical Trial
Payment Schedules
 Negotiate upfront payments
 Nonrefundable for study preparation
• IRB preparation
• IRB review fee ($2,200, required)
• Contract preparation
• Budget preparation
• Advertising (if applicable)
• Pharmacy set-up (required if involves a drug)
 Refundable: negotiated amount up-front to avoid deficit spending (usually
number of patient visits)
Industry Sponsored Clinical Trial
Payment Schedules
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Other payments to include
Screen failure payment if expensive screening
procedures
Event based costs invoiced to sponsor
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IRB Project Revisions and Amendments ($825, required)
Continuing IRB Review ($1,320, required)
Pharmacy maintenance fees (if not in per patient budget)
Government audits
Record storage
SAE report preparation (if many and not included in per subject budget)
Subject compensation and/or expenses (if applicable)
Advertising costs (if applicable)
Translation expense (if applicable)
What to do with the Budget
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Grant
Enter information into applicable format (ex:
PHS398, SF424, etc.)
Append to grant or contract per instructions
What to do with the Budget
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Industry Sponsor (cont):
Calculate detailed budget to determine actual costs
Determine budget with sponsor
• Line item budget options
– Complete worksheet provided by sponsor
– Create budget and give to sponsor
– Sponsor proposes line item budget
» If covers cost per actual budget, agree
» If doesn’t cover cost per actual budget, negotiate
» Make changes to sponsor budget once agreed upon
• Fixed price budget (per patient or per visit)
– If covers cost per detail budget, agree
– If doesn’t cover cost per detailed budget, negotiate
What to do with the Budget
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Industry Sponsor (cont.)
Sponsor budget attached to contract
• Line item budgets usually an appendix, fixed price
budgets often in the text of the contract
• If not in the contract, not obligated to pay
• Changes must be renegotiated and appended to contract
– Increased costs
– Number of subjects
– Extended term
• Send final budget to contract analyst
Prestudy Support
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Clinical Trials Office (CTO) Prestudy Unit: If industry sponsored, the
CTO can do your budget (and IRB submission, and account requests)
for you!
 Paid by sponsor
 http://www.ohsu.edu/research/crp/cto/index.shtml
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Investigator Support & Integration Services (ISIS): Can assist with nonIndustry clinical research budgeting and regulatory submissions
 First clinical research grant: FREE
 Funded investigator: Fee depending on service
 http://www.octri.org/octri/public/index.aspx?pageid=76&siteid=1&menuid=
18&siteid=1&siteid=1&MenuSelectedIndex=1
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Contact Bridget Adams, Manager, 4-5077
Tracking Your Award
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Track preaward process through set-up via “The
Jellyfish”:
http://rishtmldb.ohsu.edu:7042/pls/risprod/f?p=13
2:1:14251149068476920202
Which office is handling your study
Which analyst is responsible
Status
OGA Account Set-Up
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Award Packet transferred to Sponsored Projects
Administration (SPA) from preaward office
Industry Sponsored:
• Contract executed
– After all compliance approvals
– After receipt of final budget from study team or sponsor
• Contract copy sent to PI and Study Coordinator
All other:
• Award notice received from funding agency
• All DAC items completed
OGA Account Set-Up
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Set-up Process Overview
 Award and Project(s) set up in OGA
 Notice of Acceptance (NOA) sent to Principal Investigator (PI) and
“Award/Project Dept Fiscal Manager” with OGA Project Number
and Alias
 Timeline
• 5 business day target – from receipt of account setup packet in SPA to
NOA email to PI
• In future, industry sponsored clinical trials: 24 hours to receipt of
abbreviated NOA with OGA alias
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Information on OGA account set-up:
 Account Set-Up Process Flowchart:
http://www.ohsu.edu/research/rda/spa/docs/applic1.pdf
 More details available in SPA 101 course
Industrial Account
Setup
Required if charging hospital services to a research
account
 Complete Research Rate Request and submit to
Patient Business Services (PBS)
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 Can be completed as soon as study procedures determined
 Includes:
• Research Rate Request Form (p. 1 always required, p.2 required only if study services
billed to the subject)
• Protocol/research plan
• IRB Lay Language Summary
• Copy of Clinical Study Billing Schedule from IRB IRQ
 Signature from all OHSU departments providing clinical services for study
Industrial Account
Setup
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Complete Industrial Account Request Form and
submit to PBS
After receive OGA Project Number
Research Rate Request must have been submitted
An industrial account for a different study may NOT
be used while waiting for a new account number
Medicare Approval for
Devices
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Applies to:
Category A devices for “life-threatening conditions”
Category B devices
Humanitarian Use Devices (HUD/HDE)
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Must obtain approval from Medicare prior to using
device in Medicare patients
HDEs also require patient specific approval (will be
contacted by Melanie Hawkins, Clinical Research
Billing Manager when Medicare approval for the
HDE obtained)
Medicare Approval for
Devices
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After:
IRB approval
Contract negotiation complete or grant awarded, if applicable
Complete OHSU Investigational and Humanitarian
Device Medicare Pre-Approval Form
 Obtain signatures of PI on letter and certification
 Send to Melanie Hawkins, Clinical Research Billing
Manager
 Wait for Medicare approval
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Tips to Assure Correct Billing
Complete Research Rate Request form early and involve all Hospital
Departments providing services
 Use paper order form (downtime slip) to order services directed to the
industrial account
 If OHSU clinical services performed for research purposes:
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 Obtain an medical record number (MRN) for all subjects, even if not an OHSU
patient
 Create research FYI after subject signs informed consent form
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If study involves standard of care clinical procedures
 Participation in clinical trial must be preauthorized with private insurers
 If subject enrolled in Medicare Advantage Plan services must be billed to
traditional Medicare
• Potential significant financial impact to subject, must be informed
• Need to inform registration (email reghelp and Melanie Hawkins)
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Register/admit subjects appropriately
 Inpatient: Use Request for Research Subject Admission Form
 Outpatient: If scheduling subjects in Cadence for research related visit:
• Make sure research visit type utilized if visit for research purposes only (no
standard of care), provide scheduler with industrial account number
• If includes standard of care, should be regular clinical visit