The satellite site is a study site that is linked to an existing parent site where the parent site and the satellite site share the same principal investigator. Subjects are seen by the same principal investigator and visit both the parent site and the satellite site according to their own business requirements
Managing Satellite Sites and Contacts for Clinical Trials
You manage satellite sites and contacts for clinical trials in the same way that you manage normal sites and contacts for clinical trials. For more information, see the following topics:
- Satellite sites function in a similar way to normal sites. From a business perspective, it is important to track all the satellite sites for a parent site and ensure that the protocol guidelines are being followed at the satellite as defined for the parent site. Other important issues to note before starting to create and manage satellite sites for clinical trials include the following:
- A site can have multiple satellite sites, but each satellite site can have only one parent site.
- If a subject visit happens at a site, then all corresponding activities also happen at the same site.
- All roll up and roll down of information in the standard hierarchy for the parent site (Protocol – Region – Site) applies for the satellite site. This includes the roll up and roll down of the following information: position, payment, subject status, and contract amount.6-5
- Bulk actions carried out at the protocol and region level for the parent site (such as activity, account, document tracking, and payment generation) apply for the satellite site.
- The following data is consolidated from the parent site to the satellite site: subject enrolment, accrual payment, contract amount, and payment amount.
- The satellite site and parent site can be of different types. For example, even if the parent site is a Hospital and the satellite site is a Private Clinic, the same principal investigator conducts the study for both sites.
- The satellite site inherits the parent site’s subject visit template version, principal investigator, team, and currency information by default. Any change in the subject visit template version, principal investigator, team, or currency information is rolled down from the parent site to the satellite.
- The subject enrollment of data from the satellite site is rolled up to the parent site.
- The payments and contract data from the satellite site is rolled up to the parent site.
- Monitoring of endpoints performed outside the investigator site (e.g., central reading facilities, central laboratories) should be addressed in the monitoring plan.” Recommend that ICH E6 R3 also provide expectations with regards to potential involvement of satellite sites and adequate supervision by sponsor and investigator at multiple sites? (e.g. IP availability / transfer between parent and satellite sites, maintenance of source records, monitoring, etc)
- The following use cases are supported for satellite sites:
- A subject is allocated to a satellite site and carries out all visits at the satellite site as part of the study.
- A subject is allocated to a parent site and carries out some visits at the satellite site as part of the study.
In the October 2009 Guidance [1], the FDA
defines their understanding of ‘adequate supervision of the conduct of an ongoing clinical
trials’.
- ‘For each study site, there should be a distinct individual identified as an investigator who has supervisory responsibility for the site.
- A sub-Investigator at a site, that individual should report directly to the investigator for the site
- The investigator should have clear responsibility for evaluating the sub-Investigator’s performance and the authority to terminate the subinvestigator’s involvement with the study
- Sub-investigator should not be delegated the primary supervisory responsibility for the site
- The investigator should have sufficient time to properly conduct and supervise the clinical trial.
Factors that may affect the ability of an investigator to provide adequate supervision of the conduct
of an ongoing clinical trial at the investigator’s site:
– Conducting a study from a remote (e.g. offsite) location
– Conducting a study at multiple sites under the oversight of a single investigator
The investigator should develop a plan for the supervision and oversight of the clinical trial at the site. Supervision and oversight should be provided even for individuals who are highly qualified and experienced.’’
Satellite centers, which are geographically distant and/or where the PI has delegated supervisory responsibilities to a sub-investigator, will no longer be acceptable under the FDA guidance.
Common Question:-
Is it possible to have a Remote Location?
One of the interesting questions asks whether a “satellite site” would be possible under GCP.
The agency answered the following:
- The term “satellite site” is not defined in FDA’s regulations or guidance.
- In general, an investigator should have a detailed plan for the supervision and oversight of a clinical trial. Conducting a study from a remote (“satellite”) location, is one factor that may compromise the ability of an investigator to provide adequate supervision of the conduct of a clinical trial.
- There should be a subinvestigator responsible for the conduct of the clinical trial at each trial site. Subinvestigators should report directly to the investigator.
- If the “satellite” location is in reasonably close proximity to the one where the clinical investigator normally does business, it could be feasible for him / her to conduct the study at both sites, or at least to adequately oversee the conduct of a subinvestigator at the “satellite site”.
- When the proposed “satellite site” is located far away, or in another city, state, province, this would make it difficult for the clinical investigator to successfully conduct and / or oversee the study at that site. The agency therefore recommends that the proposed “satellite site” choose a different individual to conduct / oversee the study (= completely separate study site rather than a “satellite site”).
- The individual overseeing the study at that new site would need to sign a separate agreement with the study sponsor.
What is a satellite? Or, is it OK for us to send drug to other offices/sites?
Answer: As per “Pharmaceutical Management Branch, CTEP, NCI “
A “Satellite Location” is a local site away from the control area or primary storage area (that is, the place to which PMB shipped the agent). Any transportation of PMB-supplied agents between the con- trol location and satellite location must remain in the institution’s immediate control. If delivery of an agent requires use of a secondary carrier (e.g. US postal service, Fed-EX, UPS), the other location is not a satellite.
When investigational agents are received at the control location, they may be transported to satellite locations (originally conceived as within walking distance, sharing staff, and covered by the same IRB). Any transportation must be in the receiving institution’s direct control, and a third party shipper may not be used. Local satellite institutions or affiliates must be serviced by institution-employed couriers or central pharmacy staff. CTEP-supplied agents must not be repackaged or forwarded by mail or express courier. The NCI has established policy to maintain validated shipping conditions (and therefore product integrity) for agents used for clinical research to ensure that PMB can track all product immediately should there be a recall to be able to convey other important pharmaceutical information quickly when necessary, and to assist in agent accountability.
Any transportation of investigational agents outside the direct control of the institution receiving the agent is considered secondary distribution. Secondary distribution violates NCI policy and proce- dures.
•How far away is the satellite in both distance and travel time? How many patients will need this accommodation?
•Can we work together to develop a mechanism that works for you that will allow us to directly ship agent to your satellite?
•Does the staff member who will transport the agent know that it is considered a dangerous substance by the Department of Transportation if that is the case?
• How will you address the following?
Agent stability issues both during transportation and for any storage at the local site. safety issues (dangerous substance, how to handle a spill) preparation of the patient’s dose under appropriate conditions by appropriately trained staff the need to have someone that can appropriately administer the medication at the site a method for proper disposal of the waste, empty IV bags, etc. a plan for returning unused medication to the central location a back up plan for those instances where a replacement dose may be needed (product damaged, treatment had to be emergently interrupted, etc.) particularly if treatment has been started confirmation that the medication was given (while not a PMB requirement, it is an investigational study requirement)
- a plan for handling missed dose
- a plan for multiple day therapies (are doses driven up each day)
- agent accountability via a DARF
References:-