Close-Out Visits

closeout and archive files

I’ve done about 10 close-out visits in the last few months so it feels like a good time to write a short article explaining what the objectives of these visits are and how a typical close-out visit (COV) is conducted.

Clinical Trial Site Close-Out Visit

A close-out visit will occur once subjects are no longer being dosed, all the data have been collected (there are no more outstanding AEs/SAEs & all outstanding Queries/data clarification forms have been resolved appropriately), the database is locked and ready for statistical analysis, and the study conduct has ended. At this point, the site’s contributions are over so the monitor returns for one final visit to shut down the site. The whole concept behind a close-out visit is to ensure that everything is neat and tidy at the study site and that the documentation is well organized and will remain intact and be accessible in the future as needed for regulatory reasons. A sponsor or the FDA should be able to return to the place of study conduct years later and re-create exactly what occurred at all points during the trial by reviewing the regulatory documentation, subject and source documentation, full medical charts, and any other applicable study records. Documentation is everything in our industry and we are always saying, “if it isn’t documented it didn’t happen.” If thorough and accurate records are not maintained, the PI cannot prove that the study was conducted in accordance with the protocol and all applicable regulations and that subject safety was adequately monitored throughout the conduct of the trial.

Site Supplies and Drug Return

tamper proof box
We are using tamper evident tape to
box up investigational product for return.
If the tape is lifted it leaves behind an
artifact to show it has been tampered with.

One of your major objectives at the close-out visit will be to assist the site in dealing with any unneeded study materials or supplies. With permission from the sponsor, some of these activities can even take place before the close-out visit as you remotely supervise. The close-out duties will likely include disposing of or retrieving all unused lab or study supplies such as patient handouts, electronic diaries, etc. In most cases, you will have the site generate a file note or similar documentation so there is a record indicating that study supplies were disposed of or moved off-site. 9 times out of 10, the Investigational Product (unused and the used packaging) will need to be inventoried, accounted for in drug logs, and then shipped to a depot or destruction facility. Sometimes the drug will be destroyed on site by a pharmacist or according to the site’s SOP but this is really the decision of the sponsor. If you are lucky, you were able to pack up and ship back drug routinely throughout conduct otherwise you will have to deal with it all at the end.

Essential Documents

You will have the PI sign off on any tracking logs that were used during the study. The original will be placed in the site’s Regulatory binder but you will retrieve a copy for the Trial Master File. You will ensure that a Subject Identity List was completed and will be kept that lists the contact information for all treated subjects (you will not take a copy of this document as it has private information and stays at the site only). Documents you will take copies of include: Site Visit Log, Subject Screening AND Enrollment Log, Delegation of Authority Log, Proof of Drug Receipt, Subject Specific Investigational Product (IP) Accountability Logs, Copies of temperature/freezer logs, Site Initiation Statement, Training Documentation, Overall Site IP Log, Protocol/Amendment Signature Pages, Any updated 1572s, medical licenses, or CVs, Site communications to the IRB/IEC (ethic committee), and the IRB Final Status Document. Obviously in a study with many safety reports, a long line of routine monitoring visits, multiple site hand-offs/transitions between several different monitors, or a slew of important correspondence, checking that the essential documents binder(s) is in perfect order can be a time-consuming task.

Subject Records

Although you will have already verified this throughout conduct, the close-out visit is your last opportunity to be absolutely sure that the appropriate version of signed and dated Informed Consent Forms are on file for every subject. You will also check that all source is complete (all lab reports and ECGs have been signed and dated with Clinical Significance assessed by the PI/Sub-I) and that all AEs/SAEs have been signed off by the PI/Sub-I and that they were followed to resolution as specified by the protocol. Finally, check that all significant Protocol Deviations (study procedures not conducted according to protocol, enrollment of inappropriate subjects, dosing errors, consenting errors, unblinding, subjects developing withdrawal criteria yet continuing in study, etc.) have been properly recorded and the sponsor/IRB has been notified as appropriate.

PI Responsibilities

Discuss with the PI his/her responsibilities including: query/data collection following the close-out visit, essential document retention, publication rights, and the necessity to update the Financial Disclosure statement if there are changes in their financial interest for up to one year following completion of the study. Finally, explain to the PI the potential for regulatory agency inspection and the requirement that the site notify the CRO/sponsor immediately if contacted for an audit/inspection.

Assuming you have done a thorough job in monitoring throughout conduct, the close-out visit should be a relatively short-visit. Meeting with the PI to discuss their regulatory responsibilities post trial conduct and obtaining required signatures usually takes less than 20 minutes assuming they are an experienced investigator and are already familiar with the GCP schpeel. Drug return often takes several hours but you can prepare most drug return documents in advance of the visit by using sponsor or IVRS reports and usually save a considerable amount of time on-site. You should have been reviewing the regulatory binder at every visit throughout conduct so it should really be in order at this point and stuffed to the brim – I usually budget no more than an hour to ensuring that the binder is complete.

After you complete the close-out visit, you will write a report to the sponsor to let them know that all of the objectives were completed and a follow-up letter to the site thanking them for their participation and informing them that there are no further pending action items. Any new regulatory documentation you copied while on site will need to be forwarded to the Trial Master File so that the sponsor’s documentation is a true mirror of what is on site.

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About The Author

The Lead CRA

Nadia started The Lead CRA blog in 2007. She is now lead author for ClinOps Toolkit. Nadia is currently working as a Clinical Program Manager at a small specialty pharmaceutical company in the San Francisco Bay Area. You can reach Nadia via email at leadcra@clinopstoolkit.com anytime.

15 Comments

  • Shah A

    July 8, 2015

    Excellent Blog .. Very informative. Can you add a close out check list. That will be very helpful.

    Regards
    Shah

  • Tahreem

    July 2, 2015

    Hi,

    I hope you can help me, if a site had SIV and IMP is present on but no Subject recruitment can these sites be closed before study completion? What should be in ISF full ISF or mini ISF is required at that site?
    Thanks

  • Sandy

    June 30, 2015

    Roughly, how many COVs does the average CRAII do a year?

  • Heidi

    April 5, 2015

    A close-out maybe performed remotely if the site never received Investigational product or never screened or enrolled a subject. Sometimes close out visit are combined with the last IMV monitoring visit there maybe still open queries if that is this case. Those would have to be closed or verified. This may happen if a site enrolled minimal subjects and their data is clean or if they wish to withdraw from the trial.
    However by the time you do a close there should not be deviations to report as most likely your database will be locked by this time. Of course something could occur but should be rare. Close Out visits should be carefully planned so there are no major issues to deal with . You may have to return IP at this visit so be sure and take necessary supplies. If there is other equipment onsite make sure the site has all the details to return that equipment. You should have a central file review done to make sure you know if there any missing documents. I try to do this earlier so you do not spend time chasing at the last minute. The site needs to inform the IRB that the study closing and you will need to .However make certain that site does not so until all outstanding issues are resolved as it is difficult once this occurs to get cooperation.

  • Anonymous

    February 19, 2015

    Hi,

    I have a question about remote close out visits. I’m still a little confused about the close out visit. What if you find a discrepancy with the source document that wasn’t captured at the last visit? Or a deviation wasn’t reported, etc.

    Also, can close out visits be performed remotely? Email? Telephone?

    Thank you

  • abdul majid

    October 22, 2014

    Give me the list of original (not copy)documents you will collect in site close out visit.

  • Anonymous

    February 21, 2014

    Hi Nadia,

    I am writing from a site. Is it acceptable to make clarifications/late entries to the source documents once the site has already been officially closed by the monitor if a final QA is performed before archive and things need further clarification? Please advise.

    • Nadia

      Nadia

      February 23, 2014

      I would advise no, especially if the monitored source was used to produce CRF entries. In this instance, the clinical record might not match the database; possibly it could impact the analysis that was done. At the very least, it may make the monitoring report inconsistent as it would not also reflect these changes. The sponsor closed the study and the records are to be maintained but not modified. The sponsor would certainly need to be notified of these late entries.

  • fazel

    January 29, 2014

    This blog is wonderful

    • Nadia

      Nadia

      February 7, 2014

      Fazel, thank you for stopping by and leaving this kind comment for me last week. I am thrilled that you think the blog is wonderful. Don’t hesitate to personally contact me if there are specific topics you would like me to cover in 2014.

  • Claire

    December 26, 2013

    Nadia, many thanks for all your posts: this blog is really helpful for me, day after day.
    I have a question that I tried to resolve but nothing found so I submit it here. You specified about the tracking logs ‘The original will be placed in the site’s Regulatory binder but you will retrieve a copy for the TMF’. My QA Director ask me to do the opposite: the sponsor keeps the originals. Is there somewhere a explanation/argument to let original logs on sites and retrieve copies? Even if it is obvious for me, I’ve to convince the QA department(…).

  • Anonymous

    January 15, 2012

    Excellent post, thank you for the information

  • jay

    May 30, 2011

    please provide me detail about telephonic close out visit??

    where it applies ??

    rules and regulation ?

  • The Lead CRA

    The Lead CRA

    August 1, 2008

    Thanks for your comment, it is a real risk to wait until the end of the study to try to get the binder in shape and I appreciate you pointing that out.

    One other tip I would like to add, is that important correspondence should be in the TMF. When I go to a COV, I bring a stack of important regulatory documents with me and I slip them in as needed. For example, if you have a copy of every IND letter, that is much easier to hole punch and file than to ask the SC to give you internet access so you can forward the electronic file, then hope their printer is working and they have a few free minutes…you get the idea. Save yourself a headache and just bring copies of things like that, study newsletters, notification of screening/enrollment closure, notification of DB lock, email trails with the Medical Monitor about waivers or deviations, etc. Also be sure that the site has filed the confirmation and follow-up letters for all of the monitoring visits.

  • Anonymous

    August 1, 2008

    Very nice job detailing what happens at the Close Out Visit. It also serves as a reminder to not let things slide and to keep on top of things by sending in things ahead of time if possible. Also checking the Regulatory Binder at each visit helps ensure that the records are maintained as expected and avoids surprises.

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