James P. Bagian, M.D., P.E
Director, National Center for
Patient Safety
and
Jonathan B. Perlin, M.D., Ph.D.,
M.S.H.A.
Chief Quality and Performance
Officer
Veterans Health Administration
Department of Veterans Affairs
Before the
House Veterans' Affairs
Subcommittee on
Oversight & Investigation
July 27, 2000
Mr. Chairman and Members of the Committee,
We are pleased to appear before you to discuss VA’s
ongoing activities and initiatives to ensure the provision of
consistent, high quality and safe care to patients. The committee
rightly recognizes the link between quality and safety and the fact
that quality and safety are fundamental to the work of the VA health
care system at all levels. It is important to note that achieving the
best possible outcomes for our patients while minimizing safety risks
are overarching goals for all elements of the VA system. The Office of
Quality and Performance and the National Center for Patient Safety and
all other VHA offices have leadership roles and share responsibility
for achieving these goals.
For clarity, the fundamental principles, philosophy
and basic elements of VA's quality and safety activities are presented
separately. However, it is only when all elements work together that
the full benefit of each is realized and a number of programs that
exemplify this are also discussed.
PATIENT SAFETY
Starting in 1997, VA intensified its already
extensive efforts in quality improvement by launching major overt
initiatives on patient safety per se (see Attachment 1). By no means
were these initiatives the first safety related efforts by VA. For
example, prior to 1997 the development and implementation of clinical
guidelines ensured uniform, safe provider performance across all
facilities. VA recognized that programs to improve quality and safety
in health care often share purposes and corrective actions. However,
it believed that patient safety required a new and different approach
and set out to create a new culture of safety in which VA employees
detect and report unsafe situations and systems as part of their daily
work. Studies have shown that this change of culture is a multi-year
task. VA is committed to designing and implementing new systems and
processes that diminish the chance of error and the elimination of
unsafe situations. VA is using a systems approach that emphasizes prevention
-- not punishment -- as the preferred method to accomplish this
goal.
In December 1999, the Institute of Medicine (IOM)
released a report "To Err is Human: Building a Safer Health
System." The report’s review of existing studies, which
concluded that as many as 98,000 preventable deaths occur each year in
United States’ health care due to error, focused national attention
on patient safety. The IOM recommended creating a new National Center
for Patient Safety (not to be confused with the VA's own National
Center for Patient Safety, which already existed) that would focus on
research and policy related to errors in health care, improved error
reporting systems, improved analysis/feedback methods, performance
standards for health care organizations and individuals, and other
specific governmental actions. Importantly, the IOM report cautioned
that the focus must be on creating a culture of safety that will
require improving systems, not assigning blame.
VA interpreted the IOM report as a validation of its
commitment to improving patient safety in its health care system. All
of the IOM recommendations applicable to VA have either been in place
or were in the process of being implemented prior to the release of
the report. While VA has had quality and safety related activities
ongoing for many years, it was in 1997 that its formal patient safety
program was launched. Leaders in the field of patient safety and
medical error outside VA have participated in the design of the system
and recognize VA as a pioneer in these efforts.
VA recognized that patient safety is not a
VA-specific issue, therefore it asked other health care organizations
to join in an effort to understand the issues and to act for patient
safety. As a result, the National Patient Safety Partnership (NPSP),
a public-private consortium of organizations with a shared interest
and commitment to patient safety improvement was formed in 1997. The
charter members, in addition to VA, included the American Medical
Association (AMA), the American Hospital Association, the American
Nurses Association, the Joint Commission on Accreditation of
Healthcare Organizations (JCAHO), the Association of American Medical
Colleges, the Institute for Healthcare Improvement (IHI), and the
National Patient Safety Foundation at the AMA. Five additional
organizations have subsequently joined the charter members in the
Partnership: the Department of Defense (D0D) -Health Affairs, National
Institute for Occupational Safety and Health, the Food and Drug
Administration (FDA), Agency for Healthcare Quality and Research, and
the Health Care Financing Administration. This group addresses high
impact issues that are of importance to a broad cross section of the
health care industry. An example of the Partnership’s action and
influence was the establishment of an FDA clearinghouse for
information related to the effect of Y2K computer issues on medical
devices. The NPSP also called public and industry attention to
Preventable Adverse Drug Events and promulgated simple actions that
patients, providers, purchasers and organizations could take to
minimize their chance of an adverse drug event. VA is leading
development of an NPSP anthology on issues in patient safety that will
serve as a resource for industry, educators, and policy discussion.
Also, VA is leading the way in the use of bar-code technology to
prevent errors. The NPSP serves as a model of what a private-public
collaboration can do to improve patient safety.
VA instituted a Patient Safety Improvement Awards
Program in 1998 to focus interest on and reward innovations in
identifying and fixing system weaknesses. Not only does this produce
ideas for patient safety improvements that might otherwise go
unnoticed, but it further reinforces the importance that VA places on
patient safety activities and involves those at the ‘front-line’
in a very direct and tangible way.
In 1998, VA created the National Center for
Patient Safety (NCPS) to lead and integrate the patient safety
efforts for VA. This Center was created to lead VA’s patient safety
efforts and has a direct reporting relationship to the Under Secretary
for Health. The NCPS employs human factors engineering and safety
system approaches in its activities. The first task for the Center is
to devise systems to capture, analyze and fix weaknesses in our
systems that affect patient safety.
In 1998 VA formed the Expert Advisory Panel for
Patient Safety System Design to obtain expert advice to enhance
the design of VA’s reporting systems. These experts in the safety
field included Dr. Charles Billings, one of the founders of the
Aviation Safety Reporting System (ASRS), as well as other experts from
NASA and the academic community. They advised us that an ideal
reporting system: a) must be non-punitive, voluntary, confidential and
de-identified; b) must make extensive use of narratives; c) have
interdisciplinary review teams; and d) most importantly, focus on
identifying vulnerabilities rather than be a counting exercise. VA has
used these principles to design the patient safety reporting systems
we have in use or in development. Based on the expert advice and on
lessons learned from our mandatory adverse event reporting pilot, the
NCPS has developed and rolled out a comprehensive adverse event, close
call analysis and corrective action program and computer assisted tool
that includes an end-to-end handling of event reports. This system not
only allows for the determination of the root causes, but also
captures the corrective actions as well as the concurrence and support
of local management for implementation. The system includes a number
of innovations such as human factors decision support tools and
computer aided report tools to determine the root cause of adverse
events and close calls.
In 1999, VA established four Patient Safety
Centers of Inquiry. These Centers conduct research on critical
patient safety challenges. Activities at the Centers of Inquiry range
from fall prevention and operating room simulators to understanding
the role of poor communication in patient safety. The Center in Palo
Alto, California, which is affiliated with Stanford University, is a
recognized leader in the area of simulation and has been featured
prominently in the media. Their simulated operating room allows
surgeons and anesthesiologists to train and do research without
endangering a patient. VA expects to create additional simulation
facilities to train its physicians and other health care
professionals. One simulator with appropriate staff could train
approximately 600 anesthesiologists and residents per year. This means
that virtually all VA anesthesiologists/anesthetists can be trained in
a year on clinical situations that could not be simulated safely in
actual patients. Another Center at White River Junction, Vermont, is
partnering with the Institute for Healthcare Improvement (IHI) to
build learning collaboratives aimed at reducing medication errors, a
major issue identified in the IOM report. IHI collaboratives will
affect several hundred VHA personnel each year. Other IHI
collaboratives have resulted in measurable improvements and similar
results are anticipated with medication errors.
In November 1999, the new event and close call
reporting system was first pilot tested in VA’s VISN 8 (Florida,
South Georgia and Puerto Rico). Extensive training and constant
mentoring and feedback are provided to assure full understanding of
the search for the root cause and redesign of the system. The quality
managers, risk managers, and clinicians using the system believe that
the new methods analysis of error will make a significant improvement
in the care of veterans. Independently, VHA’s Patient Safety
Improvement Oversight Committee has stated that the reports and
corrective actions that are the product of this new approach are
superior in numerous ways to the ones from the previous system. By
August of this year, all VA hospitals will have received this training
and be using this system. To date, there have been nearly 600
participants at these national training sessions. While the vast
majority of these participants have been VA employees, we have been
pleased to accommodate requests for training about our system from
participants in both the public and private sector. Participants have
included guests from AHA, Baylor University, DoD, FDA, the Government
Accounting Office, Kaiser Permanente, the University of Michigan, the
University of Texas, and other private and public health care systems
or affiliates. Response from participants has been overwhelmingly
positive.
We sought to design reporting systems that would
identify adverse events that might be preventable now or in the
future. In addition, we sought systems to identify and analyze
situations or events that would have resulted in an adverse event if
not for either luck or the quick action of a health care provider --
we call such events "close calls." We believe that
"close calls" provide the best opportunity to learn and
institute preventive strategies, as they will unmask system weaknesses
before a patient is injured thus enabling preventive actions to be
taken. This emphasis on "close calls" has been employed by
organizations outside of health care with great success. It has been
said that experience is the best teacher, however it is also the most
expensive. In the case of medically related experience that cost can
be expressed in terms of tragic consequences. "Close calls"
enable us to learn and institute preventive actions without first
having to pay the costly tuition born of human tragedy.
To complement our internal system, an agreement to
establish the Patient Safety Reporting System (PSRS), a complementary,
de-identified voluntary reporting system, was finalized in May of this
year with NASA. The PSRS is patterned after the highly successful
Aviation Safety Reporting System that NASA operates on behalf of the
FAA. It is external to VA and allows all physicians, nurses,
pharmacists, laboratory personnel, and others to report unsafe
occurrences without fear of administrative or other action being taken
against them.
Another key VA strategy to reduce medical errors
involves the development of a new curriculum on safety. VA is moving
forward with plans to provide education and training relevant to
patient safety not only to those already in practice but also at the
medical, nursing, and health professional school levels. This will be
the first time an extensive safety curriculum will be developed and
broadly implemented. VA is particularly well situated to lead the
educational effort due to the extensive role it plays in the education
of health care professionals in the United States. (VA is affiliated
with 105 medical schools and up to one-half of all physicians in the
country train in a VA facility during medical school or residency.)
Additionally, we have instituted a performance goal to provide VA
employees 20 hours of training on patient safety this year.
Based on lessons learned from the review of adverse
events, actions are taken at both the local level and nationally.
Examples of national level actions are as follows:
- Restricting access to concentrated potassium
chloride on patient care units
- Requiring use of barcode technology for patient
identification and blood transfusions in operating rooms
- Establishing new procedures for missing patient
searches
- Enhancing violent behavior prevention efforts
- Establishing new procedures for verifying water
temperature for patient baths/treatments
- Enhanced procedures to ensure safe injection of
Radio-Labeled Blood Products
- Enhanced requirements for protective fencing
around construction sites
We believe that patient safety can only be achieved
by working towards a "culture of safety." Patient safety
improvement requires a new mindset that recognizes that real solutions
require an understanding of the "hidden" opportunities
behind the more obvious errors. Unfortunately, systems’ thinking is
not historically rooted in medicine. On the contrary, the field of
medicine has typically ascribed errors to individuals and embraced the
name-blame-shame-and-train approach to error reduction. Such an
approach by its very nature forecloses the opportunity to find systems
solutions to problems. Other industries such as aviation have
recognized the failings of this approach and over many years have
succeeded in transitioning from a similar blame and fault finding
approach to a system-based approach that seeks the root causes of
errors to guide them in preventive actions. VA realized how pivotal
culture is to improving safety and in 1998 conducted a culture survey
of a sample of employees. Of interest, the shame of making an error
appeared a more powerful inhibitor of reporting than was fear of
punishment. The survey provided information that indicated that
employees were intolerant of their own errors and were
"ashamed" if others knew that an error had been made. People
who have expressed strong feelings of shame are less likely to
exchange learning experiences with others, thus thwarting the
opportunity for the entire institution to learn from the experience.
We plan to survey culture broadly in VA for several years to track the
progress of our efforts.
QUALITY MANAGEMENT
Aviation safety has been used metaphorically to
describe both opportunities and processes to improve patient safety.
It is also an appropriate metaphor for describing the relationship
between safety and quality. While much is learned from understanding
adverse events and close calls, quality has to be "engineered
in." Safe health systems, like safe aviation, must be designed
and implemented to tolerate human imperfection and still achieve
reliably good outcomes. Neither quality nor safety can be adequately
described independently. While each may receive identifiable and
specific support, the overall fabric is far more complex than the
individual threads.
VA processes systematically seek to "engineer
in" quality. Clinical practice guidelines, electronic medical
records, computerized clinical reminders, bar code blood and
medication administration all exemplify systems which are not only
designed to reduce the risk for bad outcomes based on human factors,
but designed to support achievement of the optimal outcomes possible
for patients. All of these initiatives, except practice guidelines,
originated outside of the quality and safety offices. VA Research also
makes significant contributions to improving quality and safety of
patient care (See Attachment 2). All of these efforts and many others
represent organizational commitment to quality and safety.
The history of VA’s commitment to
"engineering in" quality is important. The 1995 publication Vision
for Change (page 7), described a radical, yet rational,
transformation of structure that would support a transformation of
culture. The ensuing structural transformation made it possible to
embark on a "quality and safety transformation" that is now
being realized.
VA articulated its commitment to quality in the
broadest sense, and expressly inclusive of safety, in 1996 with the
publication of Prescription for Change. VA’s commitment to
quality is galvanized by the Performance Measurement Program operated
through the Office of Quality and Performance. The Performance
Measurement Program begins with the principle that quality outcomes
can, and should, be specified. Through performance contracts,
clinicians and managers are accountable for achieving realistic, but
ambitious performance targets in defined time frames. A highly evolved
measurement program provides ongoing assessment of performance and the
data necessary for effective management. Improvement since inception
of performance measurement in 1995 is impressive. In many areas where
comparative quality data are available, VA meets or exceeds published
levels of performance in health care.
VA expressed its commitment to preventive health
through development of the Prevention Index. This index supports
improvement in evidence-based health services such as immunization,
cancer detection, and substance abuse screening. On a 100 point scale,
the Prevention Index improved from 33 (1996) to 67 (1997) to 79 (1998)
to 81 (1999), a 145% improvement since inception. A parallel 100 point
Chronic Disease Index including indicators of care in heart disease,
lung disease, diabetes, and hypertension has increased from 45 (1996)
to 77 (1997) to 85 (1998) to 89 (1999), a 98% improvement since
inception. VA’s rates of immunization against pneumonia and
influenza now exceed U.S. Public Health Service goals and published
private sector performance.
What does this mean in terms of real outcomes for
real patients? In the United States, only about 50% of the elderly and
patients with chronic disease appropriately receive the recommended
pneumonia vaccination. In contrast, in VA, by 1998, the improvement in
pneumonia vaccination, from levels consistent with prevailing
community rates in 1996, is estimated to have saved almost 4,000 lives
in patients with chronic lung disease alone.
These achievements exemplify a critical aspect of
the relationship between quality and safety. We may only think of
adverse events as the result of an action, be it a preventable error
or an unforeseeable and unpreventable consequence. However, adverse
outcomes may also be the result of inaction.
VA has approached both under-utilization as well as
mis-utilization of appropriate therapy through the development of
Clinical Practice Guidelines. The expected outcomes of these
guidelines are again supported by performance measures. The myocardial
infarction or "heart attack" module of the heart disease
guideline endorses the appropriate use of "beta-blocker"
medication for eligible patients. While it has been well known for
almost a decade that these beta-blockers can significantly reduce the
risk of death and rehospitalization, a recent study by Krumholz et
al revealed administration of this life-saving therapy to only 51%
of 58,000 eligible non-governmental patients. The rate of provision of
beta-blockers to patients treated for heart attack in VA hospitals is
currently 96%. Improvements in beta-blocker administration from rates
already above prevailing community rates in 1995 are estimated to have
saved an additional 500 lives.
"Engineering in" quality reduces
opportunities for breeches in safety and supports achieving the best
possible outcomes. Examples of other formal mechanisms for quality
management in VA, which have contributed to objective improvement in
the intended health benefits as well as the safety of patients,
include the National Surgical Quality Improvement Program, the
Continuous Improvement in Cardiac Surgery Program, and the Quality
Enhancement Research Initiatives. VA has also established its
leadership in programs for development and implementation of Clinical
Practice Guidelines in collaboration with the DoD, and in the area of
reliable and efficient electronic physician credentialing through the
VetPro initiative of the Federal Credentialing Program.
VA feels strongly that quality can be defined from
many perspectives. Admittedly, in this context, technical quality is
at issue. However, VA defines six "domains-of-value" which
serve as focal points for systematic organizational improvement.
Foremost among these is technical quality, and the relationship with
safety is incontrovertible. The remaining five domains – access,
satisfaction, maximizing functional status, cost-effectiveness, and
building healthy communities – are also critical. While all are
important to various stakeholders, satisfaction and functional status,
in particular, represent outcomes from the Veteran patient’s
perspective. As with technical quality, each of these domains is
supported by performance measures which link the "vision"
for improvement with markers of progress on the journey.
While VA has objectively achieved noteworthy
performance successes over the past half decade, we share your concern
and empathize with those patients whose care was not representative of
the overall progress. We share your outrage when any patient comes to
harm, and we recognize that our journey is incomplete. We seek your
support in continuing to foster a quality transformation that is the
result of the systemization of quality, and that fundamentally
embraces the systemization of safety.
CONCLUSION
The National Center for Patient Safety and the
Office of Quality and Performance work closely with all elements of
VHA to support complementary activities in quality and safety. In the
area of quality management, VA’s commitment to linking
organizational goals with performance measures has resulted not only
in objective improvements in the quality of care, but even achieving
some benchmark outcomes. VA has been twice awarded a grade of
"A" in managing for results, and will use the performance
measurement program and other quality management activities noted to
continue to improve quality.
The 2000 Innovations in American Government Awards
Program recently selected the National Center for Patient Safety and
the Performance Measurement Program as two of 96 semifinalists from
among more than 1,300 applicants for this year's awards. Innovations
in American Government awards are recognized as one of the most
prestigious public service awards in the country. Final selections
will be conducted in October.
In the area of patient safety, with no successful
models in large health care systems to guide us, VA turned to other
high risk, high reliability industries to adopt and adapt principles.
We have borrowed both methods and people from safety-conscious
settings such as aviation and space travel and from underutilized
disciplines like human factors engineering. We have also developed
novel approaches and tools where none existed before. These efforts
have already produced significant improvements in VA, and we believe
will do the same in all health care settings.
We would prefer that all of health care had begun to
address the issue of patient safety long ago. For too long, the
emphasis has been on holding individuals accountable and hoping that
well-intended and well-educated professionals wouldn’t make human
mistakes, rather than designing systems that don't fail if human
errors occur. As the IOM aptly states in the title of its report:
"To err is human." We are pleased to be on the leading edge
as health care takes a systems approach to patient safety. We are
anxious to discover new ways to make VA and all health care safer and
improve quality. We appreciate your support of these efforts and
intend to keep you fully informed of our progress.
Highlights of Patient Safety Activities at VA:
1995-Present
1995 -- Vision for Change Initiated
- Then Under Secretary for Health Dr. Kenneth Kizer
releases Vision for Change statement that unveils a radical,
yet rational, transformation of structure that would support a
transformation of culture.
1997 -- National Patient Safety Partnership (NPSP)
- VA launches public-private partnership of eight
health care organizations (now 13) to address national patient
safety concerns.
- NPSP takes public position regarding preventable
adverse drug events in May 1999.
1997 -- National Patient Safety Registry
- Database designed to collect information on a
nationwide basis that includes adverse patient events, their root
causes, and information to guide systematic improvements to prevent
future occurrences.
1997 -- Patient Safety Improvement Handbook
- Provides national framework for patient safety
improvement efforts.
1997 -- Patient Safety Improvement Oversight
Committee
- Multi-disciplinary headquarters committee charged
with oversight of patient safety issues.
1998 -- Patient Safety Improvement Awards Program
- Mobilizes and recognizes innovations in patient
safety from all levels of the organization.
1998 -- VHA Expert Advisory Panel on Patient Safety
System Design
- Provided recommendations on elements for reporting
systems leading to nationwide improvements.
- Comprehensive, non-punitive analytic approach for
close calls and actual adverse events defined.
1998 -- VHA National Center for Patient Safety (NCPS)
- Created to lead and integrate the patient safety
effort for the entire VA.
- Employs state-of-the-art human factors and safety
system approaches.
- Develops and nurtures a culture of safety
throughout the VA.
1998 -- Patient Safety Redesigns included in VHA
Performance Measurement System
- Provided concrete targets and mechanisms to focus
leadership efforts.
1999 -- Pilot of Comprehensive Adverse Event and
Close Call Analysis Program
- Extensive hands-on training to truly understand a
human factors and safety systems approach to close call and adverse
event analysis.
- Computer assisted tool to aid implementation of
comprehensive event analysis.
- Captures critical elements needed to ensure a
thorough and effective job.
- Results in preventive actions that are superior
to the status quo.
1999 -- National Implementation of Bar Code
Medication Administration (BCMA)
- Multi-year development at one medical center
resulted in cutting medication errors by two-thirds.
- National implementation is now in progress
throughout entire VA medical system.
1999 -- Patient Safety Centers of Inquiry
- Research groups (4) charged to develop practical
solutions to critical patient safety challenges.
2000 -- National Training Program and Roll-Out of
Comprehensive Adverse Event and Close Call Analysis Program
- As of this date, VA has trained 18 of the 22 VA
VISNs.
2000 -- Development of National Patient Safety
Reporting System (PSRS)
- In May 2000 VA and NASA signed an agreement that
has NASA operating the external and voluntary de-identified
reporting system.
- National in scope; supplementary to mandatory
reporting efforts.
- Modeled after NASA's successful, longstanding
Aviation Safety Reporting System (ASRS).
Patient Safety and Health Care
Quality:
The Interface of Research and
Practice
In addition to its administrative and clinical
concerns with patient safety, VA embraces the important role of
research in fostering a safer and more effective health care system.
VA policy makers and managers recognize that delivering the highest
quality care depends on collection of accurate data and continuous
monitoring, analysis, and evaluation of outcomes. Improving quality
and reducing errors requires cooperation among clinicians, managers,
information technology specialists, and researchers at all levels of
the organization. Unique among Federal health agencies, VA can take
research discoveries and put them to work, nationally, to improve
patient outcomes and system efficiencies.
VA has established several quality management
research initiatives to enhance evidence-based practice in the VA
health care system:
- National Surgical Quality Improvement Program (NSQIP)
provides clinicians, managers, and policymakers continuous high
quality information about the outcomes of major surgery performed
in 123 VA hospitals nationwide. Significant gains in patient
outcomes and systems efficiency have been documented since
implementation of NSQIP in 1994. These achievements were enabled
by research (The National VA Surgical Risk Study) that developed
the methods for collection of valid and reliable patient data, for
carrying out risk adjustments, and for monitoring, analyzing, and
reporting results.
- Quality Enhancement Research Initiative (QUERI)
is an even more ambitious program focused on improving care for
diseases and conditions that are especially common among veterans
such as heart disease, strokes, and diabetes. QUERI researchers
compare the outcomes of different treatment strategies, develop
instruments for assessing outcomes, and test methods to improve
adherence to evidence-based practice guidelines and quality
standards. QUERI creates a formal link between research and
clinical care.
- Patient Safety Research is a natural component of
VA’s interdisciplinary health services research program. A
specific call for research proposals on, "Patient Safety and
the Prevention of Adverse Events," was announced in May 1998
and will remain open indefinitely. VA is building a research
portfolio in patient safety that will identify avoidable risks,
develop and test indicators of potential errors and injuries,
determine the cost-effectiveness of alternative approaches to
reduce or prevent medical errors, and evaluate the applicability
to VA of safety concepts, measures and initiatives developed in
the private health care sector or outside the health care arena.
VA has already invested over $ 2 million in patient safety
research projects in such areas as prevention of falls and adverse
drug reactions since 1997.
VA also has policies and procedures in place to
enhance patient safety during the conduct of research:
- VA is a signatory to the Federal Government-wide
Common Rule for the Protection of Human Subjects of Research, and
requires that all VA funded research be subject to the twin
protections of scientific merit review and human studies review.
VA has established the Office of Research Compliance and
Assurances (ORCA) to enhance its human subjects protection
program, and is the first public or private organization to
require external accreditation of all Institutional Review Boards
(IRBs) providing human studies review for VA facilities.
- VA carries out an extensive program of study
monitoring oversight activities for all large-scale multi-center
clinical trials funded by the agency under its Cooperative Studies
Program (CSP). Before any trial can begin, two planning meetings
involving the CSP Director, the responsible CSP Coordinating
Center, and the CSP site management team are held, the proposal is
approved by the Human Rights Committee at the responsible CSP
Coordinating Center, and authorization is given by the
Federally-chartered Cooperative Studies Executive Committee (CSEC)
following scientific merit review. The trial must also be approved
by the institutional review board (IRB) at each study site. While
the study is in progress it is monitored by an independent Data
Safety Monitoring Board, the Study Executive Committee, the site
management team, and, at mid-term, by CSEC. If the study involves
a new medication or device or a new use for a marketed product, it
is also subject to oversight by the U.S. Food and Drug
Administration.