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Frequently Asked Questions

Physician-Initiated Research Studies

Program Overview

What are CARE and the ISR Program? What is a "sponsor-investigator"? Isn't Boston Scientific the sponsor? Is the program appropriate for me?

Protocol Submission and Review

How can I submit my idea to the ISR Program? How is it determined which proposals will be funded by the ISR Program? Who is on the ISR Committee? What documents are required for a proposal submission? What comprises a full protocol? Can I submit a study idea before developing a full protocol? When are decisions regarding proposal approvals communicated?

Study Management

Can CARE, the ISR Committee or other Boston Scientific experts help me develop a protocol, statistical analysis plan, etc? Who owns the data after the study has closed? Can the ISR Program manage a database for my research, run the statistical analysis, or participate in drafting of publications? Can Boston Scientific control or prevent me from publishing results?

Study Overruns

What happens if my study is not progressing as originally anticipated? If I have had a trial closed mid-study or have trials that are behind, does that preclude me from initiating additional projects with Boston Scientific?

Sponsor-Investigator Responsibilities

What is trial registration? Is it required and who is responsible for registering? Who reports adverse events (AEs) in ISR Program studies? What are my responsibilities with respect to the FDA? What does the ISR Program do to help me succeed?

Other Resources

How can I access the FDA GCP guidance document and information about CFR 21?


Program Overview


What are CARE and the ISR Program?

CARE is The Center for the Advancement of Research. It oversees the Investigator-Sponsored Research (ISR) Program, which consolidates and tracks the evaluation, funding, and follow-up of investigator-sponsored research proposals that are supported by Boston Scientific. For you, this program makes proposal submissions easier and the process more accessible. For Boston Scientific, the program ensures studies are progressing and makes the results more visible.


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What is a "sponsor-investigator"? Isn't Boston Scientific the sponsor?

A sponsor-investigator is a single individual or facility that is responsible for fulfilling the obligations of both a sponsor and an investigator. The sponsor's role is not related to financial support, which is provided by a funding agency. Following is a brief overview of the roles and responsibilities in the ISR Program:

Funding Agency CARE through the ISR Program Provides financial support for the study according to a defined Research Contract, which outlines milestones and specific deliverables
Sponsor Physician Oversees the conduct of the study, including document management, data management, data analysis, publication, FDA reporting, etc.
Investigator Physician Conducts the day-to-day research according to a defined protocol and per specified procedures

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Is the program appropriate for me?

The program supports unsolicited, investigator-sponsored trials. This means that as the sponsor, you are entirely responsible for protocol design, statistical analysis, study registration, IRB approval, reporting of adverse events, and other sponsor responsibilities. You will need a working knowledge of study design and management as well as federal regulations for conducting research and good clinical practice (GCP) guidelines. You will also need to ensure you have the resources available to conduct the trial (eg, personnel, equipment, time). For more information, visit www.fda.gov


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Protocol Submission and Review

How can I submit my idea to the ISR Program?

Submit your idea through the CARE website: www.guidantcare.com. You can set up a user account to manage submissions, track the review process, document milestone completion and payment, and submit publications.


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How is it determined which proposals will be funded by the ISR Program?

The ISR Committee reviews studies on a periodic basis to evaluate them for scientific merit, novelty, strategic alignment, and other criteria. If a study is of interest, it passes to the funding review phase in which the top studies are offered contract opportunities.


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Who is on the ISR Committee?

The ISR Committee is a multi-functional team consisting of experts in science, clinical applications, regulatory, and law. Additional individuals may participate in proposal evaluation as needed.


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What documents are required for a proposal submission?

For a full protocol evaluation and funding review, the ISR Committee must receive:

  1. Sponsor-investigator name and contact information
  2. A study overview
  3. The full protocol
  4. A risk assessment
  5. Requested funding detail
  6. An explanation of how the study will further the field and/or industry
  7. A publication plan
  8. The sponsor-investigator's curriculum vitae

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What comprises a full protocol?

A full protocol consists of:

  1. The project title
  2. Expected duration of study
  3. Project objectives or hypothesis
  4. An explanation of the rationale and scientific novelty
  5. The methods of study / study design and justification
  6. A statistical analysis plan including sample size justification and power analysis
  7. A list of products involved (if specific)
  8. References

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Can I submit a study idea before developing a full protocol?

Yes. An optional process exists in which a study idea can be submitted to the ISR Committee for review. To submit a study idea, only the following are required:

  1. Sponsor-investigator name and contact information
  2. A study overview
  3. Anticipated aggregate funding requirements

With this information, the ISR Committee will determine whether or not Boston Scientific would like to support the exploration proposed by the study idea. If so, the additional information required for a proposal submission will be necessary before funding can be considered. Please note: expression of interest is NOT an automatic approval.


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When are decisions regarding proposal approvals communicated?

The ISR Committee meets monthly to evaluate proposals for scientific validity, regulatory risk, and strategic alignment. On a quarterly basis, the highest priority studies are evaluated for funding. You can expect communication from the committee along the entire process. Additionally, decisions are posted on the CARE website (www.guidantcare.com) and can be accessed through users' individual accounts. If your study has been selected for funding, you will be immediately notified so research contracts can be agreed upon and executed in a timely manner.


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Study Management

Can CARE, the ISR Committee, or other Boston Scientific experts help me develop a protocol or statistical analysis plan?

No. As part of the requirements for product promotion, investigator-sponsored trials must be "unsolicited." Boston Scientific is allowed to post generalized areas of interest, but cannot participate in study concept generation or protocol development. Once the protocol is developed, the committee may ask questions to clarify the design or may offer general advice if the proposal needs more structure. However, you must maintain your role as the author and owner of the project.


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Who owns the data after the study has closed?

In most cases, unless otherwise specified, you or your facility will own the data. In that case, patient/study data received by CARE that are related to your study will be destroyed. If your research agreement indicates that Boston Scientific will own or have access to data, methods and types of disclosure will be specified therein.


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Can the ISR Program manage a database for my research, run the statistical analysis, or participate in drafting of publications?

No. Boston Scientific cannot manage the study nor participate in data collection or analysis.


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Can Boston Scientific control or prevent me from publishing results?

No, under no circumstances will Boston Scientific delay or halt publication of results. To protect intellectual property, you will be asked to submit a draft prior to submission to a third party so Boston Scientific can request reasonable redrafting if propriety information is revealed.


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Study Overruns

What happens if my study is not progressing as originally anticipated?

Should your study fall behind such that additional time, additional funding, or protocol changes become necessary, you will be asked to describe what has caused the change and what you believe can be done to get the project back on track. The ISR committee will review the proposed changes and work with you to make a decision on remedial action. Because study progress is documented in the research contract, an amendment is generally required.


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If I have had a trial closed mid-study or have trials that are behind, does that preclude me from initiating additional projects with Boston Scientific?

The ISR Committee will consider the "big picture" in evaluating proposals and will look into any past and current projects and their status. Past performance will be considered. However, the Committee recognizes that a study might be closed or delayed for reasons beyond your control. Depending on the reason(s), the ISR Committee may decline to fund future projects, withhold a funding decision until outstanding issues are resolved, or determine that past closure or delay is not indicative of future study performance.


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Sponsor-Investigator Responsibilities

What is trial registration? is it required and who is responsible for registering?

As a condition of publication, the International Committee of Medical Journal Editors (ICMJE) requires study registration prior to enrolling the first subject(s). The party who is responsible for conducting the trial (either sponsor or principal investigator) must register the study. As that individual, it is your responsibility to get your study registered. To learn about trial registration, visit the NIH protocol registration information website: http://prsinfo.clinicaltrials.gov/.


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Who reports adverse events (AEs) in ISR Program studies?

As part of good clinical practice (GCP) and as study sponsors, you should report AEs to the center IRB where the AE occurred and to Boston Scientific's Technical Services at 1-800-CARDIAC. To learn about reporting to IRBs, refer to the documented processes for the particular IRB(s). Guidance from the FDA regarding AE reporting is available at www.fda.gov.


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What are my responsibilities with respect to the FDA?

The FDA defines specific responsibilities for physicians, investigators, and sponsors. You must understand the requirements for all of these roles. Information on these requirements is available online in the FDA guidance on good clinical practice (GCP) and CFR 21 among other available documentation. Visit www.fda.gov.


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What does the ISR Program do to help me succeed?

The ISR committee has developed a "toolkit" that is provided to all recipients of ISR Program funding. The toolkit provides contacts, to-do lists, instructions, process explanations, additional resources available, reminders, and other relevant information as a reminder and quick reference guide. This material is designed to enable you to meet FDA and Boston Scientific requirements, complete your study successfully, and have a good experience conducting research with Boston Scientific's support; however, it is not a replacement for more extensive programs that may be available. The committee expects that you will already have an understanding of good clinical practice (GCP) and sponsor requirements.


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Other Resources

How can I access the FDA GCP guidance document and information about CFR 21?

To access these documents online, visit:

Good Clinical Practice:
http://www.fda.gov/ohrms/dockets/ac/04/briefing/4028B1_08_GFI-ICH%20E6.pdf

Code of Federal Regulations 21:
http://www.fda.gov/cdrh/aboutcfr.html



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