Suggested workflow for tracking manual transaction edits
To ensure auditability and regulatory compliance of edits to synchronization transactions in a production environment, the following workflow and guidelines are recommended:
- Use the transaction editing feature of CIS Administration primarily as a system implementation tool. In production, use it only when no other solution to a synchronization failure is available.
- Before changing a synchronization transaction, notify the investigator of the planned action and obtain formal signoff indicating that the investigator agrees to the action.
- At the site, maintain a manual log of the occasions on which you edit synchronization transactions. This log should record:
- The user who performed the edit.
- The date and time of the action.
- The trial or protocol in which synchronization transactions were edited.
- Update the data in the InForm software if necessary to reflect the change.
- When an audit of integrated study transactions is required, query the INF_MSGEDIT_HISTORY table for each trial in which synchronization transactions were edited to produce the audit record of those actions. At a minimum, review the INF_MSGEDIT_HISTORY table as part of the database locking process. If any records exist, verify the existence of the required paper documentation at the site.
Note: If you do not follow similar steps to make sure your audit trail is complete, you may be using the CIS software in a way that is not fully compliant with CFR 11.