| 1 |
FDA-21CFR50.25 FDA |
CRITICAL |
incomplete |
Informed Consent Process |
The informed consent process description does not explicitly address all required elements of 21 CFR 50.25, specifically: a statement that the study involves research, the expected duration of participation, and all eight basic elements required by the regulation. |
Explicitly enumerate all eight basic elements required by 21 CFR 50.25(a) and six additional elements per 50.25(b) when applicable. Add specific language covering each element in the informed consent documentation. |
0.95 |
| 2 |
FDA-21CFR11 FDA |
HIGH |
incomplete |
Data Quality Assurance / QC |
The section mentions eCRF review and data upload but does not address electronic records and electronic signatures requirements under 21 CFR Part 11, including audit trails, system validation, and security controls. |
Add explicit statements regarding compliance with 21 CFR Part 11 requirements including: system validation documentation, audit trail capabilities for all data changes, and electronic signature controls. |
0.90 |
| 3 |
FDA-21CFR312.23-a3 FDA |
HIGH |
incomplete |
References |
The References section title indicates references were added for specific safety text but no actual bibliographic references are provided in the section content. FDA regulations require that protocol information be supported by appropriate references. |
Include complete bibliographic references for safety-related citations in proper format. Each reference should include authors, title, publication, year, and standard citation elements. |
0.90 |
| 4 |
FDA-21CFR312.23-a3 FDA |
HIGH |
incomplete |
Study Rationale |
The rationale does not adequately summarize previous human experience with the investigational drugs as required by 21 CFR 312.23(a)(3)(iv). While a reference study with the standard-of-care comparator is mentioned, there is insufficient summary of prior clinical data for the investigational agents. |
Include a comprehensive summary of: previous clinical studies with the investigational drugs (indications studied, doses used, safety profile), relevant nonclinical findings, and the basis for the selected doses and combination approach. |
0.82 |
| 5 |
ICH-E6R2-4.8 ICH |
HIGH |
incomplete |
IEC / IRB |
The section does not explicitly mention submission of protocol deviations, safety reports (SAEs/SUSARs), or annual/periodic reports to the IEC/IRB during the study, which are required under ICH-E6(R2). |
Complete the list of documents to be submitted during the study to include: protocol amendments, safety reports (SAEs, SUSARs, annual safety reports), protocol deviations, and recruitment updates. |
0.85 |
| 6 |
ICH-E6R2-6.3 ICH |
HIGH |
incomplete |
Ethical Design Considerations |
The section does not explicitly describe the anticipated benefits for trial subjects or society that justify the risks and burdens, as required by ICH E6(R2) 6.3. The balance of benefits versus risks is not adequately addressed. |
Add an explicit statement describing the anticipated benefits to participants (e.g., potential therapeutic benefit, access to investigational treatment) and how these justify the known and potential risks of participation. |
0.85 |
| 7 |
ICH-E6R2-6.4 ICH |
HIGH |
incomplete |
Investigator Agreement |
The investigator agreement does not explicitly mention the investigator's responsibility to maintain adequate and accurate source documents and trial records as required by ICH-E6(R2) Section 4.9. |
Add a statement such as: 'I agree to maintain adequate and accurate source documents and trial records in accordance with ICH-GCP requirements and to permit monitoring, audits, and inspections.' |
0.75 |
| 8 |
ICH-E6R2-6.4 ICH |
HIGH |
incomplete |
Source Documents |
The section does not explicitly address procedures for ensuring accuracy, completeness, legibility, and timeliness of source documents, nor does it specify requirements for corrections/amendments to source records. |
Add explicit language requiring that source documents be accurate, complete, legible, and contemporaneous. Include specific requirements for making corrections: single line through, dated, initialed, with reason for change. |
0.85 |
| 9 |
ICH-E6R2-6.4 ICH |
HIGH |
incomplete |
CRF Completion |
The section does not explicitly address audit trail requirements for eCRF entries, corrections, and alterations. ICH-E6(R2) 6.4 requires that systems with direct data entry provide audit trails to document all changes. |
Add explicit language stating that the eCRF system maintains a complete audit trail that records all data entries, corrections, and alterations, including the identity of the person making changes and timestamps. |
0.85 |
| 10 |
ICH-E6R2-6.4 ICH |
HIGH |
incomplete |
Publication / Reporting |
ICH-E6R2-6.4 requires protocols to describe procedures for recording and reporting adverse events and intercurrent illnesses. The section references special reporting situations but does not describe the actual procedures, timelines, or responsible parties. |
Include complete procedures for special reporting situations: what constitutes a reportable event, timeframes for reporting, responsible parties, reporting mechanisms, and follow-up requirements. |
0.85 |