SCDM CCDM - Certified Clinical Data Manager

Thebest methodto identify sites withhigh subject attritionis to calculate theproportion of patients for which two visit periods have passed without data, by site.

According to theGCDMP (Chapter: Data Quality Assurance and Control), subject attrition is an important performance indicator for data completeness and site compliance. Evaluating missing or delayed data acrossmultiple consecutive visit periodsallows for early detection of potential dropouts or site-level operational issues.

By assessing this proportion at thesite level, the Data Manager can distinguish between random missing data and systematic site underperformance. Counting or proportioning late visits (options B and C) identifies scheduling delays, not attrition. Looking at missing data without site context (option D) fails to identify site-specific patterns, limiting corrective action.

This metric aligns withrisk-based monitoring (RBM)practices recommended byICH E6 (R2)andFDA RBM Guidance, which promote proactive identification of sites at risk of data loss.

Reference (CCDM-Verified Sources):

SCDM Good Clinical Data Management Practices (GCDMP), Chapter: Data Quality Assurance and Control, Section 5.4 – Site Performance Metrics

ICH E6 (R2) Good Clinical Practice, Section 5.18 – Monitoring and Site Performance Evaluation

FDA Guidance for Industry: Oversight of Clinical Investigations – Risk-Based Monitoring, Section 6 – Site Performance Metrics

Prior to an audit, theauditeeshould expect to receive anaudit plan or agenda, which outlines thescope, objectives, schedule, and logisticsof the audit.

According to theGCDMP (Chapter: Quality Assurance and Audits), anaudit planensures transparency, preparation, and efficient execution. It typically includes details such as:

The audit scope and objectives,

The audit team members,

Documents or processes to be reviewed, and

The audit schedule and timeframe.

This allows the auditee to prepare the necessary records, staff, and facilities. While the auditor’s credentials (option A) may be shared informally, they are not a regulatory requirement.Corrective actions (option B)are outcomes of the audit, not pre-audit materials.Standard Operating Procedures (option C)may be requested during the audit but are not provided in advance.

Thus,Option D – Audit Plan or Agenda– is the correct and compliant answer.

Reference (CCDM-Verified Sources):

SCDM Good Clinical Data Management Practices (GCDMP), Chapter: Quality Assurance and Audits, Section 6.1 – Pre-Audit Planning and Communication

ICH E6 (R2) Good Clinical Practice, Section 5.19.3 – Audit Procedures and Responsibilities

FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations – Section 8.1 – Audit Preparation and Planning

Once a clinical database islocked, it becomesread-only— no further data modifications can be made by any users, including site personnel. This ensures that the data arefinalized, consistent, and auditablefor statistical analysis and regulatory submission.

According to theGCDMP (Chapter: Database Lock and Archiving), the lock process involves freezing the database to prevent accidental or unauthorized changes. After lock, access permissions are restricted, and all edit and update functions are disabled. If any corrections are required post-lock, the database must beunlocked under controlled procedures(with full audit trail documentation).

Thus,option C—The site study coordinator is not able to make the change— correctly reflects standard EDC functionality and regulatory compliance.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: Database Lock and Archiving, Section 5.2 – Database Lock Procedures and Controls

ICH E6(R2) GCP, Section 5.5.3 – Data Integrity and Audit Trail Requirements

FDA 21 CFR Part 11 – Controls for Electronic Records and System Lock Functions

In managingsite data timeliness, the most actionable and effective tool is areport listing all outstanding (missing or incomplete) CRFs.

According toGCDMP (Chapter: Communication and Study Reporting), Data Managers must providesite-level performance reportshighlighting:

Outstanding CRFs not yet entered,

Unresolved queries, and

Pending data corrections.

Such reports help sites prioritize and address data gaps efficiently.

Option AandDare historical metrics without actionable context.

Option Bgives a general overview but lacks specific site-level actionability.

Hence,option C (List of outstanding forms)provides the clearest and most motivating feedback to sites for timely data entry and query resolution.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: Communication and Study Reporting, Section 5.3 – Data Timeliness and Reporting Metrics

ICH E6(R2) GCP, Section 5.1.1 – Sponsor Oversight and Data Communication Requirements

FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations, Section 6.5 – Site-Level Data Timeliness Reporting

Case Report Form Completion Guidelines (CCGs)are essential study documents that instruct site staff on how to complete each field of the CRF correctly. Aminimum requirementfor CCGs, according toGood Clinical Data Management Practices (GCDMP, Chapter: CRF Design and Data Collection), is that they must includeversion control.

Version control ensures that all updates or revisions to the CCG—arising from protocol amendments or clarification of data entry rules—are documented, dated, and traceable. This guarantees that site personnel are always using the most current version and supports audit readiness.

Option A describes an important design consideration but not a minimum compliance requirement. Option B is inaccurate, as CCGs must be approved and implementedbefore data collection begins, not after. Option D includes an irrelevant stakeholder (Marketing).

Therefore,option C—“CCGs must include a version control on the updated document”—is correct and compliant with CCDM and GCP standards.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: CRF Design and Data Collection, Section 4.3 – Development and Maintenance of CRF Completion Guidelines

ICH E6(R2) GCP, Section 8.2.1 – Essential Documents and Version Control Requirements

When an investigator retires mid-study and the replacement refuses to use theElectronic Data Capture (EDC)system, thedata managermust not take unilateral action but rathercollaborate with the study teamto explore acceptable solutions.

Per theGCDMP (Chapter: Project Management in Data Management), any deviation from the established data capture method — particularly a change that affects regulatory compliance, data consistency, or site operations — requires a cross-functional assessment. The study team, which includes clinical operations, project management, regulatory affairs, and data management, should evaluate feasible alternatives such as:

Allowing paper CRF entry followed by centralized data transcription,

Retraining site staff on EDC use, or

Temporarily suspending data entry until compliance can be restored.

Immediate site closure (option A) or unilateral decisions by data management (options C and D) violate escalation and communication protocols. Collaborative decision-making ensures continuity, compliance, and data integrity, in line withICH E6 (R2) GCPandFDA 21 CFR Part 11.

Reference (CCDM-Verified Sources):

SCDM Good Clinical Data Management Practices (GCDMP), Chapter: Project Management and Communication, Section 5.2 – Handling Site and Investigator Changes

ICH E6 (R2) Good Clinical Practice, Section 4.1 – Investigator Responsibilities

FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations – Section on EDC Operations and Site Management

In Structured Query Language (SQL), theWHEREclause is used to filter records based on specified criteria. The query retrievesall columnsfrom thepatienttable (SELECT *) but onlythose rowswhere themedical_record_numbervalue is greater than 9000.

This means:

Thenumber of columns (fields)remains the same as the original table.

Thenumber of rows (records)will beequal to or less thanthe number of rows in thepatienttable, depending on how many patients meet the filter condition.

Hence, the result set can only beshorter or equal in lengthcompared to the original table. It cannot be longer, wider, or narrower, since no new rows or columns are created.

Therefore,option B—“Shorter or of equal length than the patient table”— is correct.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: Database Design and Build, Section 5.2 – Relational Database Queries and Filtering Logic

ICH E6(R2) GCP, Section 5.5.3 – Data Retrieval, Filtering, and Storage Principles

FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations, Section 6.4 – Query Logic and Record Subsetting

In this scenario, the site hasdeviated from the approved study protocolby using adifferent formulation (nebulized albuterol instead of inhaler). This is considered aprotocol deviation or violation, depending on study definitions.

PerGCDMP (Chapter: Data Validation and Cleaning)andICH E6(R2), Data Managers are responsible for ensuring that all protocol deviations affecting data integrity or subject safety areaccurately captured and documentedwithin the clinical database. The appropriate action is toissue a data queryprompting the site to record the deviation in the designated section (e.g., “Protocol Deviations” CRF).

Option A:Incorrect — it affects data comparability.

Option B:Escalation to the Ethics Committee is handled by the sponsor, not the Data Manager.

Option C:Updating the CRF guidelines is premature; first, the deviation must be logged and assessed.

Therefore,option D (Query the site to enter a Protocol Violation)is the correct and compliant action.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: Data Validation and Cleaning, Section 6.2 – Query Management and Protocol Deviations

ICH E6(R2) GCP, Section 4.5 – Compliance with Protocol

FDA Guidance for Industry: Oversight of Clinical Investigations — Compliance and Protocol Deviation Reporting

Standard Operating Procedures (SOPs)are formal, controlled documents that definestandardized processesto ensure clinical trials are conducted in compliance withGood Clinical Practice (GCP), the study protocol, and regulatory requirements (such as ICH and FDA).

According toGood Clinical Data Management Practices (GCDMP)andICH E6(R2) GCP, SOPs are fundamental to quality management systems. They describehowtasks are performed, ensuring consistency, accountability, and traceability across all studies and team members. Proper adherence to SOPs guarantees that data areaccurately generated, documented, and reportedin compliance with ethical and regulatory standards.

Other options serve different purposes:

SAP (B)defines statistical methodology, not compliance control.

DMP (C)focuses on study-specific data handling, not organizational compliance.

CRFs (D)are tools for data collection but do not enforce compliance by themselves.

Therefore,option A (SOP)is correct.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: Quality Management and Compliance, Section 5.1 – Role of SOPs in Regulatory Compliance

ICH E6(R2) GCP, Section 2.13 and 5.1.1 – Quality Management Systems and SOP Requirements

FDA 21 CFR Part 312.50 – Sponsor Responsibilities and Compliance Systems