105 CTRU Billing Procedures
| Document Name: CTRU Billing Procedures | Document Number: 105 | Revision Date: 30Jun2025 | Supersedes: N/A |
| Target Group: Research Personnel | Approval Date: 20Dec2024 | Effective Date: 01Jan2025 | Training Required: None |
Purpose
To ensure the Principal Investigator (PI) and all research team members assisting with the conduct of clinical research at the Ohio University Heritage College of Osteopathic Medicine’s Clinical and Translational Research Unit (CTRU) are informed about their obligations and responsibilities as they pertain to Good Clinical Practices (GCP), the investigational plan, applicable regulations, and institutional policies.
This Standard Operating Procedure (SOP) describes CTRU interactions with the Sponsor or Contract Research Organization (CRO). This procedure is intended to meet Food & Drug Administration (FDA) federal regulations and Good Clinical Practices (GCP) for billing procedures for services provided to PIs and Sponsors.
Responsibilities
The CTRU is responsible for developing, implementing, and maintaining SOPs. Creating new or revising an existing SOP is determined by changes to federal regulation, guidelines, institutional policies, or procedures. All applicable documents will be provided to departments and research teams conducting human subject research.
Definitions
Internally Funded Project: Projects with internal funding sources – including but not limited to, start-up funding, and bridge funding.
Externally Funded Project: Projects with external funding sources – including but not limited to, federal funding, pharmaceutical funding, and philanthropic funding.
Procedures
1. General Billing Guidelines:
- All time spent working on a specific project will be tracked and recorded under that project.
- Time spent on CTRU Quality Improvement projects, general training, administrative tasks, or other non-study-related activities will not be tracked.
- Project time will be categorized into billable and non-billable hours. Non-billable time will be tracked to provide a comprehensive understanding of CTRU services and productivity.
- All time entries will be finalized and submitted by the last business day of each month.
- Project time will be logged in increments of 0.25 hours, unless otherwise specified.
- Equipment usage will be logged in increments of 0.50 hours, unless otherwise specified.
2. Service Descriptions
NURSING: Completes minimal to high intensity study procedures and data collection or medication administration with research participants.
PROJECT MANAGEMENT: Oversees and coordinates the operational (i.e. IRB, feasibility, budget, etc.) aspects of assigned functional areas for clinical studies and works closely with study team and Principal Investigator.
RESEARCH ASSISTANT: Completes study related activities (i.e. may complete prescreening, informed consent, data collection/entry, recruitment, scheduling and participant compensation) as delegated by the PI.
RECRUITMENT: Encompasses the study specific creation, management, and execution of subject recruitment and marketing strategies.
STUDY PHYSICIAN: Provides protection of research participant safety through administrative review (i.e. study protocol development, adverse and serious adverse event management, lab or imaging results interpretation) or procedural oversight of a research study. May perform protocol specific medical procedures.
START-UP/CLOSEOUT Fee: A one-time fee charged assessed to cover the administrative and regulatory activities required to prepare a study for activation and closure.
3. Internally Funded Projects Time Tracking:
- Time spent on direct project activities will be tracked as a BILLABLE service.
- Examples of direct project activities include pre-screening, scheduling, recruitment, data or IRB management, monitoring visits, and conducting study visits.
- Time spent on supportive activities will be tracked as a NON-BILLABLE service.
- Examples of supportive activities include visit preparation, clean up, equipment calibration, consultation services, and general study communication
4. Externally Funded Project Time Tracking:
- All time spent on necessary project activities should be tracked as BILLABLE, unless otherwise directed.
Applicable Regulations, Guidance, and Policies
| Regulation | Title |
|---|---|
| 21 CFR 50 | Protection of Human Subjects |
| 21 CFR 312 | Investigational New Drug Application |
| 21 CFR 812 | Investigational Device Exemptions |
| 45 CFR 46 | Protection of Human Subjects |
| ICH E6(R2) | Guideline for Good Clinical Practice E6 Integrated Addendum |
| FDA Guidance for Industry | Investigator Responsibilities – Protecting the Rights, Safety, and Welfare of Study Subjects, October 2009 |
References: None
Attachments: None
Appendices: None
Approver: Director, CTRU and Clinical Partnerships