1
Tactical and Strategic Planning
for Small IRBs
Dale Theobald, MD, PhD
IRB Chairman
Community Health Network
Parker Nolen, MBA CCRC CIP
Director, Research Compliance and Regulatory Affairs
Community Health Network
2
Disclosure: Dale Theobald, MD
I have no relevant
personal/professional/financial
relationship(s) with respect to this
educational activity
Community Health Network Chairman, IRB
3
Disclosure: Parker Nolen MBA
I have no relevant
personal/professional/financial
relationship(s) with respect to this
educational activity
Community Health Network Director, Research Compliance
4
Overview
Part 1: Case Study
Part 2: “The Business”
5
A CASE STUDY – “THE COMMUNITY WAY”
Part 1
6
About CHNw
• 200 sites of care
• 10 acute care and
specialty hospitals
• 13 ambulatory pavilions
• 9 surgery and endoscopy
centers
• >600 Physicians
7
Types of Research
Clinical Trials - Drug
Clinical Trials - Device
Clinical Trials - Other Intervention
Genetic Studies
Clinical Outcomes Research
Basic Research
Qualitative Research
Imaging and Diagnostics
Chart reviews/case reports
Registry or Repository
Training/Education/Quality Improvement
8
Internal
73%
External
27%
Users of the Network IRB
9
• 3 other large health care providers in region
• Indiana CTSI (IU, Purdue, Notre Dame)
• All have established research programs
• Implementation of the ACA
– New and different economic pressures on
providers
– Baseline question:
• “Can we survive on Medicare reimbursements
only?”
The Operating Environment
10
• Outsource IRB functions completely
– Transfer costs
– Maintenance costs
– Organizational Values
• Partner in a hybrid model
– Very few partners available
– Cost considerations
• Shut-down research
– Teaching hospital
– Not an option
• Get lean
Options
11
• Meetings lasted 2.5 hours
• Used only Full Board review
– Even Expedited- and Exempt-eligible items
• Electronic tracking system broken
• Board members received 400-600 pages
• 26 members on 1 board
• Questionable composition
– Unaffiliated meant retired employees
– Non-scientific meant not an MD
– Diversity meant only gender
• No SOPs
• Met 1x Monthly
• TAT ≈ >60 days (regardless of item)
October, 2013
12
Very Satisfied
16%
Satisfied
26%
Neither Satisfied
nor Unsatisfied
34%
Unsatified
24%
Customer Satisfaction 2013
13
• Unacceptable TAT
• Unacceptable customer satisfaction (< 50%)
• Inefficient use of Full Board review
• Meetings too long
• Membership composition issue
• Electronic tracking system inhibiting compliance
• No meeting cost had ever been calculated
• Meeting Cost per hour ≈ $1000 (prime cost)
Our Analysis
14
• More efficient use of Full Board time
– What can be handled administratively?
– What REALLY requires Full Board review?
• Quicker TAT
• Higher user satisfaction
• Better compliance
• Reduce costs
What did we want?
15
• Re-paneled the IRB
– Moved from 1 Board to 5 Boards
• Considered multiple Board compositions
– Prime cost critical consideration
– Personalities also an important consideration
• Increased meeting frequency
– 1x month to 1x week
• Staff triage/Pre-Review of submissions
• Expedited/Exempt reviews handled by staff*
How did we do it?
* non-scientific and administrative items only
16
• Contracted for different electronic system
– Translation: we are temporarily a paper-based
IRB
• Created new forms to serve as:
– submission
– documentation of review
– written determination
• Drafted and implemented new SOPs
• Eliminated submission deadlines
• Committed to 72 hour TAT metric
How did we do it?
17
• 4 Regular Boards
• 1 Emergency Board
• Each Panel meets composition requirements set forth in 21
CFR 56.107 and 46 CFR 46.107
– At least five (5) members
– Varying backgrounds
– Sufficient qualification of members
– Diversity with regard to race, gender, culture
– Professional Competence
– At least one (1) nonscientific member
– At least one (1) unaffiliated member
• Consultants used for specialty gap
• Member commitment is the same – 1x month
• Investigators see weekly meetings – 4x month
New Boards
18
Panel Assignments
* Board 5 is Emergency Use/Compassionate Use only (not regularly scheduled)
19
• Critical variable in transformation
• IRB Volunteer ≠ No cost
• Focused on identifying the Prime Costs
– Prime costs are the costs directly incurred to
create a product or service.
• Prime costs do not include indirect costs, such as
allocated overhead.
• Administrative costs are generally not included in
the prime cost category.
The Cost of Meeting
20
Legacy New
One (1) Panel Four (4) Panels
1x Month 4x Month
≈ 2.5 hours per meeting ≈ .25 hours per meeting
≈ $1,000 per hour prime cost ≈ $300 per hour prime cost
≈ $2,500 meeting cost ≈ $75 meeting cost
≈ $30,000 annual prime cost ≈ $3600 annual prime cost
Legacy vs. New
$26,400 reduction in Prime Costs
21
Performance Metrics
Source: 2013 AAHRPP Metrics on Human Research Protection Program Performance for Hospitals – Updated August 1, 2014
October 2013
September 2014
22
THE BUSINESS – TACTICS AND STRATEGIES
Part 2
23
Then…
24
Now…
25
• Those remaining four airlines control 80% of the market
Result of airline consolidation?
"...Data collected by the Airports Council International, a trade group,
found that the nation's smallest airports lost 10 to 15 percent of their
scheduled flights from June 2006 through this June. Medium-size
airports, meanwhile, lost 18 percent of their scheduled flights....
...Nearly 200 airports, most of them tiny and many in remote places,
have lost air service entirely since 2008....Airlines have made a
deliberate decision to forgo certain markets...Their new business
model is leaving communities disenfranchised and disconnected from
the global marketplace.
(Mouad, Jad. "Lost Jobs, Lost Flights." New York Times 09 July 2011)
26
What business are we really in?
27
• Affordable Care Act
• Consolidation and Globalization among
Commercial IRBs
• AAHRPP supporting consolidation and
globalization
• University of Minnesota tragedy
– Possible Congressional hearings
• Emergence of mHealth
• Single IRB Review is here
State of the
Clinical Research Industry
28
• Will local IRBs have relevance?
• Will our field remain “Professional” at the local
level?
• Will our institutions have access to Sponsored
research?
• Will our patients have access to novel points of
care?
Implications for Small IRBs
Yes! But…
Small IRBs must be strategic in their thinking and
creative in approaching their operations and their
cost/revenue analysis
29
• Market Forces
• SWOT Analysis
• Market Strategy
• Competitive Advantage
• Value Chain
• Core Competence
Business Concepts
30
Five Market Forces
Threat of
new
entrants
Bargaining
power of
suppliers
Bargaining
power of
buyers
Competitive
Rivalry
Strategic
Position
Threat of
substitutes
31
SWOT Analysis
32
• Efficiency –
– matching or beating AAHRPP Metrics
• Cost Allocation/Overhead
• Cost of Operation/Marginal Costs
• Specialization
Potential Strengths
33
• Bloated Board
• Wordsmithing
• Long TAT
• Board Personalities
• Lack of reviewer specialization
Potential Weaknesses
34
• Possible partnerships
– Academic
– Institutional
• Reciprocal reviews
– Network/Multi-site review
• Mergers with other IRBs in the area
• Minimum necessary allows agility
Potential Opportunities
35
• Single IRB Review
• Cost pressure/Revenue squeeze
• Market Consolidation in for-profit IRBs
Potential Threats
36
• Figure out what your IRB wants to be
– Porter’s Three Strategies
• Figure out how to do it
– Strategy vs. Tactic
• Develop a relationship with Finance
• Identify your Core Competency
• Identify your Competitive Advantage
• Calculate your Net Present Value (NPV)
How do I address the SWOT?
37
Porter’s Three Strategies (1980)
Cost Leadership Differentiation
Niche (Focus)
Stuck in the Middle
38
• It is exactly what it sounds like.
• The low-cost leader in any market gains
competitive advantage from being able to
produce the product/service at the lowest
price.
• This is a strategy that can be leveraged by
institutionally-based IRBs!
Cost Leadership
39
• Allows companies to charge high prices
and focus on a volume that generates a
better margin
• This will incur additional costs in creating a
competitive advantage.
– Example: Creating an oncology research
specialty
Differentiation
40
• Identifiable and unique needs
• Sufficient size
• Difficult, but doable!
Focus strategy (Niche strategy)
41
• The total amount that buyers are willing to
pay for a product/service
• The difference between the total value (or
revenue) and the total cost of performing
all of the activities provides the Margin
• Value Chain
Value
42
• Two categories
– Primary Activities (Review, Determination)
– Support Activities (HR, Accounting, etc…)
• All activities to design, produce, market,
deliver, and support the product/service
(Porter, 1980)
– IRB Software
– Salaries
– Space
Value chain
43
• Identify capability in which you excel
• Focus on opportunities in that area, letting
others go or outsourcing them.
• Capability is difficult to duplicate
• Involves the skills and coordination of
people across a variety of functional areas
or processes used to deliver value to
customers.
Core Competency
44
• Three building blocks:
a) the external environment, including society, market, customer, and technology;
b) the mission of the organization; and
c) the core competencies needed to accomplish the mission.
• Four criteria:
1. assumptions about the environment, mission, and core competencies must fit
reality;
2. the assumptions in all three areas have to fit one another;
3. the theory of the business must be known and understood throughout the
organization; and
4. the theory of the business has to be tested constantly.
Competitive Advantage
45
• In what area does my IRB excel or specilaze?
– Eye institute?
– SBH?
• What areas can we outsource/delegate?
– Specialty review consultants as opposed to keeping a
large membership roster?
• Who are my customers?
– Service orientation is crucial
– Educator, not enforcer
• What are my built-in advantages?
So ask yourself…
46
• Cost and Overhead Allocations
– Departmental allocation only?
– Work with finance people to spread costs over
institution/network as a shared service
• May not be possible, but if you’re a multi-site IRB,
it is probable.
• Not an easy argument – be prepared!
• Marginal costs are low
– Allows innovative pricing/revenue models
Built-in Advantages to local IRBs
47
Strategy vs. Tactic
Strategy
• Is the “What”?
• Defines goals
• Larger plan made up of
several tactics
• Examples:
– Make our Local IRB
desirable for Sponsors
to use by offering
multi-site approvals
Tactic
• Is the “How”?
• Specific actions
• Implements the strategy
• Example:
– Aligning with another
Local IRB through
merger or reciprocal
agreement
48
Put another way…
Source: http://www.uxmatters.com/mt/archives/2015/02/strategy-versus-
tactics.php
49
• Calculate Net Present Value (NPV) to your
Organization
• Know what your product costs!!!
– How much does it cost to run a meeting?
– How are our overhead costs allocated in the
organization?
• Can they be shared across a wide population/large
number of regions/departments?
• What are we doing that doesn’t need to be
done?
Things to immediately understand
50
NPV Definition and Formula
“r” represents the rate of return. It is determined by industry and usually ranges from 8% – 15%.
51
Put another way…
52
Develop Geographic Footprint
• Why?
– Create a critical mass
of sites
– Want to be attractive
to the Sponsors
• How?
– IAA?
– Reciprocal Reviews?
– Merger?
– Commercialize?
53
AAHRPP
54
2015
55
201X
56
Conclusion
• Keep abreast of industry trends
• Know your SWOT
• Identify your Core Competencies
• Identify your Competitive Advantages
• Identify your costs/potential revenue
• Build a relationship with Finance
• Consider Alternative Models
57
Contact Information
Dale Theobald, MD, PhD
Parker Nolen, MBA, CCRC, CIP
IRB@eCommunity.com
(317) 355-5678

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AER15_PPT.FINAL

  • 1. 1 Tactical and Strategic Planning for Small IRBs Dale Theobald, MD, PhD IRB Chairman Community Health Network Parker Nolen, MBA CCRC CIP Director, Research Compliance and Regulatory Affairs Community Health Network
  • 2. 2 Disclosure: Dale Theobald, MD I have no relevant personal/professional/financial relationship(s) with respect to this educational activity Community Health Network Chairman, IRB
  • 3. 3 Disclosure: Parker Nolen MBA I have no relevant personal/professional/financial relationship(s) with respect to this educational activity Community Health Network Director, Research Compliance
  • 4. 4 Overview Part 1: Case Study Part 2: “The Business”
  • 5. 5 A CASE STUDY – “THE COMMUNITY WAY” Part 1
  • 6. 6 About CHNw • 200 sites of care • 10 acute care and specialty hospitals • 13 ambulatory pavilions • 9 surgery and endoscopy centers • >600 Physicians
  • 7. 7 Types of Research Clinical Trials - Drug Clinical Trials - Device Clinical Trials - Other Intervention Genetic Studies Clinical Outcomes Research Basic Research Qualitative Research Imaging and Diagnostics Chart reviews/case reports Registry or Repository Training/Education/Quality Improvement
  • 9. 9 • 3 other large health care providers in region • Indiana CTSI (IU, Purdue, Notre Dame) • All have established research programs • Implementation of the ACA – New and different economic pressures on providers – Baseline question: • “Can we survive on Medicare reimbursements only?” The Operating Environment
  • 10. 10 • Outsource IRB functions completely – Transfer costs – Maintenance costs – Organizational Values • Partner in a hybrid model – Very few partners available – Cost considerations • Shut-down research – Teaching hospital – Not an option • Get lean Options
  • 11. 11 • Meetings lasted 2.5 hours • Used only Full Board review – Even Expedited- and Exempt-eligible items • Electronic tracking system broken • Board members received 400-600 pages • 26 members on 1 board • Questionable composition – Unaffiliated meant retired employees – Non-scientific meant not an MD – Diversity meant only gender • No SOPs • Met 1x Monthly • TAT ≈ >60 days (regardless of item) October, 2013
  • 12. 12 Very Satisfied 16% Satisfied 26% Neither Satisfied nor Unsatisfied 34% Unsatified 24% Customer Satisfaction 2013
  • 13. 13 • Unacceptable TAT • Unacceptable customer satisfaction (< 50%) • Inefficient use of Full Board review • Meetings too long • Membership composition issue • Electronic tracking system inhibiting compliance • No meeting cost had ever been calculated • Meeting Cost per hour ≈ $1000 (prime cost) Our Analysis
  • 14. 14 • More efficient use of Full Board time – What can be handled administratively? – What REALLY requires Full Board review? • Quicker TAT • Higher user satisfaction • Better compliance • Reduce costs What did we want?
  • 15. 15 • Re-paneled the IRB – Moved from 1 Board to 5 Boards • Considered multiple Board compositions – Prime cost critical consideration – Personalities also an important consideration • Increased meeting frequency – 1x month to 1x week • Staff triage/Pre-Review of submissions • Expedited/Exempt reviews handled by staff* How did we do it? * non-scientific and administrative items only
  • 16. 16 • Contracted for different electronic system – Translation: we are temporarily a paper-based IRB • Created new forms to serve as: – submission – documentation of review – written determination • Drafted and implemented new SOPs • Eliminated submission deadlines • Committed to 72 hour TAT metric How did we do it?
  • 17. 17 • 4 Regular Boards • 1 Emergency Board • Each Panel meets composition requirements set forth in 21 CFR 56.107 and 46 CFR 46.107 – At least five (5) members – Varying backgrounds – Sufficient qualification of members – Diversity with regard to race, gender, culture – Professional Competence – At least one (1) nonscientific member – At least one (1) unaffiliated member • Consultants used for specialty gap • Member commitment is the same – 1x month • Investigators see weekly meetings – 4x month New Boards
  • 18. 18 Panel Assignments * Board 5 is Emergency Use/Compassionate Use only (not regularly scheduled)
  • 19. 19 • Critical variable in transformation • IRB Volunteer ≠ No cost • Focused on identifying the Prime Costs – Prime costs are the costs directly incurred to create a product or service. • Prime costs do not include indirect costs, such as allocated overhead. • Administrative costs are generally not included in the prime cost category. The Cost of Meeting
  • 20. 20 Legacy New One (1) Panel Four (4) Panels 1x Month 4x Month ≈ 2.5 hours per meeting ≈ .25 hours per meeting ≈ $1,000 per hour prime cost ≈ $300 per hour prime cost ≈ $2,500 meeting cost ≈ $75 meeting cost ≈ $30,000 annual prime cost ≈ $3600 annual prime cost Legacy vs. New $26,400 reduction in Prime Costs
  • 21. 21 Performance Metrics Source: 2013 AAHRPP Metrics on Human Research Protection Program Performance for Hospitals – Updated August 1, 2014 October 2013 September 2014
  • 22. 22 THE BUSINESS – TACTICS AND STRATEGIES Part 2
  • 25. 25 • Those remaining four airlines control 80% of the market Result of airline consolidation? "...Data collected by the Airports Council International, a trade group, found that the nation's smallest airports lost 10 to 15 percent of their scheduled flights from June 2006 through this June. Medium-size airports, meanwhile, lost 18 percent of their scheduled flights.... ...Nearly 200 airports, most of them tiny and many in remote places, have lost air service entirely since 2008....Airlines have made a deliberate decision to forgo certain markets...Their new business model is leaving communities disenfranchised and disconnected from the global marketplace. (Mouad, Jad. "Lost Jobs, Lost Flights." New York Times 09 July 2011)
  • 26. 26 What business are we really in?
  • 27. 27 • Affordable Care Act • Consolidation and Globalization among Commercial IRBs • AAHRPP supporting consolidation and globalization • University of Minnesota tragedy – Possible Congressional hearings • Emergence of mHealth • Single IRB Review is here State of the Clinical Research Industry
  • 28. 28 • Will local IRBs have relevance? • Will our field remain “Professional” at the local level? • Will our institutions have access to Sponsored research? • Will our patients have access to novel points of care? Implications for Small IRBs Yes! But… Small IRBs must be strategic in their thinking and creative in approaching their operations and their cost/revenue analysis
  • 29. 29 • Market Forces • SWOT Analysis • Market Strategy • Competitive Advantage • Value Chain • Core Competence Business Concepts
  • 30. 30 Five Market Forces Threat of new entrants Bargaining power of suppliers Bargaining power of buyers Competitive Rivalry Strategic Position Threat of substitutes
  • 32. 32 • Efficiency – – matching or beating AAHRPP Metrics • Cost Allocation/Overhead • Cost of Operation/Marginal Costs • Specialization Potential Strengths
  • 33. 33 • Bloated Board • Wordsmithing • Long TAT • Board Personalities • Lack of reviewer specialization Potential Weaknesses
  • 34. 34 • Possible partnerships – Academic – Institutional • Reciprocal reviews – Network/Multi-site review • Mergers with other IRBs in the area • Minimum necessary allows agility Potential Opportunities
  • 35. 35 • Single IRB Review • Cost pressure/Revenue squeeze • Market Consolidation in for-profit IRBs Potential Threats
  • 36. 36 • Figure out what your IRB wants to be – Porter’s Three Strategies • Figure out how to do it – Strategy vs. Tactic • Develop a relationship with Finance • Identify your Core Competency • Identify your Competitive Advantage • Calculate your Net Present Value (NPV) How do I address the SWOT?
  • 37. 37 Porter’s Three Strategies (1980) Cost Leadership Differentiation Niche (Focus) Stuck in the Middle
  • 38. 38 • It is exactly what it sounds like. • The low-cost leader in any market gains competitive advantage from being able to produce the product/service at the lowest price. • This is a strategy that can be leveraged by institutionally-based IRBs! Cost Leadership
  • 39. 39 • Allows companies to charge high prices and focus on a volume that generates a better margin • This will incur additional costs in creating a competitive advantage. – Example: Creating an oncology research specialty Differentiation
  • 40. 40 • Identifiable and unique needs • Sufficient size • Difficult, but doable! Focus strategy (Niche strategy)
  • 41. 41 • The total amount that buyers are willing to pay for a product/service • The difference between the total value (or revenue) and the total cost of performing all of the activities provides the Margin • Value Chain Value
  • 42. 42 • Two categories – Primary Activities (Review, Determination) – Support Activities (HR, Accounting, etc…) • All activities to design, produce, market, deliver, and support the product/service (Porter, 1980) – IRB Software – Salaries – Space Value chain
  • 43. 43 • Identify capability in which you excel • Focus on opportunities in that area, letting others go or outsourcing them. • Capability is difficult to duplicate • Involves the skills and coordination of people across a variety of functional areas or processes used to deliver value to customers. Core Competency
  • 44. 44 • Three building blocks: a) the external environment, including society, market, customer, and technology; b) the mission of the organization; and c) the core competencies needed to accomplish the mission. • Four criteria: 1. assumptions about the environment, mission, and core competencies must fit reality; 2. the assumptions in all three areas have to fit one another; 3. the theory of the business must be known and understood throughout the organization; and 4. the theory of the business has to be tested constantly. Competitive Advantage
  • 45. 45 • In what area does my IRB excel or specilaze? – Eye institute? – SBH? • What areas can we outsource/delegate? – Specialty review consultants as opposed to keeping a large membership roster? • Who are my customers? – Service orientation is crucial – Educator, not enforcer • What are my built-in advantages? So ask yourself…
  • 46. 46 • Cost and Overhead Allocations – Departmental allocation only? – Work with finance people to spread costs over institution/network as a shared service • May not be possible, but if you’re a multi-site IRB, it is probable. • Not an easy argument – be prepared! • Marginal costs are low – Allows innovative pricing/revenue models Built-in Advantages to local IRBs
  • 47. 47 Strategy vs. Tactic Strategy • Is the “What”? • Defines goals • Larger plan made up of several tactics • Examples: – Make our Local IRB desirable for Sponsors to use by offering multi-site approvals Tactic • Is the “How”? • Specific actions • Implements the strategy • Example: – Aligning with another Local IRB through merger or reciprocal agreement
  • 48. 48 Put another way… Source: http://www.uxmatters.com/mt/archives/2015/02/strategy-versus- tactics.php
  • 49. 49 • Calculate Net Present Value (NPV) to your Organization • Know what your product costs!!! – How much does it cost to run a meeting? – How are our overhead costs allocated in the organization? • Can they be shared across a wide population/large number of regions/departments? • What are we doing that doesn’t need to be done? Things to immediately understand
  • 50. 50 NPV Definition and Formula “r” represents the rate of return. It is determined by industry and usually ranges from 8% – 15%.
  • 52. 52 Develop Geographic Footprint • Why? – Create a critical mass of sites – Want to be attractive to the Sponsors • How? – IAA? – Reciprocal Reviews? – Merger? – Commercialize?
  • 56. 56 Conclusion • Keep abreast of industry trends • Know your SWOT • Identify your Core Competencies • Identify your Competitive Advantages • Identify your costs/potential revenue • Build a relationship with Finance • Consider Alternative Models
  • 57. 57 Contact Information Dale Theobald, MD, PhD Parker Nolen, MBA, CCRC, CIP IRB@eCommunity.com (317) 355-5678

Editor's Notes

  • #21: Costing is an important consideration. In our transformation, one new protocol covers our cost. Every review we conduct after the first one is pure profit for the department. We are now able to use marginal pricing as a competitive advantage in the marketplace which will be important in 2015 as me move to accreditation.
  • #22: So this is a chart we all know – it is the AAHRPP Metrics chart. The red line indicates where we were. The green line shows you where we are now.
  • #24: Before we get started with the academic stuff, let’s step out of the IRB/Compliance world for a second. Not too long ago, if you wanted to travel from point A to point B, you had a lot of options. Do these logos look familiar?
  • #25: Now there are four airlines that carry a majority of air travelers. And these four companies are VERY different from their predecessors even if they have the same name. They have transformed themselves into lean, efficient operations. 20% of the airports in the United States have lost air service as a result of this consolidation. Think about that… I just want you to remember this as we move through this presentation.