Perficient’s life sciences practice once had a manual, time-consuming and expensive process for signing and collecting validation documents. From handwritten signatures to scanning and shipping documents all over the globe, it was only a matter of time before we made the move to 21 CFR Part 11-compliant digital signatures.
Michelle Engler, an expert in the development of clinical applications, discussed our experience implementing a digital signature solution and how your organization can benefit from one too.
During the presentation, we will covered:
-Cost-benefit analysis
-Solution selection and implementation
-21 CFR Part 11 system validation
-Lessons learned
So einfach geht modernes Roaming fuer Notes und Nomad.pdf
Implementing Digital Signatures in an FDA-Regulated Environment
1. Implementing Digital Signatures in anFDA-Regulated EnvironmentMichelle Engler, Senior Application Architect, Life Sciences, Perficientwith support from Sally Miranker, Computer System Validation, Life Sciences, PerficientTina Howard, Quality Assurance-Compliance, Life Sciences, Perficient
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Perficient is a leading information technology consulting firm serving clients throughoutNorth America and Europe.
We help clients implement business-driven technology solutions that integrate business processes, improve worker productivity, increase customer loyalty and create a more agile enterprise to better respond to new business opportunities.
About Perficient
3. 3
•Founded in 1997
•Public, NASDAQ: PRFT
•2013 revenue $373 million
•Major market locations:
•Allentown, Atlanta, Boston, Charlotte, Chicago, Cincinnati, Columbus, Dallas, Denver, Detroit, Fairfax, Houston, Indianapolis, Minneapolis, New York City, Northern California, Oxford (UK), Philadelphia, Southern California, St. Louis, Toronto, Washington, D.C.
•Global delivery centers in China and India
•>2,200 colleagues
•Dedicated solution practices
•~90% repeat business rate
•Alliance partnerships with major technology vendors
•Multiple vendor/industry technology and growth awards
Perficient Profile
4. Business Process Management
Customer Relationship Management
Enterprise Performance Management
Enterprise Information Solutions
Enterprise Resource Planning
Experience Design
Portal / Collaboration
Content Management
Information Management
Mobile
BUSINESS SOLUTIONS
50+ PARTNERS
Safety / PV
Clinical Data Management
Electronic Data Capture
Medical Coding
Clinical Data Warehousing
Clinical Data Analytics
Clinical Trial Management
Healthcare Data Warehousing
Healthcare Analytics
CLINICAL / HEALTHCARE IT
Consulting
Implementation
Integration
Migration
Upgrade
Managed Services
Private Cloud Hosting
Validation
Study Setup
Project Management
Application Development
Software Licensing
Application Support
Staff Augmentation
Training
SERVICES
5. 5
Michelle Engler, Senior Solutions Architect
Life Sciences, Perficient
(650) 291-4710
Michelle.Engler@perificient.com
Sally Miranker, Head of Computer Systems Validation
Life Sciences, Perficient
(619) 980-7288
Sally.Miranker@perificient.com
Tina Howard, Head of Quality Assurance Compliance
Life Sciences, Perficient
(760) 696-3650
Tina.Howard@perificient.com
Welcome & Introduction
6. Agenda
•Digital Signature Technology Overview
•Requirements for a dSignatureSolution
•Available dSignatureSolutions
•dSignatureSolution and 21 CFR Part 11 Compliance
•Implementing, Validating, and Releasing the dSignatureSolution
•Demonstration
•Future Plans
•Questions
•Contact Information
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7. Digital Signature Technology Overview
Electronic Signatures and Digital Signatures
•Definitions
FDA 21 CFR 11.3 (7) -Electronic Signature
The term 'electronic signature' means an electronic sound, symbol, or process, attached to or logically associated with a contract or other record and executed or adopted by a person with the intent to sign the record
•FDA 21 CFR 11.3 (5) -Digital Signature
Digital signature means an electronic signature based upon cryptographic methods of originator authentication, computed by using a set of rules and a set of parameters such that the identity of the signer and the integrity of the data can be verified
A digital signature falls into a sub-group of electronic signatures that provides the highest levels of security and universal acceptance. Digital signatures are based on Public Key Infrastructure (PKI) technology, and guarantee signer identity and intent, data integrity, and the non-repudiation of signed documents.1
1. http://www.arx.com/learn/about-digital-signature/digital-signature-faq
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8. Digital Signature Technology Overview
What is a digital signature?
•Adigital signaturetakes the concept of traditional paper-based signing and turns it into an electronic “fingerprint.” This “fingerprint,” or coded message, is unique to both the document and the signer and binds them together.
•Digital signatures ensure the authenticity of the signer.
•Any changes made to the document after it has been signed invalidate the signature, thereby protecting against signature forgery and information tampering.
Is a digital signature legally enforceable?
•Yes. In 1999, the EU passed the “EU Directive for Electronic Signatures” and on June 30, 2000, President Clinton signed the Electronic Signatures in Global and National Commerce Act (“ESIGN”), which made signed electronic contracts and documents as legally binding as a paper-based contract. Today, digital signature (standard electronic signature) solutions carry recognized legal significance, enabling organizations to comply with regulations worldwide. 8
9. Business Case for Digital Signatures - Survey Compliance and Assumptions
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•Survey Monkey was utilized to create a survey to assess the business need and results were able to be compiled from 53 respondents
•Perficient-Life Sciences processes approximately 856 signatures for the 53
•Time to print, sign, scan, upload, and mail original document to headquarters for each signatory was estimated and calculated company-wide
•Time to execute a digital signature was estimated at 5 minutes per signature
•Anticipated time/resource savings is approximately 75% or 314 hours/month
Unaccounted for variables: signer’s location (for mailing), equipment limitations, cost of materials (e.g. paper, printer ink), and management of hard copies of documents
10. Business Case for Digital Signatures - Department Signatures Per Month
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12. Perficient-Life Sciences Requirementsfor a Digital Signature Solution
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•Support third-party Applications (Word, Excel, PDF)
•Allow for multiple signatures per document
•Allows for sectional signing (MS Word)
•Has audit trail and secured time stamps
•Allows for sequential and parallel signing workflow
•Receives instant alerts when someone signs
•Integrates with our EDMS (Alfresco)*
•Compliant with 21 CFR Part 11
•Integrates with Active Directory and requires username/password for signing
•Provides phone/email support
•System is easy and intuitive to use
•System has trial period
•System is available in the cloud**
* No solutions were able to integrate directly out-of-the-box with our Alfresco environment; hence, this requirement was adjusted to require the ability to integrate systems via a development API
** Later, we determined that having a system in the cloud introduced more risk than having a local installation of the solution basedoncontrol of the environment
13. Digital Signature SolutionsResearched and Reviewed
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DocuSign*
•Cloud-based only
•Cost determined on number of signatures executed
•Extensive full routing and signing certificates available
•Utilized in many other industries
•Several configuration options available
•Only signs PDF
•Adequate support available
•Electronic Signatures
•Full Web API for EDMS integration available
AssureSign*
•Client or cloud-based solution available
•Cost determined by number of signers
•Full routing available
•Uses templates for signing
•Only signs PDFs
•Adequate support available
•Digital Signatures
•Full Web API for EDM Integration available
Signadura*
•Least expensive solution
•Not fully translated to English
•Support was provided from Spain
•Only signs PDFs
•Digital Signatures
•Integrated with Alfresco
ARX CoSign*
•Client or cloud-based solution available
•Cost determined by number of signers
•Routing available when integrated with EDMS
•Signs PDFs, MS Word, or MS Excel documents
•Experienced with Life Sciences and 21 CFR Part 11 Compliance
•Cost was competitive with other solutions
•Adequate support available
•Digital Signatures
•Full Web API for EDMS integration available
Adobe EchoSign
•Most expensive solution available
•Ruled out based on existence of lower cost options
* Demonstration completed by vendor for solution
14. Digital Signature Solution – Selection of ARX CoSign
•ARX CoSignSelected
–Client based installation with installed, unconfiguredappliance provided by ARX
–Allows for signing of all types of documents
–Integration with SharePoint available and full Web Developers API available
–Provides for client software or signing via a web browser
–Allows prepping of documents for signature
–Adequate support available and provided
–Cost-effective solution that provides Perficient-Life Sciences employees/consultants with the ability to sign documents
–Opportunity for Perficient–Life Sciences to become an implementation expert for digital signature solutions for our clients
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18. Implementing and Validating the Digital Signature Solution
•Receive, install, and configure CoSign Appliance
•Install and configure CoSign Web Application (separate web server)
•Add CoSign User and Administrator Groups to Active Directory
•Determine how the system can be used for existing documents
–Updated signature block of document templates
–Meaning of signature added to signature block of document templates
•Prepare and execute full validation for the system:
–Validation Plan
–User Requirements Specification (URS)
–User Requirements to Performance Qualification Traceability Matrix
–Installation Qualification (IQ) Protocol
–Installation Log
–IQ Test Suite
–IQ Summary Report
–Performance Qualification (PQ) Protocol
–PQ Test Suite
–PQ Summary Report
–Validation Summary Report with Statement of Validation
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19. Implementing and Validating the Digital Signature Solution (continued)
•Create Supplemental Guidelines and Guides
–CoSignClient User Guideline
–CoSignWeb Application User Guideline
–CoSignAdministrator Guide
•Create New Application Roles
–CoSignSuper User Role
–CoSignUser Role
•Create Training Materials
–CoSignOverview
–Training on CoSignClient (video and presentation)
–Training on CoSignWeb Application (video and presentation)
•Update existing SOP-001 Controlled Documents procedure to allow for digital signatures
•Send letter of non-repudiation to FDA to inform them of our use of digital signatures
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20. Releasing the Digital Signature Solution
•Perficient-Life Sciences Support Representative trained on Tier 1 support
•Internal bug tracking system updated to accept issues/questions with the implementation of CoSign
•Controlled Document Required Training Notification sent
•Supplemental training provided as video, live session, and with presentations
•Rolling release implemented for users that have completed required training
•Installation support provided to those users that have completed training and require the CoSign Client
•Solution Released in August 2014
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21. Future Plans
•Use ARX CoSign MS Word “Sectional Signing” to allow completion of test cases electronically
•Create a connector between ARX CoSignand the Perficient-LS EDMS, Alfresco Community Edition
•Provide implementation and validation services for Life Sciences companies wishing to implement ARX CoSign
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