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traditional on-site monitoring might be difficult for reasons such as (1) sites may not be able to accommodate monitoring visits (e.g., due to staffing limitations or site closures) or (2) monitors may not be able to travel to trial sites. When 38 See 21 CFR 312.32(b), 312.56(c), and 812.46. 39 See 21 CFR 312.50, 312.53(d), 312.56(a), 812.40, 812.43(d), and 812.46. Contains Nonbinding Recommendations 23 planned on-site monitoring visits are not possible, the reason should be documented and available for review by the sponsor and during FDA inspections. The sponsor should consider using a risk-based approach to prioritize sites for remote monitoring, including as many study sites as feasible (and with a frequency as close to that described in the site monitoring plan as feasible). The decision regarding which sites to prioritize for remote monitoring should be guided by centralized monitoring or other information available about site performance (e.g., frequency and severity of protocol deviations previously identified during monitoring visits or currently identified by centralized monitoring, number of randomized active trial participants, experience of site staff, known history of prior major audit or inspection findings). Remote monitoring should be focused on review of critical study site documentation and source data. If the materials identified for review include participants’ medical records that normally would be reviewed at the site (and such a review is consistent with the trial participants’ informed consent documents) then, as discussed below, remote review of medical records may be explored with trial sites to complete source document review. When the study monitor cannot access the site to review critical source documents, requests for review of source documents that may include private health information should be consistent with requirements for source document validation and review as described in the current study monitoring plan or other appropriate study-specific document. When remote monitoring processes and procedures have not previously been described by the sponsor, these processes and procedures should be established (e.g., in a revised study monitoring plan or in updates to existing sponsor policies and procedures). During remote monitoring, the study monitor should focus on trial activities that are essential to the safety of trial participants and/or data reliability. Sponsors and monitors may wish to consider one or more of the following options to facilitate remote monitoring access to clinical site records: • If the site can provide appropriate resources and technical capabilities, consider establishing a secure remote viewing portal that would permit site staff to provide access to the site’s study documentation and/or trial participants’ source documents for the study monitor’s review. In addition, the potential for remote access to trial participants’ electronic health records may be explored with trial sites. • Sites could upload certified copies40 of source records to a sponsor-controlled electronic system or other cloud-based repository that contains appropriate security controls. In the setting of a blinded or partially blinded study, if source documents contain potentially unblind information, controls to protect the study blind should be in place prior to transfer of source documents (e.g., use of an unblinded study monitor to review source documents, restricted access to folders containing copies of source documents). It is not necessary for the clinical site to have control of certified copies of source documents uploaded to such a 40 See footnote 26. Contains Nonbinding Recommendations 24 repository; however, the clinical investigator should maintain control of the original source records. Regarding retention of copies of source documents used for remote review, it would not be necessary to retain the certified copies of source documents used for remote review, provided the clinical investigator retains the original source documents according to FDA regulations for the retention of records. 41 In addition, processes and procedures should be established for the handling of source document copies that were placed in temporary storage locations for remote review and that are no longer needed after the remote monitoring has concluded. Remote monitoring activities, including remote review of source documents, should be documented in the same level of detail as on-site monitoring activities, and any resulting actions to address issues identified from the remote source document review should be consistent with procedures and processes described in the study monitoring plan. Q16. I am a sponsor of commercial INDs and electronic common technical document (eCTD) requirements cannot be met due to the COVID-19 public health emergency. Who do I contact for assistance? Commercial sponsors may qualify for a short-term waiver from the eCTD requirements under section 745A of the FD&C Act in unique and rare circumstances and for a limited duration. During the COVID-19 public health emergency, rare circumstances may arise in which a sponsor cannot meet eCTD requirements (e.g., if the current COVID-19 public health emergency has impacted computer operations). Companies experiencing technical difficulties with transmission of their electronic submissions to FDA should consult FDA’s 

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