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Duringdata reconciliationbetween a central laboratory and CRF data, the source of truth is typically thecentral lab database, as it provides directly measured, vendor-generated results.

When thecentral lab has data but the CRF does not (option C), the Data Manager must first query thecentral labto confirm that the result was transmitted correctly, since discrepancies may stem from data processing or timing issues. Once confirmed, a secondary query may be issued to the site to ensure CRF completion and alignment.

Conversely, if the CRF contains data but the central lab is missing results (option B), the issue is site-level, not vendor-level.

According to theGCDMP (Chapter: External Data Transfers and Reconciliation),priority for querying depends on the authoritative source— for lab data, thecentral labis considered the source of record.

Therefore,option Cis correct.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: External Data Transfers and Reconciliation, Section 6.1 – Reconciliation of Central Lab and CRF Data

ICH E6(R2) GCP, Section 5.5.3 – Source Data Verification and Vendor Reconciliation

FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations, Section 6.4 – Data Reconciliation and Traceability

According to theGood Clinical Data Management Practices (GCDMP), thedatabase lock (DBL)process signifies the formal closure of the clinical trial database, ensuring that no further changes can be made to the data before statistical analysis. This process must be documented, controlled, and approved by key study stakeholders to ensuredata accuracy, completeness, and readiness for analysis.

The GCDMP specifies that database lock should occur only after all data cleaning, discrepancy resolution, and reconciliation activities are complete. The lock authorization typically requires the approval of theClinical/Scientific Representative (to confirm clinical completeness), the Data Manager (to confirm data integrity and query closure), and the Biostatistician (to confirm readiness for statistical analysis).

This tri-party approval ensures that the database reflects final, verified data consistent with the clinical protocol, and that the statistical analysis dataset derived from the database is accurate and auditable. The approval process is documented via aDatabase Lock Authorization Form or Sign-off Log, which becomes part of the permanent trial master file (TMF).

Reference (CCDM-Verified Sources):

SCDM Good Clinical Data Management Practices (GCDMP), Chapter: Database Lock and Archiving, Section 7.1 – Lock Procedures and Approvals

ICH E6 (R2) GCP, Section 5.5.3 – Data Handling and Record Keeping

FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations – Section on Database Closure

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

The described process isBlind Verification, also known asdouble data entry with blind verification. In this method, two independent operators enter the same data. The second operator isblindedto the first entry to avoid bias. When discrepancies arise, the system flags them for review, and the second entry (or an adjudicated value) is retained as the correct one.

According toGCDMP (Chapter: Data Entry and Data Tracking), blind double data entry is used primarily inpaper-based studiesto minimize transcription errors and ensure data accuracy.

Single entry (D):Only one operator enters data.

Manual review (B):Involves post-entry checking, not during entry.

Third-party compare (C):Used for reconciling external data sources, not CRF data.

Hence,option A (Blind verification)is the correct and CCDM-defined process.

Reference (CCDM-Verified Sources):

SCDM GCDMP, Chapter: Data Entry and Data Tracking, Section 5.1 – Double Data Entry and Verification Methods

ICH E6(R2) GCP, Section 5.5.3 – Data Entry and Verification Controls

FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations, Section 6.2 – Data Accuracy and Verification

If a clinical site continues to provideinconsistent or illogical dataafter multiple queries, the correct course of action is toescalate the issue to the appropriate site contact personnel, typically theClinical Research Associate (CRA)orSite Monitor.

According to theGood Clinical Data Management Practices (GCDMP), persistent data discrepancies often indicate a misunderstanding of the protocol, CRF instructions, or data entry procedures at the site level. Repeatedly re-querying the same data without escalation wastes time and risks introducing bias or error. By escalating through formal communication channels, the issue can be clarified through re-training, documentation review, or site monitoring visits.

The GCDMP emphasizes that escalation ensuresdata accuracy, site accountability, and protocol adherence, maintaining both data quality and regulatory compliance. Data managers must document the escalation process in the Data Management Plan (DMP) and ensure proper follow-up resolution is achieved.

Reference (CCDM-Verified Sources):

SCDM Good Clinical Data Management Practices (GCDMP), Chapter: Communication and Issue Escalation, Section 4.2 – Handling Persistent Data Discrepancies

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

FDA Guidance for Industry: Oversight of Clinical Investigations – Risk-Based Monitoring, Section on Issue Escalation