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Session 2 Expanded Clinical Trials Registry Deborah A. Zarin, M.D. NLM Accomplishments Impact to Date Specific Data Element Issues. Pilot Quality Control Project Recommendation to Secretary – Narrative Summaries. Expanded Clinical Trial Registry. REGISTRY. New Administration
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Session 2Expanded Clinical Trials RegistryDeborah A. Zarin, M.D. NLM Accomplishments Impact to Date Specific Data Element Issues
Pilot Quality Control Project • Recommendation to Secretary – Narrative Summaries Expanded Clinical Trial Registry REGISTRY New Administration Transition Phase Public Meeting 9/27/07 12/26/07 9/27/08 3/27/09 9/27/10 90 d 1 yr 18 m 2 yr 3 yr Enactment Expansion by Rulemaking: Final Rule Additional Adverse Events Data RESULTS Launch Basic Results Database Linking to existing results information at FDA and NIH
Accomplishments To Date • ClinicalTrials.gov registration system (PRS) modified to enable compliance with expanded registration requirements (11/27/07) • Links established from registry to NIH/NLM and FDA results information • Information developed for affected communities • NLM Data Element Definitions and Fact Sheet • NIH Guide Notices (2) and FAQs – including instructions for initial NIH grantee/contractor compliance
Enforceability of Data Elements • Need to collect information not explicitly listed in the law • More detail required than specified in law (e.g., “study design”) • Additional information necessary to comply with law (e.g, data required to implement search requirements) • Competing concerns • Congressional intent to establish registry quickly • Difficulty of enforcing all necessary data elements without regulation • HHS is considering rulemaking
Revisions to Registry • “Data providers” are alerted to items that (may be) required by the FDAAA • Omission of these items does not block acceptance of the record, and an NCT # is assigned • Items in question include those with some complexity, those that are required to implement the law, and one that reflects NIH policy • HHS is considering rulemaking
New Records: 2007 vs. 2006 ~45% New Accounts: 2007vs. 2006 Sept Oct Nov Dec
Enhanced Registry Activity (12/1/07-1/20/08) • NewStudy Submissions: 2,932 • 419 records/week • UpdatedStudies: 10,558 • 1,508 records/week • Overall Studies: 13,490 • 1,927 records/week; 100% increase • New PRS Accounts: 252 • 36/week; 64% increase • Current Backlog: ~600 records (~10 days)
Overall Characteristics: New Studies (12/1/07-1/20/08) Total 2,932 (100%) Type of Trial* Observational 628 (22%) Interventional 2,281 (78%) - Drug, Biologic 1,492 - Behavioral, Gene Transfer, Other 479 - Medical Procedure 290 - Device 227 (+27 delayed posting) * 23 records missing “Study Types” information
Overall Characteristics: New Studies (12/1/07-1/20/08) Total – Interventional Studies 2,281 (100%) Studies by Registrant Type University, Other 1,397 (61%) Industry 645 (28%) US Federal (including NIH) 239 (11%) Studies by Facility Location US sites only 1,436 (63%) Non-US only 569 (25%) US & non-US mixed 73 ( 3%) Missing 203 ( 9%)
Overall Characteristics: Updated Studies(12/1/07-1/20/08) Total 10,558 (100%) Type of Trial* Observational 1,019 (10%) Interventional 9,535 (90%) - Drug, Biologic 8,080 - Behavioral, Gene Transfer, Other 776 - Medical Procedure 4,282 - Device 329 *4 records missing “Study Types” information
Overall Characteristics: Updated Studies(12/1/07-1/20/08) Total – Interventional Studies 9,535 (100%) Studies by Registrant Type University, Other 1,947 (21%) Industry 2,997 (31%) US Federal (including NIH) 4,591 (48%) Studies by Facility Location US sites only 5,746 (60%) Non-US only 2,006 (21%) US & non-US mixed 1,158 (12%) Missing 625 ( 7%)
Delayed Posting of Device Trial Registrations • Law appears to prohibit public posting of trials of devices that have not been approved/cleared by FDA –even whendesired by registrant • Would therefore: • Require removal from current database of some device trials voluntarily posted prior to passage of law • Preclude use of ClinicalTrials.gov for recruitment • Preclude use of ClinicalTrials.gov to comply with registration policy of journal editors (ICMJE) • Limit transparency of such trials funded by NIH or other gov’t agencies • Complaints received from some companies; some registrants are omitting approval/clearance status of devices to circumvent • HHS is studying possible options
Device Studies:Delayed Posting • Must answer “yes” to following: Indicate whether this is an unapproved or uncleared device trial for which posting to ClinicalTrials.gov should be delayed in accordance with US Public Law 110-85, Title VIII, Section 801. • 32 studies in “lock box” as of 2/7/08
Delayed Posting General Characteristics Total: 32 studies (as of 2/7/08) Provider Type 27 Industry 5 Other Study Type 27 Interventional 4 Expanded Access 1 Observational
Analysis of Response:OVERALL Data Completion Statistics forOverallActive Phase II-IV Drug/Device Interventional Trials Submitted(12/1/07 - 1/20/08)
Top Device Companies * Source: Not so Lonely at the Top. Medical Product Outsourcing (MPO), July/August 2007 **All device interventional and observational studies registered at ClinicalTrials.gov as of 2/4/08 ***Active, phase II-IV device interventional trials ****Includes: BiosenseWebster, ConorMedsystems, Cordis, Dupuy*, Ensure, Ethicon*, LifeScan, Visioncareinc
Top Pharmaceutical Companies * Source: Top 10 Companies by U.S. Sales. IMS Health, IMS National Sales Perspective.3/2007 ** All interventional and observational studies registered at ClinicalTrials.gov as of 2/4/08 *** Active, phase II-IV drug/biologic interventional trials
Specific Data Element Issues Public Law 110-85, Section 801 PL 110-85 Implementation NIH Policy
Evolution of Data Elements • ClinicalTrials.gov has included data elements necessary to accommodate many policies • FDAMA • ICMJE • Specific wording and structure of data elements has evolved with experience • FDAAA has incorporated previously optional ICMJE data elements—usually identified by overall title (without details)
NIH Policy – “Board Approval” • Submitted studies should have approval from a human subjects review board prior to the recruitment of the first patient • Studies may be registered prior to board approval, if status is “Not yet recruiting” • Data Elements • Board Approval Status (e.g., “Submitted, exempt”) • Board Name • Board Affiliation • Board Contact
Interventional “Study Design” • Each of the following elements is required • Intervention Model – intervention assignments (e.g., parallel arms) • Number of Arms – number of comparative groups • Masking – knowledge of intervention assignments (e.g., double blind) • Allocation – participant assignment to intervention arm (e.g., randomized) • Sources: ICH E3, 21 CFR 314.126
“Intervention Name” • Provides sufficiently detailed description of the intervention(s) and to link intervention(s) to arm(s) • Data Elements • Intervention Name: generic name for drugs; for others, sufficient detail to distinguish from similar interventions (e.g., devices) • Intervention Description: e.g., dosage • Arm Name or Label: way to identify arm • Arm Type: e.g., experimental, active comparator • Arm Description: if different from intervention description
“Outcome Measure” • Specific measurement that will be used to measure the effect of experimental variables in a study • Requires the following • Outcome Measure: Description of the specific measure • Outcome Time Frame: Time point(s) at which outcome measure is assessed • [Safety Issue? (yes/no)]
PL 110-85 Implementation • Safety Issue? – “the safety issue, if any, being studied in the clinical trial as a primary or secondary outcome” • Facility Contact – location information (e.g., city, state, country) to be able to search by “location of the clinical trial” • Applicable Clinical Trial? • FDA Regulated Intervention? (Yes/No) • Section 801 Clinical Trial? (Yes/No) • Delayed Posting? (Yes/No)
Other Questions to Address • Cut-off for modifying registry records? • Estimated completion date • Outcome measures • Target enrollment • Good enough outcome measure? • How should changes be displayed?