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Clinical Trials and Safety Data – Different View of the same Reality Uwe Trinks, Ph.D. PRISM Forum, San Diego. Goal: Profile Drug for Use Longitudinal Data Collection Patient and Visit driven Large Part of Analysis after LPLV Mostly placebo-controlled, blinded
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Clinical Trials and Safety Data –Different View of the same Reality Uwe Trinks, Ph.D.PRISM Forum, San Diego
Goal: Profile Drug for Use Longitudinal Data Collection Patient and Visit driven Large Part of Analysis after LPLV Mostly placebo-controlled, blinded Combined with other studies and analyzed No expedited reporting No annual reporting Data reported at the end of product development in a CTD as CDISC SDTM dataset Goal: Prevent Harm Situative Data Collection Event driven Immediate Follow up and Analysis Mostly unblinded data Expedited Reporting Annual Reporting Reporting to Ethics Committees and Investigators Reports on paper or as ICH E2BM dataset Clinical Data Management vs. Clinical Safety
Safety Efficacy Efficacy vs. Safety
Come on! It can‘t go wrong every time... Looking for the Outlayer
Visits Data A Study Patient Recruitment Randomization DB Lock FPFV LPLV Unblinding Data Cleaning Reconciliation Data Pooling Analysis Documentation Data Cleaning, QC, Data Management Reconciliation SAE SAE SAE SAE SAE
The old clinical trials paradigm SAE CRF Study Sites CTMS CTS Safety Reconciliation
The brave new world of EDC Study Sites EDC EDC EDC EDC EDC EDC CTMS CTS Safety
SDTM Clinical Domains by Class Interventions Events Findings Other Exposure AE Labs InclExcl Demog ConMeds Disposition Vitals SubjChar RELREC SuppQual SubstUse MedHist PhysExam ECG Comments Trial Design QS Other Domains most relevant to safety review
ICH ICSR DTD-XML • Message Header • M.1. Message Identifier • Type, Format, Version, Number, Sender ID, Receiver ID, Date • Case Admin Data • A.1. Identification of the case safety report • A.2. Primary source(s) of information • A.3. Information on the sender and receiver of the case safety report • Case Information • B.1. Patient Characteristics • B.2. Reaction(s)/Event(s) • B.3. Results of tests and procedures relevant to the investigation • B.4. Drug(s) information • B.5. Narrative Case Summary and further information
B4 B4 B3 B3 B2 B1 B4 SDTM Clinical Domains by Class Interventions Events Findings Other Exposure AE Labs InclExcl Demog ConMeds Disposition Vitals SubjChar RELREC SuppQual Subst Use MedHist PhysExam ECG Comments Trial Design QS Other Domains most relevant to safety review
The ideal Process Dictionaries Codelists Studies Query Trigger Inform Argus Safety E2B Plus file Argus Interchange SAE form Diff Report
The Problem • Trigger Points • EDC data collection is continuous • Study Sites update information almost daily • Mostly without thinking about SAE • Most prominent updates: Death Dates • Safety Collection is a “Snapshot” • What fields and when should trigger a follow up • Avoid having up to 40 FU reports • Which labs and vital signs to transfer? • Update of non-significant information? • Feedback Loop • EDC System must mark transferred data as such • Requires redesign of SAE form and SAE process • Requires standardization of certain form design elements
The Problem • CDISC SDTM to E2BM Conversion difficult • Field inconsistencies • Need to create a mapping routine (ETL tool) • Easier to create the E2B file directly • E2B Intake • Incomplete E2B form • Requires separate profile and DTD • Need E2B difference report • Harmonize Configuration • Need to be able to automatically find Study Information in Argus • Population of Suspect Drug etc. from Safety System not from EDC System • Requires quick configuration of Studies
Coding Medical Semantics Vary widely Are usually not harmonized between Safety and Clinical Coding in Safety is Real-time Most current MedDRA version Important for Reporting Coding in Clinical is Harmonized at the end Used only for Analysis Two Possibilities Harmonize Coding Strategies or Only transport Verbatim
Major Changes in Inform Standardized SAE form Zero deviation allowed Additional fields for Lab Data Vital Signs Event Assessments Dechallenge/Rechallenge Selection Tables for Data that are uploaded by relevance Concomitant medications Medical History Vital Signs Patient Demographics Treatments
Major Changes in Inform Pop ups in other Inform Sections “Is this an SAE/Update to SAE?” Need to be “cloned” for EVERY database Death Date Cause of Death Relatedness -> Update SAE form Other Seriousness Criteria Change in Relatedness Change in Drug Exposure Dechallenge/Rechallenge Pregnancy System Down: Fax to Safety, but enter into EDC System
Major Changes in Inform Standardized SAE Query form Assure that answers end up in SAE form Lab Data Integration difficult Standardized and harmonized Codelists Biggest source of errors Need full alignment of CRF writers Can probably build an E2B check into Inform Trigger Mechanism Difficult balance between Regulatory Requirements Operational Efficiency Basic rule: No more than one FU per day Scheduled upload of non significant information
Major Changes in Argus Study Information Needs to be configured before FPFV Needs to be harmonized with Clinical E2B Import Module Needs to be configured for partial E2B files Added non E2B fields Sequence numbers Event Assessments Configure for Always Accept Configure to not overwrite certain fields (e.g unblinded product information) Configure not to upload certain events (e.g entry criteria) No changes to Argus SAEs Except Narrative and Unblinding All Changes/Queries through EDC System
Communication Most difficult task Lots of Clinical and IT lingo needs to be translated into Safety Lingo Lots of Safety lingo needs to be translated into Clinical and IT Lingo Very few people are bi- or tri-lingual
E2B Transport Non native DTD Partial E2B form Header of non-standard format No study product information Only Study # information No Narrative Information Added fields Sequence numbers Event Assessments/Causality Non overwrite information No real acknowledgement Send Argus Case number back to Inform for sequencing and FU
The good news It works very well at some companies GSK Technical problems are mostly solvable It saves time and money once it works
The bad news It takes an effort to harmonize things SAE forms Codelists Dictionaries and Coding Conventions It takes a while to train people Safety to use Inform for Queries and Updates Investigators to “think safety” It requires adherence to agreed standards The “extra codelist item” will break the process Safety has to conform with not updating data in Argus Savings will happen late in the process Once the majority of the studies is in Inform and using the standard SAE process Can’t change studies midway