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An update on what happened…. Kevin Kane, PHASTAR kevink@phastar.co.uk. FDA / PhUSE CSS Initiative. FDA sponsored collaborative meeting with PhUSE and CDISC partners
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An update on what happened… Kevin Kane, PHASTAR kevink@phastar.co.uk
FDA / PhUSE CSS Initiative • FDA sponsored collaborative meeting with PhUSE and CDISC partners • "Update on Standards, Tools, Process Initiatives across Regulatory Review and Collaboration with Key Working Groups to Improve the Product Lifecycle" • FDA, industry, academia • “…to establish collaborative working groups” • “…current challenges related to access and review of data” • “…pursue possible solutions and practical implementations“
PhUSE and CDISC • PhUSE • Independent , not-for-profit organisation • Over 1600 volunteers • platform for creating and sharing tools and standards around data, statistical and reporting technologies • CDISC • global non-profit charitable organisation • 300 supporting member organisations • develop industry-wide data standards • harmonisation of clinical data and streamlining research processes from protocol though analysis and reporting
Six Working Groups • Data Validation and Quality Assessment • Standardising Data within the Inspection Site Selection Process • Challenges of Integrating and Converting Data across Studies • Standards Implementation Issues with the CDISC Data Models • Development of Standard Scripts for Analysis and Programming • Non-Clinical Road-map and Impacts on Implementation
Development of Standard Scripts for Analysis and Programming • Support the development of validated scripts for common data transformations and analyses for use in clinical research • Review environment to facilitate efficient efficacy and safety reviews • Develop technical requirements for a sharing platform • Share approaches for analysis of safety profiles.
Objectives • Develop a platform for sharing scripts • SAS, R, Stataetc • Leverage CDISC standards • Encourage ongoing improvement • Develop metadata standards • Identify core TFLs for safety signal detection • Analyses, summaries and data transformations • Process for managing, testing, publishing scripts • Define validation standards
Three subgroups • What scripts do we want/need? • Creation and validation of scripts • Platform for script management
Creation and validation of scripts • Define the process of creating a script • Define the process of validation • What “management” do we need? • How can we incentivise?
Script Creation • Once a script is loaded, the original author is stored as metadata but does not have any further rights or responsibilities • Basic set of programming standards would be useful. If they are too detailed, may conflict with individual organisations • We should develop standard templates for specifications and user guides etc • Investigate “V Model” further for development process • For minor changes, this should not be a separate script – should be added as an option • Encourage backward compatibility but not an absolute requirements
Metadata • Program name • Language • Program version (auto?) • Platform • Purpose • SDTM/ADaMversion/NA (dropbox) • Keywords • Original Author (auto) • Usage counts • Ratings/feedback • Validation status • Assumptions • Inputs • Outputs • Requirements • Comments/notes • Reason for change • Bug flag (DB table?) • Current author • Language version • Validation documentation
Definition of validated script • Script does what it says in specification • Specifications are required • Design • Inputs • Outputs • Test under various scenarios: these scenarios become assumptions • Code review • Validation by experience is not enough • Website/wiki needs a disclaimer • ISSUE: What documentation is required for unvalidated scripts
Process for scripts to be validated • Upload all validation documentation • Approval by moderator (committee?) • Meets all requirements on validation checklist Can we learn from SAS Online help web pages?
Script governance - functions • Approve scripts • Draft specs • Call for Scripts • Template specs • Guidelines • Validation checklist • Library management • Ratings management • Define metadata • Change management • Incentive management
Script governance – documentation required • Guidelines for creating specs • Define metadata • Overlap between specs and metadata • Web based database? • Template for user guide • Basic programming standards • Checklist for approval to validated state • Definition of requirements to consider a script validated
Issues to pass to platform group • Need to be able to review and comment on scripts. Ideally with quality rating • Create and store multiple versions • Need scripts to be able to have different states: e.g. validated; unvalidated; in development • Metadata e.g. program name; language; parameters; bug flag; variables; outcomes; version number (need to decide list of metadata variables) • Check-in check-out (not 100% defined- what happens if one person checks out for long time) • Ability to have multi-person multi-function teams • Can we have a metadata database on a Wiki
Incentives:Results from brainstorm • Maybe we don’t need any incentive • Encourage people to get a top rating leading to enhanced reputation • Platform records downloads – “most cited script” • Messages to “market”:- • Reputation factor • This system can save organisations money • This is the same code that the FDA will use • Could offer a PhUSE discount or award • FDA recommendation to use scripts • Airmiles/points system – bronze/silver/gold • Academic encouragement : get your methodology adopted • Confirm if we need any money. Ask PHARMA???
My key learnings • FDA statisticians are pretty normal • They’re happy with analyses in R • New FDA regulations:- • Draft Dec 2012; Final 12 months later • Electronic submissions required 24 mnths later • SDTM isn’t standard enough
What happens next? • Depends on volunteers • Get involved? • phusewiki.org • Join one of the subgroups (I can pass on details) • Slides from the meeting are on phuse.eu • Come to the PhUSE conference • Encourage your organisation to get involved with CDISC