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PSDM 22 May 2008. Focused on Pulmonology and Hepatology SAE RECONCILIATION: Determining how much to reconcile. Jennifer Juntado, Sr. Manager, Data Management. Confidential. Property of InterMune, Inc. Any unauthorized review, use, disclosure or distribution is prohibited. Typical Data Flow.
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PSDM 22 May 2008 Focused on Pulmonology and Hepatology SAE RECONCILIATION: Determining how much to reconcile Jennifer Juntado, Sr. Manager, Data Management Confidential. Property of InterMune, Inc. Any unauthorized review, use, disclosure or distribution is prohibited.
Typical SAE Collection Period Patient withdraws from study early: SAE collection period ends at earlier of below two time points 1) Time of study withdrawal 2) 28 days after last dose of study treatment: Final Follow-up Visit: End of SAE collection period ICF Signed: SAEs only reported if related to protocol procedure Study drug initiated: All AE/SAEs reported per protocol
SAE/AE Collection Period Examples • Patient discontinues drug and the next day withdraws from study, but agrees to vital status: • Any SAEs occurring after the withdrawal date will not be collected • Patient discontinues drug and 35 days later withdraws from study: • Any SAE occurring after the 28th day following study drug discontinuation will not be collected • Patient permanently discontinues drug on 01 August 2007 and experiences an SAE on 12 Sept 2007: • SAEs are to be collected until the end of study (Final Follow-up Visit) • Patient experiences an SAE of Pneumonia on 01 June 2007 and discontinues study drug the same day. Patient then withdraws from study on 15 June 2007 with the pneumonia still ongoing: • Pneumonia will be followed to resolution by DSRM
Documentation • CRFs – Data Management • CRF Completion Guidelines – Clinical Operations • SAE Report Form – Drug Safety • SAE Reconciliation Plan – Drug Safety • Coding Guidelines – Data Management • Data Handling Report – Data Management • To document the evaluation and resulting action of data discrepancies between the Drug Safety serious adverse event (SAE) database and the Clinical adverse event (AE) database between database soft lock and hard lock • To document how “Handling Discrepancies between SAE and AE Databases” deviates from the study’s Serious Adverse Event Reconciliation Plan in the Data Management Plan.
Beyond SAEs: Other Data • Patient Disposition: • Termination of Study Treatment • Date of last study drug • Termination due to AEs (or Serious AE) or Reasons where it might be an AE • If an AE or SAE states that treatment was discontinued, then this data must correlate. • If early termination of study treatment is due to an AE (or Serious AE, if applicable), then the AE must be captured with consistent information. • Study Completion/Early Discontinuation from Study • Date of study discontinuation • Discontinuations due to AE (or Serious AE) or Reasons where it might be and AE • Mortality • Date of death • Primary cause of death
What other data points can remain discrepant, yet assuring our regulatory obligations and maximizing subject safety? 17