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February 26, 2009
Ron Marks, Ph.D.Chief Scientific Officer
Clinipace
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Is this necessary?
Pharmaceutical Research and Manufacturers of America,Pharmaceutical Industry Profile 2008 (Washington, DC: PhRMA, March 2008).
RegulatoryAnalysisOperationsDesign
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
We already know
Thomson CenterWatch 2003, 2005 survey of sites in U.S.
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Take action
• Focus on your circle of influence Design it right Power it right Listen to the FDA Don’t rely too heavily on a CRO Create a transparent study
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Be design “intelligent”
• Prioritize your objectives & outcomes
• Seek 3rd party input early• Better manage randomization &
monitoring• Must consider number of
subjects and sites• Use “common sense”
Collect only what’s needed
What are you measuring – time to event vs. survival
Time to document efficacy is usually much shorter than determining safety
GCP allows for “appropriate” monitoring
Random sampling is appropriate for monitoring
ConsiderConsider
Most data collected is never used…Furthermore, some data are collected excessively or in an inefficient manner.[Dr. Gwendolyn Fyfe, senior staff scientist ,Genentech]
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Power it right
• Number of subjects needed to answer your primary objective
• Depends on type & variability of primary outcome
• Setting alpha (α) and beta (β)
I can tell within 15 minutes of reading a statistical plan if it will succeed.[Dr. Blair Keagy, UNC School of Medicine]
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Listen to the FDA
Objectives are not clear
Outcomes not well-defined or analyzed
Sample size not properly documented
Missing patients without explanation
Un-blinded analytic changes without explanation
SAEs that are dismissed without description as “inter-current illness”
Sloppiness; want most observations to be made by competent person and to be accurate
Red FlagsRed Flags• Get to know your review division
• Work with FDA to determine efficacy and safety criteria
• Seek guidance early and often
There is no prescribed monitoring frequency. [Robert J. Temple, M.D., Associate Director for Medical Policy, Center for Drug Evaluation and Research, FDA]
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Don’t over rely on a CRO
Performance metrics
Incentive mix
“Appropriateness” of monitoring plan
Relationship with sites
ConsiderConsider• Balance functional needs vs. complete outsourcing
• Maintain control• You’re the brains, hire for muscle• Expect transparency from your
partners• Demand the use of technology
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Create transparency
• Manage towards performance metrics
• Accountability• No excuses• Maintains study
schedule• Allows future planning
www.clinipace.com© 2003-2009 Clinipace, Inc. All Rights Reserved.
Do it now!
• Plan your study thoroughly – think “intelligent design”
• Listen to the FDA• Maintain control of your study• Maintain study schedule through
transparency and comprehensive reporting• Invest in technology-driven processes