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William Gluck, PhD VP, DATATRAK Clinical and Consulting Services
April 11, 2013
Mitigating Risk in Clinical Studies
Confidential –
Introduction
William ‘Bill’ Gluck, Ph.D, DATATRAK International, Inc. @DATATRAKinc
Bill Gluck joined DATATRAK International in October 2010 as VP of DATATRAK’s Clinical and Consulting Services (DCCS). Dr. Gluck has more than 28 years of experience in the pharmaceutical and biotechnology industries and has diversified experience in clinical trial management
systems and electronic data capture.
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Confidential –
Agenda
• Risk in Clinical Studies – Definitions – Identifying Risk in Clinical Trials
• Study Set-Up and Initiation • Study Conduct and Optimization
• Leveraging Technology to Mitigate Risk • Thoughts on the Future – Virtual Trials – Technology Driven Drug Development (TD3™)
• Wrap-Up
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Confidential –
Risk in Clinical Studies
Risk1 A probability or threat of damage, injury, liability, loss, or any other negative occurrence that is caused by external or internal vulnerabilities, and that may be avoided through preemptive action Risk Mitigation2 A systematic reduction in the extent of exposure to a risk and/or the likelihood of its occurrence 1http://en.wikipedia.org/wiki/Risk
2http://www.businessdictionary.com/definition/risk-mitigation.html
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Confidential –
Identifying Risk In Clinical Studies
► Study Set-Up and Initiation • Study Protocol • Qualification, Training, Experience of all Study Personnel • Recruitment • Informed Consent
► Study Conduct and Optimization • Protocol Deviations (inclusive of eligibility criteria) • Drug Accountability • Data Collection and Data Quality
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Confidential –
Study Protocol
Risk • Study protocol is not well defined • Complex • Risk assessments and plans are not adequate • Amendments and Mid-Study Changes
Mitigation • Use of CDISC standards
– Protocol and Study/Trial Design Model • Adaptive study design planning • Risk-based Approach planning • Electronic Data Collection (EDC)
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Adaptive Study Design Study design that allows: • Modification of pre-defined aspects of a study • Interim reviews of accumulating study data • No affect on the validity and integrity of the trial
Adaptive design requires: • Multiple stages • Access to accumulated study data • Apply the following rules (one or more) at interim reviews:
– Allocation Rule – Sampling Rule – Stopping Rule – Decision Rule
At any interim data review subsequent stages of the study can be redesigned taking into account all available data
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Confidential –
Risk-Based Approach to Monitoring Draft guidance – released August 2011 ► FDA is clear that onsite visits are not always necessary and that
“centralized monitoring” may be preferred ► Factors to consider when developing any type of monitoring plan
• Complexity of study design • Types of study endpoints • Clinical complexity of study population • Geography • Relative experience of the clinical investigator and of the sponsor with the
investigator • Electronic data capture
– Metrics generation – Site quality assessments
• Relative safety of the investigational product • Stage of the study • Quantity of data
► Potential time and money savings as well as increased data quality
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Qualification, Training, Experience
Risk • Lack of experience • Lack of essential documentation/records • Medical records inadequately maintained
Mitigation • Clinical Trial Management System (CTMS) • Electronic Trial Master File (eTMF) • EDC and/or e-Training Records
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Recruitment
Risk • Identification of sites/patients • Delays in recruitment/enrollment
– Due to recruitment of qualified participants – Due to site issues/quality
Mitigation • Electronic Health Records • Social Media • EDC
– Patient data reviews – Metrics reporting
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Confidential –
Informed Consent
Risk • Patient confidentiality and protection • Adequately informed of study risks
Mitigation • Standardization • Use of multi-media • Electronic Informed Consent (virtual studies)
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Confidential –
Protocol Deviations
Risk • Inclusion/Exclusion criteria • Procedural deviations from the study protocol • Enforcement of stopping rules/dose modification rules
Mitigation • Electronic health records • EDC
– Risk-based Approach to monitoring – Edit check specifications – Metrics reporting
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Drug Accountability
Risk • Proper drug assignments • Site accountability • Dose management
Mitigation • EDC
– Randomization – Drug inventory management – Metrics reporting
• Electronic Reported Patient Outcomes (ePRO)
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Data Collection and Quality
Risk • Site issues
– Data quality – high query rates – Staff turn-over
• Patient diary data collection – incomplete data Mitigation • EDC
– Risk-based Approach to monitoring – Metrics reporting – eTraining
• ePRO
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Virtual Studies
Combines process and technology to streamline the conduct of a study leveraging:
Protocol definitions and process SOP’s Electronic informed consent eTraining eSource EDC - Metrics reporting - Data import/export
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Technology Driven Drug Development (TD3™)
Patient-focused to improve patient adherence and safety as well as clinical outcomes More than a virtual trial, TD3™ is a holistic approach that leverages technology-based processes:
Address study needs Evaluate viability of drug pipeline Reallocate focus and resources
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Confidential –
WRAP-UP
Mitigating risk depends upon the identification of risks and the proactive planning to address points of risk during the clinical study Technology provides multiple tools to assist in assessing and mitigating risk The future is now – virtual trials and TD3™
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Confidential –
William Gluck, Ph.D. VP, DATATRAK Clinical and Consulting Services
DATATRAK International, Inc. Phone: 919-651-0222 Cell: 919-522-9681
E-Mail: [email protected]