Pragmatic Clinical Trials for Regulatory Decisions

Similar documents
Issues in Clinical Trial Designs for Devices

May 21, Moderator: Rachael Fleurence, PhD NESTcc Executive Director

The Use of Real-World Evidence to Support Regulatory Decision-Making for Medical Devices

Framework for FDA s Real-World Evidence Program

Use of Real-World Evidence to Support Regulatory Decision-Making for Medical Devices

Regulatory Pathways. Devices vs. Drugs Are there roles for registries? John Laschinger, MD CDRH/ODE/DCD/SHDB

Clinical Trials and Investigational Device Exemptions

DEVELOPING CLINICAL TRIALS INFRASTRUCTURE

Scott Gottlieb, MD Commissioner of Food and Drugs Food and Drug Administration New Hampshire Avenue Silver Spring, MD 20993

FDA s Center for Devices and Radiological Health: Strategic Priorities for 2017 and Beyond

Human Subjects Research Policy Update. Naomi Coll Director of Research Policy and Compliance

Current Trends at FDA: Implications for Data Requirements

Large, Simple Trials Policy Needs: Ethics, Trial Processes

Summary of Provisions in 21 st Century Cures Act (H.R. 6) as passed by full House of Representatives, July 10, 2015

May 9, Meeting Summary. Facilitating Antibacterial Drug Development

CRNs as Foundational Blocks of the National Evaluation System for Medical Devices: A Call to Action

Clinical Research and Adjudication

COOPERATIVE RESEARCH AND EXTERNAL INVESTIGATORS

PRAGMATIC TRIALS AND THE LEARNING HEALTHCARE SYSTEM

Human Research Protection Program Guidance for Human Research Determination

Protection of Research Participants: The IRB Process and the Winds of Change

Opportunities for Large Simple Trials An FDA Perspective

What s New in GCP? FDA Clarifies, Expands Safety Reporting Guidance

Product Quality Outcomes Analytics Update

UT SOUTHWESTERN MEDICAL CENTER AT DALLAS INSTITUTIONAL REVIEW BOARD. Emergency Use of an Investigational Drug, Biologic or Device

Objectives Discuss the importance of proper data collection. Identify the types of data collected for clinical trials. List potential source documents

What is New on the Regulatory Front?

Nuts & Bolts of Clinical Trials, DSMBs, Event Committees, Core Labs and Data Standards

Real World Evidence Generation in the 21 st Century: National Evaluation System for health Technology (NEST)

1.4 Applicable Regulatory Requirement(s) Any law(s) and regulation(s) addressing the conduct of clinical trials of investigational products.

Draft Guidance for Industry Development and Use of Risk Minimization Action Plans

3.1. Overall Principal Investigator (PI), who holds the IND and is the Sponsor.

2.0 DETERMINING ACTIVITIES THAT QUALIFY as HUMAN RESEARCH or CLINICAL INVESTIGATIONS

3.1. Overall Principal Investigator (PI), who holds the IND and is the Sponsor.

SWOG

Advocate Health Care Network. Human Research Protection Program. Plan

Expanded Access and the Individual Patient IND

Current Issues in Device Development and Approval An Academic Perspec7ve

MCW Office of Research Standard Operating Procedure

Clinical Trials Management for Molecular Diagnostics. April 2016

Title: Review of Medical Devices Page: 1 of 5 Written by:

Data Quality in the Real World: Ensuring Integrity across the Medical Device Lifecycle

The Revised Common Rule. Ann Johnson, PhD, MPH IRB Director University of Utah

Short Course: Adaptive Clinical Trials

SUBJECT: INSTITUTIONAL REVIEW BOARD (IRB) - HUMANITARIAN USE DEVICES

Docket #: FDA-2018-D-3268

Implications for Investigator Initiated Trials (IITs)- Risk Based Approaches in Managing Clinical Trials

1201 Maryland Avenue SW, Suite 900, Washington, DC ,

Ethics of pragmatic trials: Considerations for informed consent

A Coordinated Registry Network Based on the Vascular Quality Initiative: VISION. Vascular Implant Surveillance & Interventional Outcomes Network

Standard Operating Procedures Guidelines for Good Clinical Practice

FDA Decisions for Investigational Device Exemption (IDE) Clinical Investigations

Re: Docket No. FDA-2015-D-4562: Draft Guidance Safety Assessment for IND Safety Reporting

Risk-Based Monitoring: How Can It Be Implemented For More Effective Study Oversight

Guidance for Sponsors, Institutional Review Boards, Clinical Investigators and FDA Staff

PHARMA CONGRESS. Pharmacovigilance and Drug Safety: Assessing Future Regulatory and Compliance Developments. October 28, 2008

Eileen Navarro MD, FACP Medical Officer, OCS, OTS, CDER, FDA

MANUAL: Administrative Policy & Procedure Manual POLICY:

October 25, Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Room 1061 Rockville, MD 20852

Session 4: Statistical considerations in confirmatory clinical trials II

US Regulatory and Marketing Barriers for Medical Devices

External IRB Review What Does it Mean for Your Institution

The Role of the IRB in Clinical Trials: What Patients and Families Need to Know. Marjorie A. Speers, Ph.D. Executive Director, WCG Foundation

Regulatory Science: FDA Paths Forward With Real World Evidence Mitchell W. Krucoff, MD, FACC

University of California, Irvine Human Research Protections Standard Operating Policies and Procedures

A Path from RWD to RWE Stopping Over at Statistical Inference

DEPARTMENT OF HEALTH & HUMAN SERVICES

Title: IRB Purpose, Principles and Responsibilities Page: 1 of 5

Outline of Discussion

Field trial with veterinary vaccine

Overview of FDA s Sentinel Initiative

Introduction. Summary A LOOK AT CFTR MODULATORS FOR CYSTIC FIBROSIS JUNE 2018 TREATMENT OPTIONS CYSTIC FIBROSIS POLICY IMPLICATIONS

Office for Human Subject Protection. University of Rochester

Tailoring best practices for the evaluation of endpoints in clinical device trials

Ethical Principles in Clinical Research. Disclaimer. Christine Grady Department of Bioethics NIH Clinical Center

Value Assessment: Building Payercentric value propositions to inform decision-making

Investigator s Handbook

Ethical Principles in Clinical Research

Formalizing Study Design & Writing Your Protocol. Manish A. Shah, MD Weill Cornell Medicine Center for Advanced Digestive Care

FRAMEWORK OF CHARACTERISTICS OF A QUALIFIED SITE TEAM: How Does Yours Measure Up?

Regulatory Documentation and Submissions for C2012 Clinical Trials DCP SOP #1

The Right Data for the Right Questions:

A Primer on Clinical Trials Issues

FDA Drug Approval Process Vicki Seyfert-Margolis, Ph.D.

Research: An Essential Component of a Comprehensive MS Center

Good Clinical Practice. Martin Rose, MD, JD February 8, 2018 ASQ

What s New in GCP? FDA Draft Guidance Details FIH Multiple Cohort Trials

Facilitating Antibacterial Drug Development: Bayesian vs Frequentist Methods

1.0 Abstract. Palivizumab P Study Results Final

Human Research Protection Program Policy

Human Research Protection Program Policy

Investigational New Devices

FDA Perspective on Data Quality Rachel E. Sherman, MD, MPH Associate Director for Medical Policy Center for Drug Evaluation and Research

EIGHT BASIC ELEMENTS OF INFORMED CONSENT

This document provides guidelines for unblinding participants enrolled in IMPAACT clinical trials.

11.0 FDA-Regulated Research Research Involving Investigational Drugs and Biologics

Bios 6648: Design & conduct of clinical research

Compassionate Use Navigator Information for Physicians

I. Purpose. II. Definitions. Last Approval Date

CDRH s Inspection Strategy for 2018: How it Will Impact Your Company

Transcription:

Pragmatic Clinical Trials for Regulatory Decisions Jacqueline Corrigan-Curay, MD JD Office of Medical Policy Center for Drug Evaluation and Research FDA May 16, 2018

Pragmatic Clinical Trials Pragmatic in reference to trials means many things to many people Broadly, refers to an attempt to make the result of the trial applicable to a broad real population Pragmatism is a range of characteristic with many different domains It is not a single design An important question is whether some or all of these flexibilities will work for regulatory questions 2

Keep it Simple Put another way, considering both applicability and simplification of trials Can we integrate research into clinical practice Enroll a more diverse population Potentially increase efficiency and lower costs through use of clinical data already being collected Understand how products work when administered as part of clinical practice AND Provide substantial evidence for a labeling claim 3

There is a Model to Build on 4

The Opportunity and Challenge 5

Potential Components for RCTs in real world clinical practice settings for label expansion Primary hypothesis well-defined, relevant to participating HCPs: consistent with non-placebo controlled non-blinded design When is lack of blinding unlikely to impact the results? Approved medication, widely available, and therapeutic alternatives being studied acceptable to practices and to patients Intervention studied fits within healthcare system; practice visit frequency adequate to data collection and monitoring Can this be integrated into the work flow Straightforward dosing and administration Study enrollment criteria easily applied and appropriately defines target patients Study Design Elements 6

Potential Components for RCTs in real world clinical practice settings for label expansion Primary endpoint and other key clinical outcomes easily ascertained from practice (ehr) and/or claims datasets (can consider embedded ecrf) Can the physician/investigator reliably capture the endpoint of interest? Will there be challenges with measuring disease progression/changes versus more objective measures, labs, imaging? Can mobile technologies be leveraged to fill in the gaps? Network captures all outcomes drug dispensing, ER visits hospitalization, death, PCP or specialist care interactions--limited patient movement out of system How much missing data is acceptable? Will we know it is unknown? Data accuracy and completeness 7

Potential Components for RCTs in real world clinical practice settings for label expansion Streamlined AE reporting acceptable (e.g., reporting only serious events, use of reporting waivers, routine practice setting safety monitoring appropriate) FDA Guidance Determining the extent of Safety Data Collection Needed in Late-Stage Premarket and Postapproval Clinical Investigations Central site monitoring appropriate with more + limited on-site monitoring / risk-based monitoring Study Monitoring 8

The question matters Is Drug A equivalent to Drug B? What is the non-inferiority margin in the real world setting? Can one be confidence that treatment variability, compliance and missing data do not drive the result? 9

Statistical considerations Does the actual adherence or lack of adherence in clinical practice warrant different statistical approaches? o Per-protocol analyses - The validity of per-protocol analyses depends not only on the choice of the appropriate method but also on: an explicit definition of the per-protocol effect, an a priori specification of the statistical plan, and the collection of high-quality data on adherence and prognostic factors. 10

Considerations for the Clinician/Investigator Will clinicians agree to be Investigators under FDA regulations? Sub-investigators? VA HCTZ/Chlorthalidone Study: study functions were established such that no personnel at VA medical centers from which patients are enrolled are considered engaged in research. This consideration was facilitated by our decision to obtain consent from primary care clinicians to serve as study participants What roles aside from clinical care will practitioners be willing to undertake? e.g. AE reporting Will there be any ethical concerns raised by a blurring of the investigator/clinician roles? 11

Putting it All Together Identification of relevant questions for practitioners and patients Selection of an intervention that can be appropriately delivered in a clinical setting Normalization of the integration of clinical practice/research Integration of clinical data across health care systems, with appropriate patient protections to maximize data capture Potential use of mobile technologies to fill in the gaps, e.g. to capture patient reported outcomes Many trials can have pragmatic elements while maintaining rigorous standards for data collection and assessment 12

Thank You 13

Acknowledgements Khair ElZarrad Dianne Paraoan Peter Stein Bob Temple 14

The Use of Real-World Evidence to Support Regulatory Decision-Making for Medical Devices Owen Faris, Ph.D. Director, Clinical Trials Program Office of Device Evaluation Center for Devices and Radiological Health Food and Drug Administration

Context for RWE Guidance 2016-2017 CDRH Strategic Priorities National Evaluation System for health Technology (NEST) FDARA (including MDUFA IV) commitment to use of real-world evidence to support device pre/postmarket decisions Guidance issued to clarify how RWE may be used to support regulatory decisions. Issued August 31, 2017 16

Devices Are Different from Drugs Many devices are highly dependent on clinician knowledge, experience, and skill Devices and techniques iteratively and rapidly improve (sometimes even during a trial) Gold-standard RCT often not practical = 17

What are the opportunities? Flexibility Can t always get what you want. But if we are flexible, we can get what we need Innovation Modeling Adaptive designs Real-world evidence Collaborations NEST Industry groups Patient and clinician groups www.fda.gov 18

Clinical Trial Innovation 19

Evidence in Regulatory Decisions Traditional Regulatory Pathway Pre-Clinical Testing Clinical Studies Pre-Market Application Post-Market Hypothesis Generation Device Innovation Informed Clinical Decision Making Claims Databases Laboratory Tests Pharmacy Data Patient Experience Social Media Healthcare Information Registries Electronic Health Records Hospital Visits Real-World Device Use Physician and Patient Experience Non-Traditional Clinical Data Generation 20

Data Quality Fit for Purpose Data should be assessed for completeness, consistency, accuracy, and whether it contains all critical data elements needed to evaluate a medical device and its claims. Relevant & Reliable Benefit Risk 21

Some Regulatory Uses for RWE Control arm for pivotal clinical study New indications for approved devices Studying new improvements to devices Replacing post approval study Adverse event reporting Shifts to prepostmarket balance 22

National Evaluation System for health Technologies (NEST) NEST Industry Patient Groups Clinician Groups NESTcc Hospital Systems Payers CDRH www.fda.gov 23

Cardiac Device Coordinated Registry Network CDCRN To provide uniquely reliable prospective clinical and regulatory evidence about the effects of studied treatments on important outcomes over long periods of time To allow access to data for all stakeholders that will promote appropriate regulatory approval and clinical application of medical devices for therapeutic interventions Do it in a way that provides flexibility and affordability Laschinger JC 24

CDCRN A Reusable Infrastructure for Clinical and Regulatory Evidence Generation * Identifiable Personal Information; + Unique Device Identifier # CDCRN Results In: NO CHANGE to current governance or business models of any registry NO DISRUPTION of current clinical uses or utility of registries to end users Positions Academic Societies & Registries at the center of the clinical trial enterprise CDCRN Allows: Prospective collection of uniform trial/rx data Programmed passive longitudinal data and evidence acquisition Production of Dynamic CLINICAL/REGULATORY evidence over TPLC Laschinger JC # Continue to operate independently to fulfill their current individually designed, essential and sustainable missions 25

Longitudinal Data Generation & Acquisition Important Hard Outcomes Continuously Tracked Over Time Index Procedure Passive Follow-up: Acquisition of Normally Generated Longitudinal Data *Success = alive with well functioning device and no life altering cx, re-intervention or re-hospitalization Administrative Records Event Generated Government/Payer Datasets* Laschinger JC Registry Records: Procedure Generated Reoperation Reintervention New Intervention or Surgery Longitudinal data acquired Yearly or as RDCF # Entered Longitudinal data acquired Yearly (e.g. anniversary date of index procedure) *pre-specified ICD-10 Codes # RDCF = Registry Data Collection Form + Life altering complications = effecting long term outcomes/qol e.g. Disabling stroke, Dialysis, AMI, etc. 26

Data Flow and Creation of Evidence Evolving Index Procedure Data Sponsor: Responsible for source data verification & monitoring Laschinger JC Passive Longitudinal Follow-up Longitudinally Acquired Data Site: Normally enters data in appropriate data repository * Pre-specified statistical analysis plan * 27

owen.faris@fda.hhs.gov

The Common Rule: What s Special about Pragmatic Trials? Julie Kaneshiro Office for Human Research Protections (OHRP) May 16, 2018

Disclaimer The opinions expressed are those of the presenter and do not necessarily reflect the policy of the U.S. Department of Health and Human Services. 30

Topics Applicability of the Common Rule to pragmatic trials Trial design IRB review Revised Common Rule OHRP initiatives 31

Determining if the Common Rule Applies The activity is conducted or supported by HHS The activity is non-exempt human subjects research To determine whether the activity is non-exempt human subjects research, ask these questions: 1) Does the activity involve research? 2) Does the research involve human subjects? 3) Is the human subjects research exempt? 32

Does the Pragmatic Trial Involve a Research Intervention? Definition of Research: Research means a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge. 33

Who are the Subjects in Pragmatic Trials? Definition of Human Subject: Human subject means a living individual about whom an investigator conducting research: i. Obtains information or biospecimens through intervention or interaction with the individual, and uses, studies, or analyzes the information or biospecimens; or ii. Obtains, uses, studies, analyzes, or generates identifiable private information or identifiable biospecimens 34

Trial Design Cluster design and impact on consent e.g., community, provider, hospital) Questions to consider: If a cluster design is proposed, is it necessary? Is the intervention research? Who are the subjects? What role, if any, should a patient s treating physician have in determining whether patients should be asked to enroll? Existence of equipoise does not necessarily mean that the study poses minimal risk or that consent can be waived 35

Which Collaborators Need IRB Review? Only institutions engaged in the research need IRB review not necessarily all collaborating institutions 36

IRB Review: Engaged? Need to consider the institution s activities A few examples of non-engagement: Release to investigators at another institution identifiable private information or identifiable biological specimens Perform commercial services for investigators provided that specified conditions also are met

Pragmatic trials and the Revised Common Rule New consent requirements IRB review 38

General Improvements to Informed Consent Establishes a new standard to provide the information needed to make an informed decision about whether to participate Reasonable person standard is used to determine what information to include 39

General Improvements Information presented in sufficient detail, and organized and presented in a way that facilitates subject s understanding of why one might or might not want to participate Not merely a list of isolated facts 40

General Improvements New requirement that certain key information must be provided first Key information About why one might or might not want to participate often include (though not limited to) information about purposes, risks, benefits and alternatives Must be presented in concise and focused manner 41

Requirement for Single IRB Review Applicability U.S. institutions engaged in cooperative research for the portion of the research conducted in the U.S. Does not apply: When more than single IRB review is required by law (including tribal law) Whenever any Federal department or agency supporting or conducting the research determines and documents that the use of a single IRB is not appropriate for the particular context Compliance date for sirb provision: January 20, 2020 42

OHRP Initiatives OHRP exploratory workshop on consent Public engagement on the regulation of certain types of health services research 43