Transcript Clinical Trials and FDAAA for NIH Grantees Part I

ClinicalTrials.gov and
FDAAA for NIH Grantees
NIH Regional Seminar - June 2013
Rebecca J. Williams, PharmD, MPH
Assistant Director, ClinicalTrials.gov
National Library of Medicine
http://ClinicalTrials.gov
Overview
• Introduction to the Food and Drug Administration
Amendments Act of 2007 (FDAAA)
– Why FDAAA Title VIII?
– Requirements it establishes
– Next Steps
• FDAAA for NIH Extramural Grantees
– Implementation for NIH grants
– OER resources
• ClinicalTrials.gov Practical Considerations
– Protocol Registration System (PRS)
– Resources
2
Introduction to FDAAA
Three Key Issues with Publications
• Not all trials are published
• Publications do not always include all
prespecified outcome measures
• Unacknowledged changes are made to the
trial protocol that would affect the
interpretation of the findings
– e.g., changes to the prespecified outcome
measures
4
Kaplan-Meier estimates for ulcer complications according to
traditional definition. Results are truncated after 12 months, no ulcer
complications occurred after this period. Adapted from Lu 2001.
Source: Jüni P, Rutjes AW, Dieppe PA. BMJ. 2002 Jun 1;324(7349):1287-8.
5
The Controversies Continue…
6
7
Summary of Findings
• Fewer than half of NIH funded trials registered at
ClinicalTrials.gov after September 2005 and
completed by December 2008 were published in a
peer reviewed biomedical journal indexed by
Medline within 30 months of trial completion
• After a median of 51 months after study
completion, a third of NIH-funded trials in the
sample remained unpublished
BMJ 2011;344:d7292 doi
Rationale for Registering and
Reporting Clinical Trial Results
• Responsibility to human subjects and
the public
• Research integrity
• Evidence-based medicine
• Allocation of resources
9
Levels of “Transparency”
10
Zarin DA, Tse T. Science. 2008
10
ClinicalTrials.gov – Milestones
• 1997 - Food and Drug Administration
Modernization Act (FDAMA)
• 2000 - ClinicalTrials.gov launched
• 2005 - International Committee of Medical Journal
Editors (ICMJE) policy
• 2007 - FDAAA (Title VIII of Public Law 110-85)
– Expanded clinical trial registration requirement and
imposed new results submission requirements
– Added enforcement provisions including up to
$10,000/day in civil monetary penalties and withholding
remaining or future grant funds
11
FDAAA = Food and Drug Administration Amendments Act of 2007
What does FDAAA require?
The responsible party for an applicable
clinical trial (ACT) subject to FDAAA must :
1. Register the ACT in ClinicalTrials.gov no later
than 21 days after enrollment of the first
participant;
2. Submit summary results (including adverse
event information) for certain trials not later than
1 year after the trial’s (primary) completion date.
–
Delays allowed in some circumstances
12
12
FDAAA Key Terms
• Applicable Clinical Trials (ACTs)
• Responsible Party
• (Primary) Completion Date
13
13
What is an ACT?
• “Applicable Clinical Trials”* (ACTs)
subject to FDAAA are:
– Interventional studies of drugs, biologics, &
devices
– Not phase 1 drugs, not small feasibility devices
– US FDA jurisdiction (e.g., IND/IDE or US site)
– ACTs initiated on or after 9/27/07 or ongoing as
of 12/26/07
* http://prsinfo.clinicaltrials.gov/ElaborationsOnDefinitions.pdf
14
Who is the Responsible Party?
• “Responsible Party”* is defined as:
– Sponsor [only one per trial]
• IND/IDE holder; if none, then
• Person or entity who “initiated” the trial
– Funding recipient if grant or sponsored research agreement
– Funder if procurement funding agreement (contract)
– Sponsor may designate the Principal
Investigator (PI) as Responsible Party [only one
per trial]
• If PI meets certain requirements (e.g., has access to
and control over data, right to publish)
* http://prsinfo.clinicaltrials.gov/ElaborationsOnDefinitions.pdf
15
FDAAA Registration Requirements
• Where do I register?
– ClinicalTrials.gov web-based Protocol Registration
System (PRS); interactive data entry or XML upload
• Tool available for cancer centers also submitting protocol
information to NCI Clinical Trials Reporting Program (CTRP)
• When do I register?
– May register before initiation*; must register no later
than 21 days after enrolling the first participant
– Updates (if any) required at least once every 12 months
– Recruitment status and (primary) completion date must
be updated within 30 days
* International Committee of Medical Journal Editors (ICMJE) requires registration prior to enrollment of
first participant as a condition of consideration for publication
16
FDAAA Registration Requirements
• What do I register?
– ClinicalTrials.gov/FDAAA data elements*,
including:
• Study Design and Locations
• Responsible Party (updated format Aug 2011)
– Sponsor
– Sponsor Investigator
– Principal Investigator (designated by Sponsor)
• Complete NIH Grant Number in Secondary ID
17
* ClinicalTrials.gov Protocol Data Element Definitions (DRAFT): http://prsinfo.clinicaltrials.gov/definitions.html
FDAAA Results Requirements
• Which Trials Must Submit Results?
– “Applicable clinical trials” of FDA approved or
cleared drugs, biologics, devices
• Interventional studies of drugs, biologics, or devices
• Not phase 1 drug or not small feasibility device
• US FDA jurisdiction (e.g., IND/IDE or US site)
– Initiated on or after 9/27/07 or ongoing as of
12/26/07
18
http://www.clinicaltrials.gov/ct2/manage-recs/fdaaa
18
FDAAA Results Requirements
• When Must Results be Submitted?
– Within 12 months of (primary) completion date;
• “The date that the final subject was examined or received an
intervention for the purposes of final collection of data for the
primary outcome, whether the clinical trial concluded
according to the prespecified protocol or was terminated.”
– OR within 30 days of product approval or
clearance
– Delays possible
• Seeking approval of a new use
• Extensions for “good cause”
19
http://www.clinicaltrials.gov/ct2/manage-recs/fdaaa
19
FDAAA Results Requirements
• What Information Must be Submitted?
– Scientific Information (per arm)
• Participant Flow
– Number of participants started
– Number of participants completed
• Baseline Characteristics
– Number of Participants Analyzed
– Age and Gender
• Outcome Measures
–
–
–
–
Number of Participants Analyzed
Title and Description
Measure Type (e.g., mean) and Measure of Dispersion (e.g., SD)
Statistical analyses, as appropriate
20
http://www.clinicaltrials.gov/ct2/manage-recs/fdaaa
20
FDAAA Results Requirements
• What information? (cont.)
– Scientific Information (per arm)
• Adverse Events – Serious and “Other”
– Number of Participants Affected/At Risk
– Adverse Event Term and Organ System
• Limitations and Caveats (optional)
– Administrative Information
• Results Point of Contact
• Certain Agreements (related to investigator’s right to
publish, if not an employee of sponsor)
21
http://www.clinicaltrials.gov/ct2/manage-recs/fdaaa
21
FDAAA Results Requirements Clarifications
• Does NOT prescribe how study should be
conducted
• Summary results at the end of the trial
– No interim or “real time” reporting
– No participant level reporting
• Information currently targeted at readers of
the medical literature
– “Tables” of information; “just the facts”
– No narrative discussion or results/conclusions
22
Registration, Results Submission
and Publication
• International Committee of Medical Journal
Editors (ICMJE) requires registration of all
clinical trials as a condition of publication
– Must register prior to enrollment of first participant
• Deadlines for submitting results to
ClinicalTrials.gov are independent of
publication status
• Submitting results to ClinicalTrials.gov will
not interfere with publication*
– But, failing to register the trial will!
* Laine C, Horton R, DeAngelis C, et al. Ann Intern Med. 2007; http://www.icmje.org/faq_clinical.html
23
Results and non-ACTs
• Non-ACTs registered in ClinicalTrials.gov
are *not* required to submit results to
ClinicalTrials.gov
– Phase 1 trials
– Observational studies
• Exception: Pediatric postmarket surveillance of
devices
• NOTE: Other policies may apply
24
25
Participant Flow ClinicalTrials.gov Format
NCT00145249
NCT00145249
26
Baseline Measures ClinicalTrials.gov Format
“Default” Required Measures
27
NCT00145249
Outcome Measures ClinicalTrials.gov Format
NCT00145249
28
Outcome Measures ClinicalTrials.gov Format (cont’d)
29
NCT00145249
30
Adverse Events ClinicalTrials.gov Format
NCT00145249
31
Experience with Results Database
• Entering results is similar to the
process of preparing a journal article
• Data provider must be familiar with the
study design and data analysis
– Typically, the investigator and/or a
statistician will need to be involved
32
32
General Review Criteria
• Protocol and results must be clear and
informative
• Review focuses on:
– Logic and internal consistency
– Apparent validity
– Meaningful entries
– Formatting
33
33
Who is the Audience?
PI and Clinical Research Team
Other Medical Researchers in same field
Other Medical Researchers in other fields
Other Readers of the medical literature
Science Writers
Lay Public (readers of consumer health literature)
34
FDAAA – Other Considerations
• FDA Requirements
– Certification of Compliance to FDA
• Form 3674 must accompany human drug, biological, and
device product submissions
– FDA Compliance Program 7348.810: Sponsors,
Contract Research Organizations, and Monitors
• Instructs FDA staff to identify SOPs and determine if studies
were registered on ClinicalTrials.gov appropriately
– Informed Consent Regulations (21 CFR § 50.25(c))
• A statement must be included in informed consent documents
of applicable clinical trials initiated on or after March 7, 2012
regarding the availability of information at ClinicalTrials.gov
http://www.fda.gov/RegulatoryInformation/Guidances/ucm125335.htm
http://www.fda.gov/ICECI/ComplianceManuals/ComplianceProgramManual/default.htm
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=50.25
35
FDAAA - Next Steps
• HHS plans to issue regulations that will prescribe
procedures for registering and submitting results
of clinical trials to ClinicalTrials.gov in accordance
with FDAAA
• Notice of Proposed Rulemaking (NPRM)
– Fall 2012 HHS Unified Agenda estimated publication in
the Federal Register in January 2013
36
Overview of Rulemaking Process
Food and Drug Administration Amendments Act of 2007
Announcement in Department’s Unified Agenda of Regulatory Action
Agency Develops Draft Notice of Proposed Rulemaking (NPRM)
Department and OMB Review
NPRM Published in Federal Register
Public Comment Period (typically 60 – 90 days)
Agency Responds to Comments/ Develops Final Rule
Department and OMB Review
Final Rule Published in Federal Register
37
Additional Issues in Rulemaking
• Expand results reporting to trials of unapproved
products?
• Include narrative summaries? Can it be done
without being promotional and misleading?
• Technical; Lay language
• Data quality verification
• Process
• External sources
• Full protocol versus extract “necessary to help
evaluate the results”
38
ClinicalTrials.gov Practical
Considerations
Who is the Responsible Party?
• “Responsible Party”* is defined as:
– Sponsor [only one per trial]
• IND/IDE holder; if none, then
• Person or entity who “initiated” the trial
– Funding recipient if grant or sponsored research agreement
– Funder if procurement funding agreement (contract)
– Sponsor may designate the Principal
Investigator (PI) as Responsible Party [only one
per trial]
• If PI meets certain requirements (e.g., has access to
and control over data, right to publish)
* http://prsinfo.clinicaltrials.gov/ElaborationsOnDefinitions.pdf
40
PRS Responsible Party Format
• Updated format August 2011
• Responsible Party (RP) must approve and
release record
• If RP = Sponsor; no change in process
– Administrator “releases” record; fewer data elements
• If RP ≠ Sponsor; new process
– Record is in the Sponsor’s PRS Organization Account
– Investigator must be specified as a User in the PRS and name
must be properly formatted (for public display)
– Investigator “releases” record
» Administrator receives notification after release
• See: “Responsible Party FAQ” on PRS Main
Menu under Help
http://register.clinicaltrials.gov/
PRS Responsible Party Format
42 Information
Drug
Association
www.diahome.org
PRS Responsible Party Format
PRS Entry of Grant Number
44
Additional PRS Resources
• Problems Report
– Allows investigators and administrators of
organizational accounts to identify potential problems
with records
• Record Owner issues
• PRS Administrator issues
• FDAAA issues (report is downloadable)
– Trials missing FDAAA required data elements
– Trials that reached (primary) completion date more than
one year ago and results are not posted on
ClinicalTrials.gov
– Note: For informational purposes only. The Responsible
Party must determine if the trial is an “applicable clinical
trial” subject to FDAAA requirements.
45
PRS Information Resources
• Protocol Registration
– Data Element Definitions
– Review Criteria
• Results
– Data Element Definitions
– Review Criteria
– Simplified, Printable Results Templates
– Helpful Hints and Common Errors
• User’s Guide [PRS Main Menu]
46
http://www.clinicaltrials.gov/ct2/manage-recs/resources
46
Recorded Presentations
• Available at: http://prsinfo.clinicaltrials.gov/index.html
• Eight presentations with audio and slides
1. Overview of
ClinicalTrials.gov
2. Key FDAAA Issues
3. PRS Information and
Data Review Process
4. PRS Accounts and
Registration
• Results
5. Participant Flow Module
6. Baseline Characteristics
Module
7. Outcome Measures and
Statistical Analysis Module
8. Adverse Events Module
47
CTSA Training Opportunity
• ClinicalTrials.gov Results Database Train-theTrainer Workshop
– Goal is to train key personnel at CTSA institutions on
FDAAA and results database requirements so that they
may serve as a knowledge source for investigators at
their institution
– Next workshops are June 10-11(registration is closed)
and July 22-23, 2013
48
Select Publications
Zarin DA, Tse T, Williams RJ, Califf RM, Ide NC. The
ClinicalTrials.gov results database – update and key issues.
N Engl J Med 2011;852-860.
Tse T, Williams RJ, Zarin DA. Update on registration of clinical
trials in ClinicalTrials.gov. Chest 2009;136:304-5.
Tse T, Williams RJ, Zarin DA. Reporting basic results in
ClinicalTrials.gov. Chest 2009;136:295-303.
Zarin DA, Tse T. Moving toward transparency of clinical trials.
Science 2008;319:1340-2.
49
Additional Information
General ClinicalTrials.gov information:
www.clinicaltrials.gov
Office of Extramural Research (OER)
http://grants.nih.gov/Clinicaltrials_fdaaa/
Questions?
[email protected]