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Mitigating Risk in Clinical Studies
                                 William Gluck, PhD
       VP, DATATRAK Clinical and Consulting Services
                                         April 11, 2013
Introduction

      William β€˜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.



Confidential – 2
Agenda
      β€’β€― Risk in Clinical Studies
             –  Definitions
             –  Identifying Risk in Clinical Trials
                  β€’β€― Study Set-Up and Initiation
                  β€’β€― Study Conduct and Optimization
      β€’β€― Leveraging Technology to Mitigate Risk
      β€’β€― Thoughts on the Future
             –  Virtual Trials
             –  Technology Driven Drug Development (TD3β„’)
      β€’β€― Wrap-Up

Confidential – 3
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



Confidential – 4
Identifying Risk In Clinical Studies
      β–Ίβ€―   Study Set-Up and Initiation
             β€’β€― Study Protocol
             β€’β€― Qualification, Training, Experience of all Study Personnel
             β€’β€― Recruitment
             β€’β€― Informed Consent
      β–Ίβ€―   Study Conduct and Optimization
             β€’β€― Protocol Deviations (inclusive of eligibility criteria)
             β€’β€― Drug Accountability
             β€’β€― Data Collection and Data Quality


Confidential – 5
Leveraging Technology
          Study Set-Up and Initiation


Confidential – 6
Study Protocol
      Risk
             β€’β€― Study protocol is not well defined
             β€’β€― Complex
             β€’β€― Risk assessments and plans are not adequate
             β€’β€― Amendments and Mid-Study Changes
      Mitigation
             β€’β€― Use of CDISC standards
                    –  Protocol and Study/Trial Design Model
             β€’β€―    Adaptive study design planning
             β€’β€―    Risk-based Approach planning
             β€’β€―    Electronic Data Collection (EDC)

Confidential – 7
Adaptive Study Design
     Study design that allows:
        β€’β€― Modification of pre-defined aspects of a study
        β€’β€― Interim reviews of accumulating study data
        β€’β€― No affect on the validity and integrity of the trial
     Adaptive design requires:
        β€’β€― Multiple stages
        β€’β€― Access to accumulated study data
        β€’β€― 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

Confidential – 8
Risk-Based Approach to Monitoring
   Draft guidance – released August 2011
   β–Ίβ€― FDA is clear that onsite visits are not always necessary and that
      β€œcentralized monitoring” may be preferred
   β–Ίβ€― Factors to consider when developing any type of monitoring plan
           β€’β€―   Complexity of study design
           β€’β€―   Types of study endpoints
           β€’β€―   Clinical complexity of study population
           β€’β€―   Geography
           β€’β€―   Relative experience of the clinical investigator and of the sponsor with the
                investigator
           β€’β€―   Electronic data capture
                  –  Metrics generation
                  –  Site quality assessments
           β€’β€―   Relative safety of the investigational product
           β€’β€―   Stage of the study
           β€’β€―   Quantity of data
   β–Ίβ€―    Potential time and money savings as well as increased data quality

Confidential – 9
Qualification,Training, Experience
      Risk
              β€’β€― Lack of experience
              β€’β€― Lack of essential documentation/records
              β€’β€― Medical records inadequately maintained
      Mitigation
              β€’β€― Clinical Trial Management System (CTMS)
              β€’β€― Electronic Trial Master File (eTMF)
              β€’β€― EDC and/or e-Training Records



Confidential – 10
Recruitment
      Risk
              β€’β€― Identification of sites/patients
              β€’β€― Delays in recruitment/enrollment
                    –  Due to recruitment of qualified participants
                    –  Due to site issues/quality
      Mitigation
              β€’β€― Electronic Health Records
              β€’β€― Social Media
              β€’β€― EDC
                    –  Patient data reviews
                    –  Metrics reporting

Confidential – 11
Informed Consent
      Risk
              β€’β€― Patient confidentiality and protection
              β€’β€― Adequately informed of study risks
      Mitigation
              β€’β€― Standardization
              β€’β€― Use of multi-media
              β€’β€― Electronic Informed Consent (virtual studies)




Confidential – 12
Leveraging Technology
           Study Conduct and Optimization


Confidential – 13
Protocol Deviations
      Risk
              β€’β€― Inclusion/Exclusion criteria
              β€’β€― Procedural deviations from the study protocol
              β€’β€― Enforcement of stopping rules/dose modification rules
      Mitigation
              β€’β€― Electronic health records
              β€’β€― EDC
                    –  Risk-based Approach to monitoring
                    –  Edit check specifications
                    –  Metrics reporting

Confidential – 14
Drug Accountability
      Risk
              β€’β€― Proper drug assignments
              β€’β€― Site accountability
              β€’β€― Dose management
      Mitigation
              β€’β€― EDC
                     –  Randomization
                     –  Drug inventory management
                     –  Metrics reporting
              β€’β€―    Electronic Reported Patient Outcomes (ePRO)

Confidential – 15
Data Collection and Quality
      Risk
              β€’β€― Site issues
                     –  Data quality – high query rates
                     –  Staff turn-over
              β€’β€―    Patient diary data collection – incomplete data
      Mitigation
              β€’β€― EDC
                     –  Risk-based Approach to monitoring
                     –  Metrics reporting
                     –  eTraining
              β€’β€―    ePRO

Confidential – 16
Thoughts on the
           Future


Confidential – 17
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

Confidential – 18
Technology Driven Drug
                     Development (TD3β„’)
      Patient-focused to improve patient adherence and
      safety as well as clinical outcomes

      More than a virtual trial, TD3β„’ is a holistic approach
      that leverages technology-based processes:
             Address study needs
             Evaluate viability of drug pipeline
             Reallocate focus and resources


Confidential – 19
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 TD3β„’



Confidential – 20
William Gluck, Ph.D.
                 VP, D ATATRAK Clinical and Consulting Services
                           D ATATRAK International, Inc.
                              Phone: 919-651-0222
                               Cell: 919-522-9681
                         E-Mail: Bill.Gluck@datatrak.net


Confidential –

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Mitigating Risks in Clinical Studies

  • 1. Mitigating Risk in Clinical Studies William Gluck, PhD VP, DATATRAK Clinical and Consulting Services April 11, 2013
  • 2. Introduction William β€˜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. Confidential – 2
  • 3. Agenda β€’β€― Risk in Clinical Studies –  Definitions –  Identifying Risk in Clinical Trials β€’β€― Study Set-Up and Initiation β€’β€― Study Conduct and Optimization β€’β€― Leveraging Technology to Mitigate Risk β€’β€― Thoughts on the Future –  Virtual Trials –  Technology Driven Drug Development (TD3β„’) β€’β€― Wrap-Up Confidential – 3
  • 4. 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 Confidential – 4
  • 5. Identifying Risk In Clinical Studies β–Ίβ€― Study Set-Up and Initiation β€’β€― Study Protocol β€’β€― Qualification, Training, Experience of all Study Personnel β€’β€― Recruitment β€’β€― Informed Consent β–Ίβ€― Study Conduct and Optimization β€’β€― Protocol Deviations (inclusive of eligibility criteria) β€’β€― Drug Accountability β€’β€― Data Collection and Data Quality Confidential – 5
  • 6. Leveraging Technology Study Set-Up and Initiation Confidential – 6
  • 7. Study Protocol Risk β€’β€― Study protocol is not well defined β€’β€― Complex β€’β€― Risk assessments and plans are not adequate β€’β€― Amendments and Mid-Study Changes Mitigation β€’β€― Use of CDISC standards –  Protocol and Study/Trial Design Model β€’β€― Adaptive study design planning β€’β€― Risk-based Approach planning β€’β€― Electronic Data Collection (EDC) Confidential – 7
  • 8. Adaptive Study Design Study design that allows: β€’β€― Modification of pre-defined aspects of a study β€’β€― Interim reviews of accumulating study data β€’β€― No affect on the validity and integrity of the trial Adaptive design requires: β€’β€― Multiple stages β€’β€― Access to accumulated study data β€’β€― 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 Confidential – 8
  • 9. Risk-Based Approach to Monitoring Draft guidance – released August 2011 β–Ίβ€― FDA is clear that onsite visits are not always necessary and that β€œcentralized monitoring” may be preferred β–Ίβ€― Factors to consider when developing any type of monitoring plan β€’β€― Complexity of study design β€’β€― Types of study endpoints β€’β€― Clinical complexity of study population β€’β€― Geography β€’β€― Relative experience of the clinical investigator and of the sponsor with the investigator β€’β€― Electronic data capture –  Metrics generation –  Site quality assessments β€’β€― Relative safety of the investigational product β€’β€― Stage of the study β€’β€― Quantity of data β–Ίβ€― Potential time and money savings as well as increased data quality Confidential – 9
  • 10. Qualification,Training, Experience Risk β€’β€― Lack of experience β€’β€― Lack of essential documentation/records β€’β€― Medical records inadequately maintained Mitigation β€’β€― Clinical Trial Management System (CTMS) β€’β€― Electronic Trial Master File (eTMF) β€’β€― EDC and/or e-Training Records Confidential – 10
  • 11. Recruitment Risk β€’β€― Identification of sites/patients β€’β€― Delays in recruitment/enrollment –  Due to recruitment of qualified participants –  Due to site issues/quality Mitigation β€’β€― Electronic Health Records β€’β€― Social Media β€’β€― EDC –  Patient data reviews –  Metrics reporting Confidential – 11
  • 12. Informed Consent Risk β€’β€― Patient confidentiality and protection β€’β€― Adequately informed of study risks Mitigation β€’β€― Standardization β€’β€― Use of multi-media β€’β€― Electronic Informed Consent (virtual studies) Confidential – 12
  • 13. Leveraging Technology Study Conduct and Optimization Confidential – 13
  • 14. Protocol Deviations Risk β€’β€― Inclusion/Exclusion criteria β€’β€― Procedural deviations from the study protocol β€’β€― Enforcement of stopping rules/dose modification rules Mitigation β€’β€― Electronic health records β€’β€― EDC –  Risk-based Approach to monitoring –  Edit check specifications –  Metrics reporting Confidential – 14
  • 15. Drug Accountability Risk β€’β€― Proper drug assignments β€’β€― Site accountability β€’β€― Dose management Mitigation β€’β€― EDC –  Randomization –  Drug inventory management –  Metrics reporting β€’β€― Electronic Reported Patient Outcomes (ePRO) Confidential – 15
  • 16. Data Collection and Quality Risk β€’β€― Site issues –  Data quality – high query rates –  Staff turn-over β€’β€― Patient diary data collection – incomplete data Mitigation β€’β€― EDC –  Risk-based Approach to monitoring –  Metrics reporting –  eTraining β€’β€― ePRO Confidential – 16
  • 17. Thoughts on the Future Confidential – 17
  • 18. 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 Confidential – 18
  • 19. Technology Driven Drug Development (TD3β„’) Patient-focused to improve patient adherence and safety as well as clinical outcomes More than a virtual trial, TD3β„’ is a holistic approach that leverages technology-based processes: Address study needs Evaluate viability of drug pipeline Reallocate focus and resources Confidential – 19
  • 20. 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 TD3β„’ Confidential – 20
  • 21. William Gluck, Ph.D. VP, D ATATRAK Clinical and Consulting Services D ATATRAK International, Inc. Phone: 919-651-0222 Cell: 919-522-9681 E-Mail: Bill.Gluck@datatrak.net Confidential –