Abstract
Background
With an increase in the complexity and cost of clinical trials and the advances in information technology, monitoring guidance issued by regulatory authorities recommends risk-adapted monitoring. To introduce the monitoring method for investigator-initiated investigational new drug (IND) trials using unapproved anticancer drugs, we performed exploratory retrospective analyses to identify risk factors for data quality.
Methods
To select investigator-initiated IND trials using unapproved anticancer drugs, we set the trial selection criteria. Data collection was performed by using audit trails and monitoring reports. Collected data were analyzed by univariate and multivariate analyses to identify the independent risk factors related to error.
Results
By trial selection criteria, 5 investigator-initiated IND trials using unapproved anticancer drugs were selected. The error rates of the total data, critical data, and noncritical data were 7.4%, 9.7%, and 5.9%, respectively. There was no difference between clinical research core hospitals certified by the Ministry of Health, Labour and Welfare and other hospitals in univariate analysis (odds ratio [OR], 1.00; 99% confidence interval [CI], 0.96-1.05; P =.9179). As the main independent risk factors related to error, critical data in the importance of data (OR, 1.28; 99% CI, 1.24-1.33; P <.0001) and groups with ≤3 patients after registration (OR, 1.12; 99% CI, 1.10-1.15; P <.0001) were significantly related to errors in multivariate analysis.
Conclusions
The results of this research suggest that the feasibility of risk-based monitoring and sampling source data verification was indicated for noncritical data and patients after the third case.
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References
International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use. Guidelines for good clinical practices E6(R1). http://www.ich.org/fileadmin/Public_Web_Site/ICH_Products/Guidelines/Efficacy/E6/E6_R1_Guideline.pdf. Published 1996. Accessed January 16, 2016.
Smith CT, Stocken DD, Dunn J, et al. The value of source data verification in a cancer clinical trial. PLoS One. 2012;7:e51623.
Andersen JR, Byrjalsen I, Bihlet A, et al. Impact of source data verification on data quality in clinical trials: an empirical post hoc analysis of three phase 3 randomized clinical trials. Br J Clin Pharmacol. 2015;79:660–668.
Funning S, Grahnén A, Eriksson K, Kettis-Linblad Å. Quality assurance within the scope of good clinical practice (GCP)—what is the cost of GCP-related activities? A survey within the Swedish association of the pharmaceutical industry (LIF)’s members. Qual Assur J. 2009;12:3–7.
Tantsyura V, Grimes I, Mitchel J, et al. Risk-based source data verification approaches: pros and cons. Drug Inf J. 2010;44:745–756.
Tantsyura V, Dunn IM, Waters J, et al. Extended risk-based monitoring model, on-demand query-driven source data verification, and their economic impact on clinical trial operations. Therapeutic Innovation & Regulatory Science. 2016;50:115–122.
Reith C, Landray M, Devereaux PJ, et al. Randomized clinical trials—removing unnecessary obstacles. N Engl J Med. 2013;369:1061–1065.
US Department of Health and Human Services, Food and Drug Administration. Guidance for industry: oversight of clinical investigations—a risk-based approach to monitoring. http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM269919.pdf. Published 2013. Accessed January 16, 2016.
European Medicines Agency. Reflection paper on risk based quality management in clinical trials. EMA/269011/2013. http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/11/WC500155491.pdf. Published 2013. Accessed January16, 2016.
Pharmaceutical and Food Safety Bureau, Ministry of Health, Labour and Welfare. Basic rules of the risk-based approach to monitoring clinical trials. PFSB/ELD notice, 1 July 2013. https://www.pmda.go.jp/files/000161664.pdf. Published 2013. Accessed January 16, 2016.
TransCelerate. Position paper: risk-based monitoring methodology. http://www.transceleratebiopharmainc.com/wp-content/uploads/2016/01/TransCelerate-RBM-Position-Paper-FINAL-30MAY2013.pdf.pdf. Published 2013. Accessed January 23, 2016.
Sheetz N, Wilson B, Benedict J, et al. Evaluating source data verification as a quality control measure in clinical trials. Therapeutic Innovation & Regulatory Science. 2014;48:671–680.
De S. Hybrid approaches to clinical trial monitoring: practical alternatives to 100% source data verification. Perspect Clin Res. 2011;2:100–104.
Nielsen E, Hyder D, Deng C. A data-driven approach to risk-based source data verification. Therapeutic Innovation & Regulatory Science. 2014;48:173–180.
Knepper D, Fenske C, Nadolny P, et al. Detecting data quality issues in clinical trials: current practices and recommendations. Therapeutic Innovation & Regulatory Science. 2016;50:15–21.
Gough J, Wilson B, Zerola M, et al. Defining a central monitoring capability: sharing the experience of TransCelerate BioPharma’s approach, Part 2. Therapeutic Innovation & Regulatory Science. 2015;50:8–14.
Morrison BW, Cochran CJ, White JG, et al. Monitoring the quality of conduct of clinical trials: a survey of current practices. Clin Trials. 2011;8:342–349.
Kurzrock R, Stewart DJ. Compliance in early-phase cancer clinical trials research. Oncologist. 2013;18:308–313.
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Sudo, T., Sato, A. Investigation of the Factors Affecting Risk-Based Quality Management of Investigator-Initiated Investigational New-Drug Trials for Unapproved Anticancer Drugs in Japan. Ther Innov Regul Sci 51, 589–596 (2017). https://doi.org/10.1177/2168479017705155
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DOI: https://doi.org/10.1177/2168479017705155