Grand Rounds April 26, 2024: Waiver or Alteration of Informed Consent for Minimal Risk Clinical Investigations – FDA Regulation Development and Research Landscape (Lauren Milner, PhD; Jonathan Casey, MD, MSCI; Matthew Semler, MD, MSCI)

Speakers

Lauren Milner, PhD
Office of Clinical Policy
U.S. Food and Drug Administration (FDA)

Jonathan Casey, M.D., MSCI
Assistant Professor, Division of Pulmonary and Critical Care Medicine
Vanderbilt University Medical Center
Director, Coordinating Center Pragmatic Critical Care Research Group

Matthew Semler, M.D., MSCI
Associate Professor, Division of Pulmonary and Critical Care Medicine
Vanderbilt University Medical Center
Director, Steering Committee Pragmatic Critical Care
Research Group
Co-Director, Vanderbilt Center for Learning Healthcare

Keywords

Food and Drug Administration, FDA, Waiver of Consent, Alteration of Informed Consent, IRB, Ethics, Regulatory

Key Points

  • Section 3024 of the FDA 21st Century Cures Act (2016) amends the Food, Drug and Cosmetics Act and provides the U.S. Food and Drug Administration (FDA) with the authority to permit an exception from informed consent requirements when the proposed clinical testing poses no more than minimal risk to the human subject and includes appropriate safeguards to protect the rights, safety, and welfare of participants.
  • In 2018, FDA issued the Proposed Rule that would allow an IRB to waive or alter certain informed consent elements, or to waive the requirement to obtain informed consent, under limited conditions, for certain minimal risk clinical investigators.
  • The Final Rule (2023) finalizes 4 criteria for waiver or alteration of consent with minor edits and adopts a 5th criterion for waiver or alteration of consent for identifiable information and biospecimens.
  • The Final Rule is not new for IRBs and investigators familiar with the minimal risk waiver/alteration provision in the Common Rule. It has the same criteria, same process. It is relatively new to FDA’s regulated community. Previously, FDA regulations allowed waiver only for certain types of emergency research.
  • The goal of the Final Rule is to advance medical product development without compromising the rights, safety and welfare of people participating in clinical research. FDA will develop a draft guidance to accompany the final rule and communicate with researchers, IRBs, patient communities and other interested parties about the rule.
  • To understand how the regulations are being applied currently, a team at Vanderbilt systematically reviewed all studies meeting the NIH definition of clinical trial, published in the last year (May 2023 to April 2024) in JAMA and the New England Journal of Medicine (NEJM). Each trial was reviewed to determine whether informed consent prior to enrollment was required.
  • During that time period, 33 trials were published in JAMA or NEJM that did not require informed consent. The reasons they did not require informed consent fell into 3 buckets: 1. Emergency and critical care studies (19 RCTs enrolling more than 15,000 patients where informed consent before enrollment was considered impracticable because of the urgency of the intervention and the condition of the patient); 2. Cluster-level: Infection Prevention (11 RCTs enrolling almost 3 million patients where consent was considered impracticable because the intervention was delivered to a group of patients different than the patients who would experience the outcomes (i.e. infection control) and due to the scale); 3. Interventions to promote communication and facilitate care (3 RCTs).
  • In all, the systematic review found that 13% of trials did not require informed consent before enrollment, and 89% of patients (more than 3 million) in trials that did not require informed consent before enrollment.
  • Upcoming FDA guidance on waiver and alteration of consent could provide the first regulatory guidance for minimal risk interventional research. While U.S. federal regulators do not currently provide guidance on minimal risk for interventional trial, trials are occurring with waiver and alteration.
  • Upcoming FDA regulations present an important opportunity for the NIH Collaboratory’s goal of facilitating Learning Healthcare Systems capable of using embedded pragmatic trials to improve patient outcomes

 

Discussion Themes

-What is next from FDA in terms of the release of any further guidance? The timeline is challenging. It is under development and the FDA is working through the process.

How does one judge the minimal risk criteria? For example, there are a lot of people who treat patients with diabetes with various medications. They may vary in terms of side effects, some of which might be rare. How do you identify if it is minimal risk? You have to meet 2 criteria to be considered for waiver of informed consent, both minimal risk and impracticability. Regardless of how you assess risk for a modestly sized study of a non-urgent intervention, then it would be conceivable to do it under consent and you would not need a waiver. If you are talking about health care system level studies, and for example, a study where these medications are already being used commonly and they are considered to be equivalent, that might be a case where people could consider choices like that. The framework of thinking is always “compared to what” and who is making the decisions. In clinical care is this something where the data is already good enough that physicians feel confident most of the time about one choice or would the patient have a strong preference about or a situation where the patient and clinician are not making the decision and there’s a spectrum in between. The question what does it look like now in clinical care can give a qualitative sense about the risk.

 

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#pctGR, @Collaboratory1

Grand Rounds April 19, 2024: The Yale Open Data Access (YODA) Project: 10 Years of Clinical Trial Data Sharing (Joseph S. Ross, MD, MHS)

Speaker

Joseph S. Ross, MD, MHS
Professor of Medicine and Public Health
Yale University

Keywords

YODA, Open Data Access, Data Sharing

Key Points

  • Data sharing and open science are important because underreporting research through selective publication and reporting are common. Fifty percent of clinical trials are never published. Even when published, many trial publications are delayed more than 2 years, many are underreported, statistically significant findings are most likely to be reported, and nearly two-thirds of studies had a primary outcome that was changed, introduced, or omitted. Yet patients and physicians frequently make treatment decisions based on only a portion of the potentially available clinical data.
  • The 1997 FDA Modernization Act (section 113) provided public access to information about ongoing clinical trials, which led to the creation of ClinicalTrials.gov. The International Committee of Medical Journal Editors (ICMJE) realized that ClinicalTrials.gov had slow growth, and it decided not to accept papers that had not been registered.
  • In 2007 the FDA Amendments Act (FDAAA) broadened the scope, requiring expanded registry, trial results uploaded within 12 months of study completion, sharing of basic results and adverse events. Other funders started requiring similarly.
  • Since 2007 there has been a sea change in thinking about data sharing. ICMJE said effective July 2018 manuscripts must contain a data sharing statement, and trials that begin enrolling participants on or after January 2019 must include a data sharing plan in the trial’s registration. Effective January 2023, all research funded or conducted by NIH must include in the proposal plans for management and sharing of all data necessary to validate and replicate research findings.
  • NIH is now implementing these large-scale efforts for data sharing. Researchers have to submit a data management and sharing plan including data types and amount as well as metadata; related tools, software, and/or code that will be generated; standards (formats, documentation, dictionaries); data preservation, access, associated timelines; access, distribution or reuse considerations; oversight of data management and sharing; and budgets for allowable costs.
  • The YODA Project platform launched to find ways to make clinical trial data more available for investigators to use. YODA started with core principles to answer what would the ideal clinical trial data sharing platform would look like.
  • YODA was launched in partnership with Johnson & Johnson in 2014 after a proof-of-concept effort with Medtronic. J&J started sharing trial data from all pharmaceutical products (including legacy trials), device and diagnostic products as of 2015, and consumer products as of 2017. YODA established data access policy and procedures with input from a Steering Committee, experts, stakeholders and public comment.
  • YODA has 459 trials currently available with about 90% that have been thus far requested. Of 385 requests submitted, 368 have been approved, 4 remain under review, 11 were withdrawn/closed, 2 were rejected. Nearly all of the requests that come in require some administrative revision, but one-quarter required scientific revisions after review for clarity. 157 manuscripts and 93 abstracts have been submitted and 119 and 89 of which have been published or presented, respectively.
  • There is valuable strengthening of science that happens in these data sharing efforts. Numerous studies that might not otherwise been feasible to pursue. Data sharing has facilitated direct collaborations and developed efficiencies. Replication studies have supported the original study. There have been no instances of patient privacy breaches, no publications of spurious safety findings that received unwarranted attention or disrupted patient care, and no data have been used for commercial or litigious purposes.

Learn More

Visit the YODA Project website.

Discussion Themes

-What were some surprises compared to expectations over the 10 years of the YODA project? It is firmly in our mind that we should be living in an open science data world, and part of that is sharing data and trying to help improve patient care. How do we get the resources on the academic side to help investigators who want to do this work? On the industry side, partners have stepped up and made their data available. Across the field, how do we get more prior data available?

 

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#pctGR, @Collaboratory1

Grand Rounds April 5, 2024: A New Look at P Values for Randomized Clinical Trials (Erik van Zwet, PhD)

Speaker

Erik van Zwet, PhD
Department of Biomedical Data Sciences
Leiden University Medical Center, the Netherlands

Keywords

P Values, Randomized Clinical Trials, Biostatistics

Key Points

  • The “essence” of a clinical trial is a set of 3 numbers:  β, b, and s. β is the unobserved, “true” effect of the treatment. B is a normally distributed, unbiased estimator of β with standard error s. It is helpful to think of the estimate b as the true effect β plus a normally distributed “error” (b= β + N (0,s).
  • There are 2 more quantities to consider. The z-stat, where z= b/s and the signal-to-noise ration (SNR= β/s). Usually in a clinical trial we want to test the null hypothesis that the treatment has zero effect. If the z statistic is greater than 1.96 then the p-value is less than 0.05. The power depends on the SNR. For example, if SNR = 2.8 then the power is 80%.
  • Researchers have been studying data from the Cochrane Database of Systematic Reviews (CDSR) that include about 23,000 z-stats for the primary efficacy outcome of RCTs in the database.
  • From the CDSR, we can estimate the distribution of the z-stat and, also, surprisingly, of the signal-to-noise ration. This is possible because there is such a simple relationship between the two. First, estimate the distribution of z directly from the observed z-stats, then derive the distribution of SNR by “removing” the standard normal error component.
  • Researchers can use the estimated distributions of the z-stats and the SNRs to build a “synthetic” version of the CDSR with the same statistical properties of the real CDSR. With the synthetic database researchers can get insights to the real CDSR.
  • The first thing to look at is power. RCTs are designed to have 80% or 90% power for testing that the true effect is actually 0 against an alternative that is considered to be of clinical interest, or plausible, or both. But the SNR is larger than 2.8 in only 12% of the CDSR trials.
  • Many trials have low power against true effect. This has 2 consequences: if p is greater than 0.05 you might be discarding a useful treatment because you didn’t collect enough information to show that it works. If p is less than 0.05 you got very lucky. The effect estimate is likely overestimated and replication attempts will likely fail. A potential solution is to calculate the shrinkage estimation.

Learn More

Read more in NEJM Evidence.

Discussion Themes

-Overestimation was found across medical disciplines. There are a lot of small low power trials that should be published and part of math analyses. There is a lot of financial pressure to design a trial that is not too large, not to small and will have a good chance of success.

Do you have any thoughts on how this applies to non-inferiority trials? Did you exclude those from these analyses? We did not exclude those. There is a small minority where we know they were non-inferiority trials. Maybe they would be differently sized.

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#pctGR, @Collaboratory1

Grand Rounds March 29, 2024: Effect Of A Multicomponent Intervention to Improve Patient Access to Kidney Transplant and Living Kidney Donation: A Pragmatic, Cluster-Randomized Trial (Amit Garg, MD, MA, FRCPC, FACP, PhD; Stephanie N. Dixon, PhD, MSc)

Speakers

Amit Garg, MD, MA (Education) FRCPC, FACP, PhD
Associate Dean, Clinical Research, Schulich School of Medicine and Dentistry
Lead, Institute for Clinical Evaluative Sciences Kidney, Dialysis and Transplantation Provincial Program
Director, Institute for Clinical Evaluative Sciences (ICES) Western Facility
Nephrologist, London Health Sciences Centre
Professor, Medicine, Epidemiology & Biostatistics, Western University 

Stephanie N. Dixon, PhD MSc
Staff Scientist, Institute for Clinical Evaluative Sciences Kidney, Dialysis and Transplantation Research Program
Biostatistician, London Health Sciences Centre

Keywords

Cluster-randomized; Kidney disease; Transplant; Outcomes

Key Points

  • For patients with kidney failure, a kidney transplant is proven to offer patients a better quality of life and is more cost effective for health care systems than dialysis over time. However, there are many barriers preventing eligible patients from receiving a kidney transplant.
  • EnAKT LKD is a cluster randomized trial that sought to improve access to transplants in order to determine whether renal program-wide use of a multicomponent intervention is superior to usual care through 4 key steps: referral, donor evaluation, waitlist, and transplant. This multicomponent intervention was designed to address several barriers that prevent kidney transplantation and living donation through providing administrative support, educational resources, patient support groups, and performance reports.
  • During 4.2-year trial period, 10,000 patients eligible for a kidney transplant between the ages of 18-75 entered each of the two trial arms. Half of these patients were approaching a need for dialysis.
  • In conducting the statistical analysis of a trial, it’s especially important to consider the types of outcomes, as well as how they are collected to incorporate into the analysis. In the EnAKT LKD trial, the primary outcome is completing 4 unique key steps toward receiving a kidney transplant.
  • The primary outcome was analyzed using a patient-level constrained multistate model adjusting for the clustering in CKD programs. The multistate model allowed the researchers to start patients at different steps in the process upon enrollment in order to more accurately reflect where they are on their transplant journey. One of the limitations of this model is that it assumes that once a patient moves into a new state, they are no longer in the previous state. In order to address this limitation, researchers can expand the multistate framework to allow for different baseline hazards to be associated with the different transitions between states, creating a step completion history for each patient that evaluates their experiences in each step of the process.
  • Although researchers observed evidence of multicomponent intervention uptake through each of the 4 intervention components, the rate at which patients completed each of the 4 key steps to receiving a kidney transplant did not significantly differ between the intervention and usual-care groups.
  • The trial investigators are working toward a modified approach to addressing the important issue of access to transplantation.

Learn More

Read more in JAMA.

Learn about the Pragmatic Trials Training Program.

Discussion Themes

-Essentially all the potential upside that you were aiming for in this trial was to increase the number of living kidney donors, correct? Yes, that is correct. In order to meet the demand for kidney transplant, the World Health Organization and other agencies have increased the amount of living donor transplants. Unfortunately, this is a complex issue with a number of steps. There are health care systems issues. It’s difficult to get people to come forward to donate a kidney. Those are the various barriers we’re trying to address through this trial.

-Why did you choose to measure total transplantation rather than those from living donors as your outcome? For the primary analysis, we counted all transplants, and we certainly looked at living donor transplants separately in additional outcomes. The reason for that is we were trying to activate the intervention. For example, for referral for transplant, that might not result in a living donor transplant but might result in a kidney donor transplant, particularly for people who were enrolled earlier in the trial. We acknowledge that given the wait times, the biggest impact we were hoping for was a living donor transplant.

 

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#pctGR, @Collaboratory1

Grand Rounds March 22, 2024: Early Diagnosis and Assessment of Autism Via Objective Measurements of Social Visual Engagement (Warren Jones, PhD)

Speaker

Warren Jones, PhD
Director of Research, Marcus Autism Center
Children’s Healthcare of Atlanta
Norman Nien Distinguished Chair in Autism
Associate Professor, Dept. of Pediatrics
Emory University School of Medicine

Keywords

Autism Spectrum Disorder, Biomarkers, Social Visual Engagement

Key Points

  • Autism affects 1 in every 36, impacting more than 9.1 million individuals and their families in the U.S. When we think about conditions that affect young children and their families, autism is one of the most common.
  • Parents in the U.S. spend an average of 2-3 years between the time when they first begin to worry and the time when they finally receive a diagnosis. There are not enough expert clinicians or expert centers to meet public need. Disadvantaged families wait even longer.
  • Clinicians need more measures that are objective, quantitative, dimensional and fine-grained, performance-based, standardized, efficient and community-viable, able to capture core features of social disability, and mechanistically relevant.
  • Social visual engagement measures how children look at and learn from their surrounding social environment. Children look at and acquire information from what they are looking at. Researchers use eye tracking data to measure social visual engagement, which reflects early-emerging differences in autism spectrum disorder (ASD).
  • In 3 studies, researchers tested the performance of eye-tracking-based assays of social visual engagement in 16-30-month-old children to accurately assess presence of ASD and accurately assess severity of ASD.
  • The Discovery study included 719 participants, and the Replication study included 370 participants aged 16-30 months old. The initial Discovery study and first Replication study showed high sensitivity and specificity when comparing eye-tracking-based measures of social visual engagement with expert clinician diagnosis in children approximately 16-30 months old.
  • With the results from the initial studies, the trial team embarked on a multi-site clinical trial at 6 sites across the U.S. 475 participants completed eye-tracking measurement of social visual engagement, expert clinical diagnosis, and a rating of expert diagnostic certainty.
  • The study resulted in 335 participants with a reference standard certain diagnosis for ASD and 140 with a reference standard uncertain diagnosis for ASD. The children seen in the study who did not have autism did have other developmental diagnoses, which highlights the challenge of diagnosing children with developmental delays.
  • Study results show a high sensitivity and specificity when comparing eye-tracking-based measures of social visual engagement with expert clinician diagnosis in children as young as 16-30 months old. Results also show a strong correlation with standardized assessments given by experienced clinicians

Learn More

Read more in JAMA.

Discussion Themes

-Is there an eventual hope that a tool like this could be used without a referral to a specialty center? Absolutely. We started at a point to try to develop a tool with gold standard outcomes, and we are going on to test screening studies in other age groups. Our hope is to extend and develop clinical tools that could be easier to use.

What did you learn that informed the development of tools that would be more generalizable? This work has been conducted in conversation with FDA for many years, successfully moving something that was lab-based to increasingly more real-world. We are working toward making this more usable by general clinicians, asking what they need and want to make it more useful. For the screening studies, we looked at the SMART study framework for clinical trials to get to who is most likely to need a diagnostic evaluation.

 

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#pctGR, @Collaboratory1

Grand Rounds March 15, 2024: Antibiotic Choice on Renal Outcomes – The ACORN Trial (Edward Qian, MD, MSc)

Speaker

Edward Qian, MD, MSc
Assistant Professor of Medicine
Vanderbilt University Medical Center
Division of Pulmonary and Critical Care Medicine

Keywords

ACORN, Antibiotics, Acute Kidney Injury, Critical Care Medicine, Randomized Clinical Trial, EHR

Key Points

  • Sepsis is a common cause of critical illness and death. A common treatment is treating with vancomycin plus either piperacillin-tazobactam or cefepime. Piperacillin-tazobactam and cefepime have unique risk/benefit profiles but comparative data are lacking.
  • There have been associations with piperacillin and acute kidney injury (AKI). Acute kidney injury is associated with a 6-to-8-fold increase in mortality in critically ill patients. There was concern that there is an association between concurrent vancomycin and piperacillin-tazobactam with creatinine elevations, but a retrospective, observational analysis was inconclusive.
  • The ACORN Trial was randomized clinical trial to understand the effect of empiric antibiotic choice for patients in the ED and ICU. The trial enrolled 2,511 patients, who were adults who were in the hospital ED or ICU for less than 12 hours and received at least one dose of empiric cefepime or piperacillin-tazobactam. The intervention was a choice of empiric gram-negative antibiotic (cefepime or piperacillin-tazobactam).
  • The screening process was done via an interruptive alert in the electronic health record (EHR) that was activated based on a provider placing an order for drugs. The alert would remind for exclusion criteria, and ask if the patient is eligible for ACORN trial.
  • The trial operated under a waiver of informed consent. The research involved no more than minimal risk to subjects, and the research could not be carried out practicably without the waiver or alteration.
  • The participant randomization happened within the EHR. The delivery of the intervention happened in the EHR, starting with an alert to enroll. Providers were sent an order set depending on the arm. The study team monitored for compliance within the EHR.
  • The primary outcome was AKI ordinate scale between enrollment and Day 14. Secondary outcomes were major adverse kidney events within 14 days and days alive and free of delirium and coma to day 14.
  • The trial found that, compared to cefepime, piperacillin-tazobactam does not increase the incidence of AKI. Compared to piperacillin-tazobactam, cefepime may decrease the number of days alive and free of delirium and coma.

Learn More

Read more in JAMA.

Discussion Themes

-How much pilot testing did you do? I was trained as an EPIC physician builder. In preparation for this trial, I underwent this training so all the pieces that you saw, I built and tested in a relatively short time period.

How did you engage clinicians and make sure the question you were answering was one they wanted the answer to? There was a huge amount of leg work to engage stakeholders. We were talking to the leadership of ICU, nephrology, ID, and others for buy-in, to answer questions, and to make modifications based on suggestions.

How portable are your EHR modifications? In particular, how big a lift would it have been to implement the same protocol in multiple EPIC installations? This whole trial was done while I was getting a master’s in applied informatics. The answer is no. The screening and randomization could be portable. Each installed EPIC has slight differences and quirks. There will be small differences in the application of the intervention.

 

Tags

#pctGR, @Collaboratory1

Grand Rounds March 8, 2024: Public-Private Partnerships in the Trustworthy Health AI Ecosystem (Michael Pencina, PhD; Brian Anderson, MD)

Speakers

Michael Pencina, PhD
Chief Data Scientist, Duke Health
Duke University School of Medicine

Brian Anderson, MD
CEO, Coalition for Health AI

Keywords

Artificial Intelligence, AI, Coalition for Health AI (CHAI), Duke ABCDS, Governance, Regulation

Key Points

  • The regulatory landscape for AI is changing rapidly. There are a number of government agencies trying to establish their position on AI, including FDA and The U.S. Department of Health and Human Services Office of Civil Rights. The Office of the National Coordinator for Health Information Technology (ONC) published its final rule on AI in December.
  • We are living in a “wild west” of algorithms. There’s so much focus on development and technological progress and not enough attention to its value, quality, ethical principles, or health equity implications.
  • There are principles we can apply for the responsible development and use of AI, such as ensuring that AI technology serves humans; defining the task we want the AI tool to accomplish; describing what the successful use of the AI tool looks like; and creating transparent systems for continuously testing and monitoring AI tools.
  • Three years ago, Duke created an algorithm-based clinical support (ABCDS) function which monitors application of algorithms, AI, in our health system. The governance is now changing as AI moves from predictive models to large-language models.
  • This is complex environment where not everyone speaks the same language, clinicians, developers, patients, informaticists, statisticians, and more. It is very important that development teams are connected with what is happening at the health system level and the clinical teams on everything they build.
  • Model development follows the FDA process starting with model development, silent evaluation, effectiveness evaluation, and general deployment, with evaluations at regular intervals.
  • The Coalition for Health AI (CHAI) is a nonprofit that brings together more than 1,400 private sector organizations, including health care systems, payors, device manufacturers, technology companies, and patient advocates, plus U.S. government partners, to provide a framework for the landscape of health AI tools to ensure high quality care, increase trust among users, and meet health care needs.
  • Generative AI will become more impactful and ubiquitous. We have an urgent need to define what is safe and effective in this space and rethink how we regulate and align generative AI

 

Discussion Themes

-The field is really exploding. How are you forecasting how the federation will come together to address the potential volume of algorithms? Part of the challenge is that it is really important that we build consensus quickly and include as many voices as we can. We are identifying as many use cases as we can, building consensus around a set of shared definitions and frameworks, and then fleshing those out in the nuances of use cases. The other challenge is, once we have that defined, we need to share freely what we learn for wide adoption. We can’t do this in silos.

How are you approaching ethics in AI? How do you envision including an ethical component in algorithm development? For our ABCDS team for Duke, we have an ethicist on the team to make sure our principles are applied. This is not enough; we will need more as the field develops

Tags

#pctGR, @Collaboratory1

Grand Rounds March 1, 2024: Effect of an Intensive Food-As-Medicine Program on Health and Health Care Use: Evidence from a Randomized Clinical Trial (Joseph Doyle, PhD)

Speaker

Joseph Doyle, PhD
Erwin H. Schell Professor of Management and Applied Economics
MIT Sloan School of Management

Keywords

Food-as-Medicine, Randomized Clinical Trial, Diabetes

Key Points

  • Diabetes is common and costly. 9% of the U.S. has the condition; it is responsible for 300,000 premature deaths/year and $330 billion in annual healthcare spending. Payers should have some incentive to improve outcomes because sustained reduction in HbA1c from poor to fair can result in cost savings. Food insecurity is associated with diabetes.
  • Food-as-Medicine observational studies have had a large correlation with improved health.
  • For the intervention in this Food-as-Medicine trial, participants with diabetes were prescribed 10 meals/week for participants and their families that they could fill at the program’s clinic. Clinic staff included a dietitian, a nurse and a community health worker. The dietician met with the patient to share education about nutrition, portion size, recipes to make food taste good, and information via an optional diabetes self-management program. They also screened for complications and close care gaps. The average duration of the intervention was 1 year, and the cost was about $2,000 per participant.
  • The trial was for adults with HbA1c greater than 8.0, who were food insecure and lived within a residential zip code within 25 miles of a clinic. Recruitment was by phone calls and physician referrals, and consent was over the phone. Randomization was stratified by HbA1c greater than 9.5 and site. The intervention group started the program now. The control group started in 6 months and received a brochure that lists addresses of area food banks.
  • The primary outcome was HbA1c after 6 months. Lab results for HbA1c, cholesterol, triglycerides, blood pressure, weight were taken at 0, 6 and 12 months. There were also surveys to assess program education, diet, a self-efficacy questionnaire, and a self-assessed physical and mental health questionnaire at 0, 6, and 12 months. Participants received a $50 gift card for completing the labs and surveys.
  • Additional data sources came from EHR data, health plan claims, and program participation data including food visits and education.
  • 500 patients were randomized to intervention or control groups, with a utilization of 465 and 349 participants completing the 6-month HbA1c lab sample. The treatment group started with a mean 10.3 HbA1c it dropped to a mean of 8.8 at 6 months, which plateaued in 12 months. The control group followed similarly. There were no significant drops in cholesterol, triglycerides, or fasting glucose and weight did not lower. There was not a statistically significant difference between the 2 groups at 12 months.
  • The study found a null effect on HbA1c. The study did find substantial effects on diet and healthcare engagement.

Learn more

Read more in JAMA.

Discussion Themes

-Why do you think it was a negative study? The idea was that they would have to go get the food. Medically tailored meals is the alternative. We don’t have the diaries of what they do with the food. We see people visiting the fresh food pharmacies for up to 12 months. When they get home do they give the food away, eat it themselves, throw it away, we don’t know. In terms of the types of food they had, they were not especially culturally diverse.

Can you say something about the dose of the meal, which was 10 meals a week? Were people eating less healthy meals for the non-program meals? How much food to give is a parameter that needs more research. The dietitians in the program thought that 10 meals a week was the right number and that providing all meals would have been too much and resulted in waste. From a researcher standpoint, we need more information

Tags

#pctGR, @Collaboratory1

Grand Rounds February 23, 2024: Virtual Vigilance: Monitoring of Decentralized Clinical Trials (Adrian Hernandez, MD; Christopher J. Lindsell, PhD)

Speakers

Adrian Hernandez, MD
Executive Director, Duke Clinical Research Institute
Vice Dean, Duke University School of Medicine

Christopher J. Lindsell, PhD
Professor and co-Chief of Biostatistics, Department of Biostatistics & Bioinformatics
Director, Data Science and Biostatistics, Duke Clinical Research Institute
Duke University School of Medicine
Editor in Chief, Journal of Clinical and translational Science

Keywords

Decentralized Clinical Trials, Virtual Vigilance, Data and Safety Monitoring

Key Points

  • There has been global growth of decentralized clinical trials (DCTs) and with that a growing need to develop best practices and to ensure quality results are generated from trials. The global decentralized clinical trial market is expected to grow at a compound annual growth rate of 30.1% from 2021 to 2026.
  • But there are concerns to developing DCTs including lack of standardization and validation, regulatory and ethical uncertainties, engagement vs. coercion, data security and privacy issues, technological literacy and access, resistance to change and adoption, and lack of “safe” sharing.
  • There is agreement that trials need to meet the people, at home and covering clinical trial deserts.
  • There are 5 guiding principles for defining quality that should inform DCTs: Have we enrolled the right participants according to the protocol with adequate consent? Did participants receive the assigned treatment and did they stay on the treatment? Was there complete ascertainment of primary and secondary efficacy data? Was there complete ascertainment of primary and secondary safety data? Were there any major GCP-related issues?
  • Regardless of the trial inclusion and exclusion is routine. What we often do not think about is verifying the identity of the participant. In a remote study, it would be possible for duplicate enrollment, falsified or fabricated eligibility source documents, or data completed by surrogates. Consider secure digital identification, two-fact authentication or virtual/video visits. Balance with not adding barriers for participation.
  • Getting study drug and other study materials into the hands of a participant requires distribution via mail or courier, breaking the traditional chain of custody. Under RBM, the process by which study materials get to participants should be considered high risk and monitored accordingly.
  • As roles for sites change, it remains critical that participants can be actively managed and that data about patient status can be acted upon, including mechanisms for participants to ask questions and get timely responses, participants to report worrisome events, participants to report healthcare encounters and other events, tracking adherence to study intervention, and tracking adherence to data collection procedures. Solutions include a bi-directional EDC (electronic data capture system), MyChart for research, and active notifications to study personnel based on entered data.
  • Baseline state, treatment, outcome, and safety data are critical to understanding treatment benefits and risks. Outcomes including patient reported outcomes, functional assessments including via digital technology, healthcare events or mortality may require identify verification. Supporting documentation may include recordings of functional assessments, EHR data, or other information that can be uploaded for remote review. Note that the release of medical records may be needed for health systems unrelated to sites.
  • New issues to consider for DCTs: Geographic distribution of participants; enrollment of two or more participants who share the same digital resource; enrollment of participants who do not have sufficient digital resources; and rogue digital and social media recruitment practices

 

Discussion Themes

-Do you anticipate that a new set of clinical practices will emerge from this work? I think we must. One of the things we are in the process of sharing in terms of what we are observing is putting new procedures for what we monitor in a study. It is based on good study design and focusing on the key principles we are trying to adhere to. There has to be a range of approaches that could be fit for use.

Can you comment on how this is perceived at NIH and some of the institutes? I am sure NIH is trying to accelerate our understanding of DCTs. The knowledge base isn’t there yet in terms of what you need to look for that would be missing in terms of monitoring efforts. From my perspective, if one key goal for NIH is to reach people in underserved communities having sound practices for decentralized methods will be important.

How can we prepare research teams that do not always have the training and compensation to do all of these things? We need to train the workforce for what we need them to do. We are building out what are the core competencies, the technological, legal, ethical, clinical research administration competencies that are needed in addition to data management for a CRC. I hope we see further development of education programs that support the workforce with the skills needed. The skills may also vary between trials and getting participants the care they need.

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Grand Rounds February 16, 2024: Clinical Implications of the MINT Trial: p=0.07 (Jeffrey Carson, MD, MACP)

Speaker

Jeffrey Carson, MD, MACP
Principal Investigator and Study Chair
MINT Trial
Provost-New Brunswick, Rutgers Biomedical Health Sciences
Distinguished Professor of Medicine
Richard C. Reynolds, M.D. Chair in General Internal Medicine
Rutgers, Robert Wood Johnson Medical School

Keywords

Transfusion; MI; MINT; Anemia; Clinical trials

Key Points

  • Anemia is common in patients with acute MI. Due to the lack of evidence, indications for red blood cell transfusion in patients with MI are controversial. Prior to the completion of the MINT trial, three trials had compared transfusion thresholds in a total of 820 patients, and the results were inconsistent. Trials in other clinical settings suggest the use of restrictive transfusion strategy, which is a lower hemoglobin level, is safe. Most trials conducted prior to the MINT trial suggested that a restrictive transfusion strategy was comparable to a liberal transfusion strategy.
  • The MINT trial investigators looked at 30-day mortality and several outcomes including MI, heart failure, stroke, bleeding, infection, and clot. None of these relative risks or confidence intervals are significant, suggesting that you could safely use a restrictive transfusion strategy for these patients. The previous trials suggest that when you randomize people to either more or less blood, those who receive less blood get about 40% less blood overall in these studies.
  • Prior to the MINT trial, investigators detected very little difference between liberal and restrictive transfusion strategies. However, they saw very wide confidence intervals, which made it difficult to determine the best way to manage patients in this context.
  • The objective of the MINT trial was to determine whether the risk of death or MI through 30 days differed with a restrictive transfusion strategy with a hemoglobin threshold of 7 to 8 g/dL as compared to a liberal transfusion strategy with a hemoglobin threshold of 10 g/dL among patients with an acute MI and a hemoglobin concentration of less than 10 g/dL.
  • The team enrolled patients across 144 sites who fit the following criteria: 18 years or older, had an STEMI or NSTEMI, had Types 1, 2, 4b, or 4c MI, and had a hemoglobin concentration of less than 10 g/dL within 24 hours of enrollment.
  • They utilized 2 transfusion strategies, restrictive and liberal. In the restrictive strategy, transfusion was permitted, but not required, when the hemoglobin concentration was less than 8 g/dL and strongly recommended when the concentration was less than 7 g/dL or when angina symptoms were not controlled with medications. For the liberal strategy, 1 unit of packed red blood cells were administered following randomization, and red blood cells were transfused to maintain a hemoglobin concentration greater than or equal to 10 g/dL through hospital discharge or 30 days.
  • There were 3 primary limitations of the MINT trial. The assigned strategy was not masked; trial results were not adjusted for multiple comparisons; and although pre-specified, cardiac death was not designated as primary, secondary, or tertiary outcome or adjudicated.
  • The results of the MINT trial did not demonstrate a statistically significant difference in the rate of 30-day death or recurrent MI in patients with acute MI and anemia assigned to a restrictive compared to a liberal transfusion strategy. Additionally, while not statistically significant, the point estimates for the primary outcome and secondary outcomes consistently favored a liberal transfusion strategy. Finally, heart failure and other safety outcomes were comparable in the two transfusion groups.
  • In contrast to other clinical settings, the MINT trial results suggest that a liberal transfusion strategy has the potential for clinical benefit with an acceptable risk of harm and may be the most prudent approach to transfusion in anemic patients with acute MI.

Learn more

Read more about the MINT trial.

Discussion Themes

-When did you consent the patients – before or after the cath lab? We consented them as early in the hospitalization as we could. Some patients were consented before cath and others were consented after. In general, we tried not to consent patients until their hemoglobin was less than 10 in most situations. Whenever it was less than 10, then we consented them when we could get to the patient, but that varied. There was a solid mix of pre- and post- cath lab.

-Could you discuss the journal review process? Was there substantial disagreement among the authors, reviewers, and editors regarding the trial conclusions or clinical implications? There were differing opinions. One of our reviewers was incredibly helpful in helping us frame the relative risk confidence interval concepts that I described, which helped us shape the language. I think that the journal bought into that and helped us do it. It wound up being a very collaborative, constructive process. In general, I think as these things go, it was quite positive. There was some negotiation about how we would describe some of our conclusions, but overall, it was a good experience.

Tags

#pctGR, @Collaboratory1