June 20, 2019: EMBED Investigators Discuss Progress and Transition to Implementation Phase

At the May 2019 meeting of the NIH Collaboratory Steering Committee, we talked with Drs. Ted Melnick and Gail D’Onofrio of EMBED, an NIH Collaboratory Demonstration Project, to hear about progress and challenges during the UG3 planning phase. The goal of EMBED is to test whether implementation of a user-centered clinical decision support system increases adoption of initiation of buprenorphine/naloxone into the routine emergency care of patients with opioid use disorder. In the UG3 phase, the study team put in place the infrastructure of a pragmatic, multicenter, parallel, group-randomized health IT intervention. EMBED recently transitioned to the UH3 implementation phase and plans to launch the intervention at 20 sites across 5 healthcare systems in August 2019.

“With EMBED, we’re trying to take evidence-based research and implement it to improve practice. EMBED is both a research and patient care project.”

Were there any surprises during the study’s planning phase?

The first surprise came at last year’s Steering Committee meeting, when we met with the Biostatistics and Study Design Core. They encouraged us to change our original study design from stepped-wedge to group-randomized, which we did. We think this advice led to a stronger study. The main reason for this is the group-randomized design’s ability to better account for temporal changes. Since our intervention is being conducted in the middle of an opioid crisis, there are potentially other concurrent interventions that could make it difficult to determine the effect of our intervention. The group-randomized design should give us better insight into whether our intervention is driving behavior change in treating patients with opioid use disorder.

What is an example of a challenge that you were able to overcome with the help of a Core Working Group?

In addition to design advice from the Biostatistics Core, we received expert guidance from the Ethics and Regulatory Core, who helped us prepare for the central IRB process. The Core’s input was essential to how we developed our protocol’s waiver of informed consent, data handling, and protection of patient privacy. We were able to demonstrate to the IRB that our approach was logical and informed. We think this helped the IRB “get it” and allowed us to more efficiently address patient privacy issues in a vulnerable population across multiple healthcare systems.

What other key challenges have you faced?

One challenge was on the IT side with electronic health record (EHR) integration, which required more customization than we initially planned. How we work with EHR vendors is evolving, and we’ve found good partners so that we can integrate across different systems. This has strengthened our intervention so that it is perceived as more universal than one designed only for a specific EHR system.

Another challenge is the general under-resourcing of healthcare delivery systems for pragmatic research. We found that, regardless of budget, getting approval from system leadership for an IT change is often not enough—what is needed is figuring out who is going to make the change, how much time is involved, and whether the team has the bandwidth to complete the task. You cannot underestimate the degree of difficulty a change poses to a health system that is still struggling to get the clinical side of things right.

The way a study is framed to leadership is important—understand what’s motivating them to participate and move a project forward. With EMBED, we’re trying to take evidence-based research and implement it to improve practice. EMBED is both a research and patient care project. We need to impress upon leadership that we can improve patient outcomes and we’ll pay for it, but we need their help and support in navigating the process through the institution.

What words of advice do you have for investigators conducting their first embedded PCT?

  • Study teams should think about potential barriers from the beginning and find solutions quickly.
  • Make sure that health system leadership discusses your project with those on the ground.
  • Enlist the experts your study needs for each site. In our case, we needed both an IT expert for the operational side and a clinical expert, or we couldn’t have moved the project forward.
  • Recognize that there are trade-offs in pragmatic design and remember that you’re working with health systems in which your intervention will need to be replicated.
  • Make your intervention sustainable and easily usable by the clinician, without the need for research or other additional staff.

EMBED is supported within the NIH Collaboratory by a cooperative agreement from the National Institute on Drug Abuse and receives logistical and technical support from the NIH Collaboratory Coordinating Center. Read more about EMBED in the Living Textbook, and learn more about the NIH Collaboratory Demonstration Projects.

June 14, 2019: Good Clinical Practice Guidance and Pragmatic Trials: Balancing the Best of Both Worlds in the Learning Health System (Robert Mentz, MD)

Speaker

Robert J. Mentz, MD, FACC, FAHA, FHFSA
Associate Professor
Director, Duke Cooperative Cardiovascular Society
Associate Program Director, Duke Cardiovascular Disease Fellowship
Duke University Medical Center and Duke Clinical Research Institute

Topic

Good Clinical Practice Guidance and Pragmatic Trials: Balancing the Best of Both Worlds in the Learning Health System

Keywords

International Council for Harmonization (ICH); Good clinical practice (GCP); Learning health system; Pragmatic clinical trials; Institutional review board (IRB); Research oversight; Regulatory issues; Quality by design (QbD)

Key Points

  • Good clinical practice (GCP) guidance details the responsibilities, procedures, and recording that are necessary for appropriate trial conduct; for example, conducting the trial in accordance with an IRB-approved protocol with appropriate adverse event monitoring and reporting.
  • There is an urgent need to streamline randomized trials. Key obstacles are lack of transparency, lack of representativeness, and lack of evidence of competence.
  • In the United States, clinical investigators must abide by guidance from FDA, HHS, and ICH-GCP. Yet it is hard for investigators to keep track and to know how GCP applies to their study.
  • GCP as an overall construct is useful, but it does not deal well with issues particular to pragmatic trials or trials outside the FDA-regulated world.

Discussion Themes

With embedded pragmatic trials, informed consent is more nuanced. New considerations and approaches for consent have arisen since ICH GCP first came into effect.

Establishing quality by design will take time, effort, and educating IRBs to understand how QbD can be used to avoid errors in a trial and collect data that is fit-for-purpose.

It’s crucial that trials address an important question, answer that question reliably, and keep participants safe.

Read more about Dr. Mentz’s study of GCP and pragmatic trials.

Tags

#pctGR, @Collaboratory1, @RobMentz

October 1, 2018: Meeting Minutes from NIH Collaboratory’s Ethics and Regulatory Core Discussions with the New Demonstration Projects

Meeting minutes and supplementary materials are available that summarize discussions related to the ethics and regulatory issues associated with each of the new UG3 Demonstration Projects. These discussions, which took place by teleconference, included representation from study principal investigators and study teams, members of the NIH Collaboratory Ethics and Regulatory Core, NIH staff, and NIH Collaboratory Coordinating Center personnel as well as some IRBs responsible for oversight of the projects.

January 18, 2018: Implementation of Revised Common Rule Delayed

On January 17, 2018, the Department of Health and Human Services and 15 other federal departments and agencies announced a delay to both the effective and compliance dates for the revisions to the “Federal Policy for the Protection of Human Subjects” (also known as the Common Rule). Most provisions in the revised Common Rule were scheduled to go into effect on January 19, 2018. The Interim Final Rule announced a delay until July 19, 2018, with the option for further delay, to give institutions additional time to prepare to implement the revisions. Before July 19, 2018, institutions may only begin implementing provisions of the revised Common Rule that do not conflict with the pre-2018 Common Rule.

A notice of proposed rulemaking (NPRM) is also in development to seek public comment on a proposal for further delay in the required implementation of the revised Common Rule (for example, until January 21, 2019). A decision will be made after considering public comments.

November 20, 2017: NIH Collaboratory Core Working Group Interviews: Reflections from the Ethics and Regulatory Core

We recently asked Drs. Jeremy Sugarman and Kevin Weinfurt, Co-chairs of the Ethics and Regulatory Core, to reflect on the first 5 years of the Core as well as on the challenges ahead. The regulatory and ethical landscape for pragmatic clinical trials was not well defined when the Core began 5 years ago, and the Core helped to map and navigate the emerging landscape to enable the implementation of Demonstration Projects in ways that satisfied ethical and regulatory criteria.

“The Core’s work has led to the creation of a substantial body of scholarship contributing to the ongoing policy and ethics debates about pragmatic clinical trials.” – Drs. Sugarman and Weinfurt

Download the interview (PDF).

NIH & FDA seek feedback on new clinical trial protocol template


As part of their ongoing effort to improve the speed and efficiency of conducting clinical trials, the NIH-FDA Joint Leadership Council has created a draft clinical trial protocol template. The template contains instructional and sample text intended to assist NIH-funded investigators in writing protocols for phase 2 or 3 clinical trials that require Investigational New Drug (IND) or Investigational Device Exemption (IDE) applications. Feedback is sought from investigators, investigator-sponsors, institutional review board members, and other stakeholders involved in protocol development and review.

Our goal is to provide an organized way for creative investigators to describe their plans so that others can understand them. – Dr. Pamela McInnes, NIH

Details on the rationale and development of the protocol template are on these blog posts:

Notice Number: NOT-OD-16-043. Responses accepted through April 17, 2016.

You can access the template document as well as a template shell, comment form, and other resources at NIH’s Clinical Research Policy website.

CTSA-PCORnet Webinar: A Central IRB Approach


The webinar copresented on March 2, 2016, by the Clinical and Translational Science Awards (CTSA) program and PCORnet is available as a video and slideset.

Petra Kaufmann, MD, MSc
Director, Office of Rare Diseases Research and Division of Clinical Innovation
National Center for Advancing Translational Sciences
National Institutes of Health

Rachael Fleurence, PhD
Program Director, CER Methods and Infrastructure Program
Patient-Centered Outcomes Research Institute

Sabune J. Winkler, JD
Director, Regulatory Affairs Operations
Harvard Catalyst

Webinar details:
March 2, 2016
3pm - 4pm ET
To join the WebEx, click here: http://bit.ly/1TGRTFS
Call-in number: 1-855-244-8681
Access code: 737 807 582

New Lessons Learned Document Draws on Experiences of Demonstration Projects

The NIH Collaboratory’s Health Care Systems Interactions Core has published a document entitled Lessons Learned from the NIH Health Care Systems Research Collaboratory Demonstration Projects. The Principal Investigators of each of the Demonstration Projects shared their trial-specific experience with the Core to develop the document, which presents problems and solutions for initiation and implementation of pragmatic clinical trials (PCTs). Lessons learned are divided into the following categories: build partnerships, define clinically important questions, assess feasibility, involve stakeholders in study design, consider institutional review board and regulatory issues, and assess potential issues with biostatistics and the analytic plan.

Other tools available from the Health Care Systems Interactions Core include a guidance document entitled Considerations for Training Front-Line Staff and Clinicians on Pragmatic Clinical Trial Procedures and an introduction to PCTs slide set.

OHRP Offers Webinars on Proposed Revisions to the Common Rule


The Office for Human Research Protections (OHRP) has posted a series of six webinars explaining the recent Notice of Proposed Rulemaking (NPRM) regarding revisions to the Common Rule (the federal policy for human subjects protection). The presentations by policy experts can be viewed anytime; they cover the following topics:

  • Overview of the NPRM
  • Exclusions and exemptions
  • Informed consent
  • IRB review and operations
  • Research with biospecimens
  • Secondary research use of data

For more information on the NPRM, visit the OHRP website. The deadline for comments on the proposed revision has been extended to January 6, 2016.


Special Issue Published on Ethical & Regulatory Complexities of Pragmatic Clinical Trials


Tools for ResearchA new series of 12 articles published in a special issue of the journal Clinical Trials addresses ethical and regulatory challenges particular to pragmatic clinical research. Pragmatic clinical trials are designed to efficiently provide answers to important clinical questions, yet they present special challenges in conforming to the ethical and regulatory guidelines that were developed for more traditional clinical research. The special issue describes these challenges and begins to outline possible solutions that will protect the rights and welfare of research participants while allowing pragmatic clinical trials to gather much-needed evidence for informing healthcare decisions. An introductory article is followed by 11 articles addressing individual topics, such as alteration of informed consent, privacy, gatekeepers, and defining minimal risk research. The effort was funded by the NIH Health Care Systems Research Collaboratory, with additional support from the Patient-Centered Outcomes Research Institute (PCORI), and involved diverse groups of stakeholders, including researchers, patient advocates, bioethicists, and regulatory experts. Robert M. Califf, MD, and Jeremy Sugarman, MD, MPH, were editors of the special issue.

For more information: