September 22, 2020: New Article Highlights Ethical and Regulatory Challenges of Conducting PCTs

Cover of Ethics & Human ResearchA recent article in Ethics & Human Research describes the experience and management of regulatory noncompliance during the conduct of a large, multisite embedded pragmatic clinical trial (ePCT). The Trauma Survivors Outcomes and Support (TSOS), an NIH Collaboratory Trial, was a stepped-wedge, cluster-randomized clinical trial of a collaborative care intervention for injured patients with symptoms of posttraumatic stress disorder in 25 level 1 trauma centers in the United States. The article, Ethical and Regulatory Concerns in Pragmatic Clinical Trial Monitoring and Oversight, was coauthored by members of the TSOS study team, the Collaboratory’s Ethics and Regulatory Core, and colleagues.

The authors describe how the study encountered variabilities in participant tracking across sites, which led to a study-wide internal audit and corrective action. The study team implemented a revision of the participant tracking system and retrained site staff in new procedures. Based on the lessons learned, the authors offer recommendations for future PCTs and relevant stakeholders, including institutional review boards, data safety and monitoring boards, institutions, and trial sponsors.

Among the recommendations:

  • Use a single IRB of record to streamline regulatory processes and reduce variability among research sites.
  • Standardize research procedures but allow for real-world flexibility; this could include real-time, workflow-integrated study logging that captures and documents provider turnover and regulatory training compliance.
  • Implement thorough, specific, and practical training in procedures, especially around participant enrollment and tracking.
  • Ensure that research procedures, monitoring and oversight plans, and training are study specific to account for unique issues, contexts, and needs.

Thoughtful planning, communication, and development and dissemination of standardized procedures remain hallmarks of successful research operations both to advance biomedical research and to ensure appropriate safeguards for its participants. –Roberts et al.

August 21, 2020: Adaptive Platform Trials: Scalable from Breast Cancer to COVID (Laura Esserman, MD, MBA)

Speaker

Laura Esserman, MD, MBA
Director, UCSF Carol Franc Buck Breast Care Center
Alfred A. de Lorimier Endowed Chair in General Surgery
Professor of Surgery and Radiology, UCSF

Topic

Adaptive Platform Trials: Scalable from Breast Cancer to COVID

Keywords

COVID-19; Adaptive platform trial; Study design; Learning healthcare system; Collaborative research

Key Points

  • Adaptive trial design is an innovative, collaborative approach with the potential to maximize learning about treatments so as to prioritize therapeutic agents and drive better patient outcomes.
  • Adaptive platform trials are designed to identify early endpoints that can be captured in the course of care. Multiple agents are evaluated simultaneously, and those with a potential for big impact are advanced quickly.
  • As a “learning engine,” adaptive platform trials could be used to accelerate high-impact treatments for COVID-19 and future pandemics.

Discussion Themes

Essential to an adaptive platform trial are checklists of data and nimble EHR tools that evolve as the disease evolves.

What is the process to monitor for and make the decision to modify the standard of care backbone?

Read more about adaptive platform trials at the I-SPY Trials website and a recent Grand Rounds presentation, Optimized Learning While Doing: The REMAP-CAP Adaptive Platform Trial.

Tags

#pctGR, @Collaboratory1

August 14, 2020: Learning While Sprinting: A One-Year Retrospective from the NOHARM Pragmatic Trial (Jon Tilburt, MD; Andrea Cheville, MD)

Speakers

Jon Tilburt, MD
Professor of Medicine and Biomedical Ethics
Mayo Clinic

Andrea Cheville, MD
Professor of Physical Medicine and Rehabilitation
Mayo Clinic

Topic

Learning While Sprinting: A One-Year Retrospective from the NOHARM Pragmatic Trial

Keywords

PRISM; NIH Heal Initiative; NOHARM; Postoperative care; Nonpharmacologic pain care (NPPC); Stepped wedge; Cluster-randomized trial; Electronic health records (EHRs); Patient engagement; Clinical decision support

Key Points

  • The Nonpharmacologic Options in Postoperative Hospital-based and Rehabilitation Pain Management (NOHARM) NIH Collaboratory Trial is completing its pilot phase. This embedded, stepped-wedge PCT will test a sustainable strategy in perioperative, nonpharmacologic pain management that preserves patient function, honors patient values, and maintains the availability of opioids as a last resort.
  • NOHARM is a pragmatic, EHR-integrated intervention that bundles a portal-based conversation guide that captures patient preferences for postsurgical pain care and a clinician-directed decision support tool.
  • Nonpharmacologic pain care management options include walking, yoga, tai chi, acupressure, massage, meditation, and relaxation.

Discussion Themes

Opioids are insufficient in postsurgical care. Guidelines recommend nonpharmacologic pain care (NPPC), but there have not been studies showing how to make NPPC more viable.

The COVID-19 pandemic caused disruption in scheduled surgeries and also air travel, which precluded on-the-ground support at two study sites. However, the team was able to adjust recruitment methods during the pilot phase.

What was the team’s proactive process in working with the IRB in order to obtain a waiver of consent?

The NOHARM intervention has sustained high-level institutional support despite the impact of COVID-19.

Read more about the NOHARM NIH Collaboratory Trial.

Tags

#pctGR, @Collaboratory1

April 24, 2020: The RECOVERY Trial: A UK National Platform Trial of Potential Treatments for Patients Hospitalised with COVID-19 (Martin Landray, PhD, FRCP)

Speaker

Martin Landray, PhD, FRCP
Professor of Medicine & Epidemiology
Nuffield Department of Population Health
University of Oxford, UK

Topic

The RECOVERY Trial: A UK National Platform Trial of Potential Treatments for Patients Hospitalised with COVID-19

Keywords

Coronavirus; Virus pandemic; COVID-19; SARS-CoV-2; RECOVERY Trial; Randomized trial; Epidemiology

Key Points

  • Between March 10 and April 3, 2020, the RECOVERY team developed the protocol, obtained regulatory and ethics approval, and enrolled 1,000 patients.
  • COVID-19 presents an unprecedented clinical challenge to the health system, staff, and patients. Even moderate effects from this study will be worthwhile in the generation of robust evidence.
  • RECOVERY follow up will involve linkage to national data sources for vital status and death certificates; coded hospital episode statistics (diagnoses, procedures); intensive care audit data and SARS-CoV-2 PCR laboratory results; and primary care and national outpatient prescribing data.

Discussion Themes

Informed consent for participants in the RECOVERY trial consists of a 2-page information sheet and single form written in plain language.

The urgency of this pandemic requires everyone to focus on what matters and leave orthodoxy, habits, and traditional practices behind. Our mindset has been altered by the COVID-19 disruptions and this public health crisis of extraordinary proportion.

For more information, visit the RECOVERY Trial website.

Tags
#pctGR, #COVID19, @Collaboratory1

February 28, 2020: Meeting Minutes from NIH Collaboratory’s Ethics and Regulatory Core Discussions with the PRISM NIH Collaboratory Trials

Meeting minutes and supplementary materials are available that summarize discussions related to the ethics and regulatory issues associated with each of the UG3 PRISM NIH Collaboratory Trials. 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.

November 1, 2019: NIH Collaboratory: Looking Back, Looking Forward (Adrian Hernandez, MD, MHS, Lesley Curtis, PhD, Kevin Weinfurt, PhD)

Speakers

Adrian F. Hernandez, MD, MHS
Professor of Medicine
Vice Dean for Clinical Research
Duke University School of Medicine

Lesley H. Curtis, PhD
Chair and Professor
Department of Population Health Sciences
Duke University School of Medicine
Interim Executive Director, Duke Clinical Research Institute

Kevin Weinfurt, PhD
Professor and Vice Chair of Research
Department of Population Health Sciences
Duke University School of Medicine

Topic

NIH Collaboratory: Looking Back, Looking Forward

Keywords

Embedded pragmatic clinical trials; ePCTs; NIH Collaboratory; Health care systems research; NIH Collaboratory Trials; Living Textbook; HEAL Initiative; Coordinating Center; Research dissemination; Learning health systems; Real-world evidence

Key Points

Discussion Themes

How can we harmonize the different ideas about what it is to be “pragmatic” for NIH study sections, IRBs, and DSMB reviews? For example, if your DSMB isn’t knowledgeable about PCTs, you could end up with a very explanatory trial.

A willingness to share imperfections is an important part of learning and helps the clinical trial ecosystem evolve.

An important future topic would be how the NIH Collaboratory and PCORnet fit together.

Read more about the NIH Collaboratory Program and the Living Textbook of Pragmatic Clinical Trials.

Tags
#pctGR, #PragmaticTrials, @Collaboratory1, @texhern, @lmhcurtis, @KevinWeinfurt

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 Trial, 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 Trials.

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 NIH Collaboratory Trials

Meeting minutes and supplementary materials are available that summarize discussions related to the ethics and regulatory issues associated with each of the new UG3 NIH Collaboratory Trials. 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.