September 7, 2022: This Week’s Grand Rounds Kicks Off Special Series on Ethical and Regulatory Issues in Pragmatic Trials

Steven Joffe, MD, MPH
Dr. Steven Joffe

In this Friday’s PCT Grand Rounds, Dr. Steve Joffe will kick off our special Grand Rounds series, Ethical & Regulatory Dimensions of Pragmatic Clinical Trials, with a keynote presentation, “Building an Academic Learning Health System: Why Is It So Hard?” The Grand Rounds session will be held on Friday, September 9, 2022, at 1:00 pm eastern.

Dr. Joffe is a pediatric oncologist and bioethicist who is currently the Art and Ilene Penn Professor of Medical Ethics & Health Policy and Professor of Pediatrics at the University of Pennsylvania Perelman School of Medicine.

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This special Grand Rounds series will include an additional 5 moderated webinar discussions with panels of experts. The sessions will focus on a range of topics, including responding to signals of mental and behavioral health risk in pragmatic trials; the ethics of data sharing; ethical and regulatory considerations in the design and conduct of pragmatic trials; pragmatic research involving patients with dementia; and the use of waivers and alterations of consent. Read the full program.

August 30, 2022: FDA Announces Webinar on Patient-Focused Drug Development Draft Guidance

FDA logoThe US Food and Drug Administration (FDA) will host a webinar on September 9 for industry, patient groups, and other interested stakeholders to discuss and answer questions about the draft guidance, Patient-Focused Drug Development: Selecting, Developing, or Modifying Fit-for-Purpose Clinical Outcome Assessments.

The draft guidance, known as “Guidance 3,” is the third of 4 methodological guidance documents for patient-focused drug development that describe how patients, caregivers, researchers, medical product developers, and others can collect and submit patient experience data and other relevant information to be used for medical product development and regulatory decision making. Guidance 3 discusses approaches to selecting, modifying, developing, and validating clinical outcome assessments to measure outcomes of importance to patients in clinical trials.

Register for the webinar at https://www.eventbrite.com/e/public-webinar-patient-focused-drug-development-pfdd-draft-guidance-3-tickets-397246183027.

June 24, 2022: FDA Draft Guidance on Real-World Evidence (John Concato, MD, MS, MPH)

Speaker

John Concato, MD, MS, MPH
Associate Director for Real-World Evidence Analytics
Office of Medical Policy (OMP)
Center for Drug Evaluation and Research (CDER)
Food and Drug Administration (FDA)

 

 

Keywords

Big data; Real-word evidence; Real-world data; 21st Century Cures Act; FDA Draft Guidance

 

Key Points

  • Big Data, a term first used in the 1990s, leverages modern technology to increase the quantity, forms, speed, and capability to manipulate large-scale data. Real-world data (RWD) is a term with specific regulatory implications referring to health care data routinely collected from a variety of sources. Real-world evidence (RWE) is clinical evidence derived from analysis of RWD regardless of study design.
  • Terminology is important in research work, and we should strive to be as precise as possible with the terminology we use.
  • With the 21st Century Cures Act of 2016, the FDA established a program to evaluate the potential use of real-world evidence to support new indications for drugs and satisfy post-approval study requirements.
  • In 2021, the FDA issued 4 draft guidance documents for Real-world data and Real-world evidence intended to guide the selection and management of data sources to appropriately address the study question and support decision-making for drug and biological products.

Discussion Themes

– Could real-world data sources be certified and preclude the need for submission of source data on a study specific basis? From the FDA point-of-view, while reliability can be more readily evaluated and would tend to be more stable, the relevance to a particular study could not be determined as easily.

– While there can be a reflex that says we can never be sure about major confounding, it should not be the miasma of the 21st century. A thoughtful approach that considers the characteristics that matter is the best approach.

 

Read Dr. Concato’s publication Randomized, observational, interventional, and real-world—What’s in a name? and the FDA Draft Guidance for RWD/RWE.

Tags

#pctGR, @Collaboratory1

June 23, 2022: Ethics and Regulatory Core Aims for Better Design and Improved Implementation

In an interview at the NIH Pragmatic Trials Collaboratory's annual Steering Committee meeting and 10th anniversary celebration, we asked Drs. Jeremy Sugarman and Pearl O'Rourke to discuss the role of the Ethics and Regulatory Core in helping the NIH Collaboratory Trial teams plan and implement their pragmatic trials, and the contributions the Core has made to the literature on ethics and regulatory challenges in pragmatic clinical research.

Headshot of Dr. Jeremy SugarmanBased on your experience working with the NIH Collaboratory Trials, what are some of the common challenges of the Core?

A common challenge the NIH Collaboratory Trial investigators face is determining their study’s level of risk, specifically whether the research is determined to be “minimal risk.” This issue is important, because it influences the permissibility of using alternatives to conventional written informed consent, such as waiving consent or waiving the requirement to document consent.

A recent focus of the Ethics and Regulatory Core is the challenge some studies face with “collateral findings.” These are findings, whether discovered intentionally or unintentionally, that don’t address the trial’s research questions, but may have implications for the health of patients in the trial. For example, when collecting data from electronic health records, researchers might detect the possible use of contraindicated medications in some patients. We recently completed a multimethod investigation of the ethical and regulatory implications of collateral findings in pragmatic clinical trials.

The Core has also offered advice and guidance on several other issues, including innovative study designs such as cluster randomization and stepped-wedge designs, data and privacy issues, collaborating and communicating with healthcare system representatives and clinicians, and challenges related to conducting research at multiple sites.

Headshot of Dr. Pearl O'Rourke

What strategies have NIH Collaboratory Trials used to overcome these barriers?

The Ethics and Regulatory Core hosts an initial consultation with each NIH Collaboratory Trial in the planning phase, and then a follow-up consultation when the project transitions to the implementation phase. We also invite the study teams to consult with us to help address any ethical challenges they’re facing. Sometimes these consultations result in changes in study design, partnerships with the Core to nest empirical ethics studies within the NIH Collaboratory Trials, and other approaches.

How are the NIH Collaboratory Trials’ experiences with the Core helping the field of pragmatic research?

The Core’s work with the NIH Collaboratory Trials has created a body of knowledge and guidance that we have made available to help those engaged in pragmatic research. In addition to a series of published articles in the peer-reviewed literature, we have included some related content in the Living Textbook of Pragmatic Clinical Trials.

Can you describe the impact the Core has had on pragmatic trials over the past decade?

The Core’s consultations during the development stage of these trials has improved investigators’ understanding, appreciation, and planning for the relevant ethical and regulatory issues. The result has hopefully been better research design and improved implementation. Likewise, routine conference calls with active studies have provided opportunities for investigators to hear about the challenges encountered and the solutions developed by other study teams. Sharing these experiences has been invaluable.

The Core is available for ad hoc consultation regarding the ethical and regulatory issues facing any of the projects. Such issue-specific consultations hopefully help study teams develop appropriate solutions.

Finally, Core members have generated a substantial amount of empirical and conceptual scholarship related to the ethical and regulatory issues encountered in the NIH Collaboratory. This work is helping to expand understanding of pragmatic clinical research for the broader research community.

What do you think the Core can contribute over the next decade?

The Core’s ongoing consultations during all phases of the NIH Collaboratory Trials will promote improvements to research protocols and offer real-time check-ins for unanticipated challenges. Our regular conference calls, contributions to the Living Textbook, and scholarly publications will continue to provide an important resource for investigators as well as IRBs.

June 6, 2022: Bioethics Supplement to Address Data Sharing and Pragmatic Clinical Trials

In an interview at the NIH Pragmatic Trials Collaboratory Steering Committee’s annual meeting in April, Dr. Stephanie Morain shared information about a bioethics supplement designed to explore the ethical issues that arise in the context of pragmatic clinical trials (PCTs) and data sharing.

 

“Our goal with the supplement is to identify the ways in which existing policies to promote data sharing do or do not align with the specific needs of pragmatic clinical trials.”

The activities of the bioethics supplement are to:

  • Conduct a systematic literature review to identify the specific features PCTs that may alter the risk-benefit calculus for data sharing as compared to explanatory trials & other settings with ethically relevant similarities
  • Through stakeholder interviews, explore data sharing in PCTs as understood by those responsible for the oversight, generation, dissemination, and future use of PCT data
  • Evaluate existing and proposed policies and guidance to promote data sharing.

Dr. Morain is a member of the Ethics and Regulatory Core of the NIH Pragmatic Trials Collaboratory, and this work is part of an overarching goal to develop approaches to the ethical design and conduct of pragmatic clinical trials.

Read Dr. Morain’s presentation on the Bioethics Supplement given at the Steering Committee Meeting in April.

Headshot of Dr. Stepanie Morain
Dr. Stepanie Morain

May 11, 2022: MOTIFS Investigation of Collateral Findings in Pragmatic Trials Will Be Featured in PCT Grand Rounds

Head shots of Dr. Jeremy Sugarman, Dr. Stephanie Morain, Juli Bollinger, and Dr. Kevin WeinfurtIn this Friday’s PCT Grand Rounds, Dr. Jeremy Sugarman, Dr. Stephanie Morain, and Juli Bollinger of Johns Hopkins University and Dr. Kevin Weinfurt of Duke University will present “Ethics and Collateral Findings in Pragmatic Clinical Trials: Implications of a Multi-Method Exploration.” The Grand Rounds session will be held on Friday, May 13, at 1:00 pm eastern.

The team will present lessons from MOTIFS, a recently completed multi-method investigation of the ethical and regulatory implications of “collateral findings” in pragmatic clinical trials.

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May 4, 2022: Ethics Core Members Pen Guest Editorial for AJOB Focus on Machine Learning in Healthcare

In a guest editorial in the American Journal of Bioethics, members of the NIH Pragmatic Trials Collaboratory’s Ethics and Regulatory Core introduced the issue’s target article and peer commentaries on artificial intelligence and machine learning in healthcare. Prof. Kayte Spector-Bagdady and Drs. Vasiliki Rahimzadeh and Kaitlyn Jaffe, who are Core members, were joined by coauthor Dr. Jonathan Moreno in writing the editorial.

The target article of the themed collection proposes a research ethics framework for the clinical translation of healthcare machine learning. In several peer commentaries accompanying the article, experts offer their perspectives on the proposed framework, including critiques of “the insufficiency of current ethics and regulatory solutions to adequately protect communities at higher risk for [machine learning] bias.”

Read the full editorial, “Promoting Ethical Deployment of Artificial Intelligence and Machine Learning in Healthcare.” Learn more about our Ethics and Regulatory Core.

March 1, 2022: BeatPain Utah Has New Study Snapshot, Updated Ethics and Regulatory Documentation

BeatPain Utah logoA downloadable study snapshot and updated ethics and regulatory documentation are now available for BeatPain Utah, an NIH Pragmatic Trials Collaboratory Trial.

BeatPain Utah recently transitioned from the planning phase to the implementation phase. As part of the transition, the study team reviewed and updated the minutes of their initial ethics and regulatory consultation with the Ethics and Regulatory Core. The project is studying real-world implementation of a telehealth physical therapy strategy for patients with chronic back pain in primary care clinics of federally qualified health centers.

  • Also available is a new study snapshot for BeatPain Utah. This downloadable handout summarizes the study’s aims, lessons from the planning phase, and links to other resources from this innovative pragmatic clinical trial.

BeatPain Utah is supported by the NIH through the NIH Heal Initiative under an award from the National Institute of Nursing Research.

January 20, 2021: New Article Explores Ethical Obligation to Monitor Signals of Behavioral and Mental Health Risk in Pragmatic Trials

In a new Contemporary Clinical Trialslsarticle, members of the Ethics and Regulatory Core of the NIH Pragmatic Trials Collaboratory explore the ethical obligation of investigators to address signals of behavioral and mental health risk in pragmatic clinical trials.

The article was published online ahead of print in Contemporary Clinical Trials and will appear in a forthcoming special issue on pragmatic and virtual trials.

Some pragmatic trials collect sensitive data that could signal distress, such as suicidal ideation, opioid use disorder, or depression. Investigators have an ethical obligation to monitor these signals and identify in advance if, when, and how such signals will trigger a response. Using examples from the NIH Collaboratory Trials, the authors offered preliminary recommendations and identified opportunities for future work.

The NIH Collaboratory Trials discussed in the article are supported by the PRISM program—Pragmatic and Implementation Studies for the Management of Pain to Reduce Opioid Prescribing. The projects are studying the real-world effectiveness of nonpharmacologic interventions to improve pain management and reduce reliance on opioids.

Read the full article.

The PRISM program is a part of the Helping to End Addiction Long-Term Initiative℠, or NIH HEAL Initiative℠. The NIH Pragmatic Trials Collaboratory Coordinating Center serves as the PRISM Resource Coordinating Center.

December 15, 2021: This Friday in PCT Grand Rounds, Cybersecurity and Compliance in Clinical Research and Healthcare

Headshot of Dr. Eric Perakslis
Dr. Eric Perakslis

In this Friday’s PCT Grand Rounds, Dr. Eric Perakslis of Duke University will present “Cyberthreat, Cybersecurity and Cyber Compliance in Clinical Research and Healthcare: One Size Fits None.” The Grand Rounds session will be held on Friday, December 17, at 1:00 pm eastern.

Dr. Perakslis is the chief science and digital officer for the Duke Clinical Research Institute and the chief research technology strategist in the Duke University School of Medicine. Join the online meeting.