How to Implement an ePRO Strategy: A Best Practice Guide Frans Wald
Transcription
How to Implement an ePRO Strategy: A Best Practice Guide Frans Wald
How to Implement an ePRO Strategy: A Best Practice Guide Frans Wald Head Global Clinical Trial Support Boehringer Ingelheim Pharma GmbH . 26th Annual EuroMeeting 25-27 March 2014 ACV, Vienna Austria Disclaimer The views and opinions expressed in the following PowerPoint slides are those of the individual presenter and should not be attributed to Drug Information Association, Inc. (“DIA”), its directors, officers, employees, volunteers, members, chapters, councils, Special Interest Area Communities or affiliates, or any organization with which the presenter is employed or affiliated. These PowerPoint slides are the intellectual property of the individual presenter and are protected under the copyright laws of the United States of America and other countries. Used by permission. All rights reserved. Drug Information Association, DIA and DIA logo are registered trademarks or trademarks of Drug Information Association Inc. All other trademarks are the property of their respective owners. Authors of Best Practice Guide Dr. Daniel Eek PRO Senior Scientist AstraZeneca R&D Molndal Dr. Karoly Kulich PRO Director Novartis – Basel Dr. Frans Wald Head Global Clinical Trial Support Boehringer Ingelheim Pharma GmbH & Co.KG Martin Wurm Head of eClinical Trial Services Global Clinical Trial Support Boehringer Ingelheim Pharma GmbH & Co. KG 3 Overview • How ePRO/eCOA Changes Internal Processes • Advantages of Centralized Knowledge • How to Implement an ePRO Strategy 4 Stakeholders for transition to ePRO • PRO Team / Health Economics • Clinical Operations • Biometrics, Programming, DM • Regulatory / Quality Management • Sourcing • IT 5 Some Advantages of ePRO • Meets recommendations of regulatory guidances for claims. • Improves patient compliance with scheduled completion of diaries. • Reduces missing information • Increases accuracy data with automatic timestamps & prevents retrospective entry • Designed so that patients cannot leave incomplete items. 6 Some Disadvantages to ePRO • ePRO data collection may require a higher initial cost compared with paper PRO. • Trial teams have limited time to document or capture knowledge or lessons learned from (e)PRO trials. • Trial setup with ePRO requires that all data issues be resolved prior to FPI 7 Differences when collecting PRO or ePRO Data Endpoints • Proof that each instrument is ‘fit for context of use’ if data are submitted for a labeling claim • New questionnaire validations and translations • Diary translations • Cognitive debriefs for existing paper PRO instruments • IRB or EC approval for patient material • Potential risk that the developer of a PRO tool will request an equivalency study. Equivalency testing for layout, patient acceptance and psychometric properties can be costly and take up to a year. • FDA guidelines 8 ePRO Requires a Change in Processes and Personnel 9 Various Regulation Mandates for ePRO • FDA Guidance: PRO Measures • EMA Reflection Paper • EU respective government laws • ICH Technical Requirements for Registration of Pharmaceuticals for Human Use 10 Industry ePRO Standards & Recommendations • CDISC • Critical Path Institute (C-Path) • PRO Consortium • Internat. Society for Pharmacoeconomics and Outcomes Research (ISPOR) 11 Rules for Exchange of Electronic Records • eSource data governed by Guidances & Regulations • ePRO data are eSource data, meeting all requirements Additional Rules for Exchange of Electronic Records • • • • • • 21 Code of Federal Regulations (CFR) Part 11 Organisation for Economic Co-operation and Development EU Data Protection Directive Health Insurance Portability and Accountability Act (HIPAA) Act of the Protection of Personal Information (Japan) Asia-Pacific Economic Cooperation framework mandate for personal data protection 12 4 Key process modifications Paper PRO ePRO Data Paper diary translations Collection Paper diary duplication & shipping Site personnel and patient training, User acceptance testing of the ePRO device Software programming to include logical branching, randomization and other devicelevel calculations. Specify Data Clarification Form (DCF) Data conditions and process Managem Specify how entry errors will be managed ent Determine the transcription process from paper to the database Define source data, especially when Data someone completes a diary on behalf of a Analysis patient Determine when analysis can begin after last patient out (LPO) Determine how trial data will be pooled with other clinical data. Reporting Anticipate when reporting can begin Specify DCF conditions and process Specify electronic data transfer formats Clarify data transmission and transfer frequencies. Define how often interim analysis will be conducted to determine enrollment, compliance and power achievements Determine how trial data will be pooled with other clinical data. Train site and trial personnel on how to access real-time data online 13 FDA Roadmap Specifies Process 14 Advantages of a Centralized Knowledge Center Health Economi cs Clinical Ops IT • Global project team dealing with ePRO & eDevices Regulato • Sponsored by ry senior management ePRO Team Biometry Program ming DM Sourcing 15 Quality Mngt Main Goals and Tasks • Global single point of contact for all trial teams & vendors together with key stakeholders • Support all trial teams in managing the ePRO/eDevices related tasks Preparation • Selection of device & vendor • Prepare & review documents • Logistics • Training Conduct • Questions • Software Updates • Issues • Escalation Close-out • Database lock • Return of Equipment • Lessons Learned Main Goals and Tasks • Save cost and time in implementing standards Build up ePRO/eDevices Working Groups for each Therapeutic Area to create Company standards Standardize and implement processes and documents together with working groups resulting in shorter timelines and reduced complexity • Create and maintain knowledge base and lessons learned • Increased utilization of ePRO instead of paper • Find innovative solutions for new requirements and requests (e.g. FDA, special measurements in studies) Therapeutic Area Team • Functional sub teams formed for specific topics: Data Management, Training Options, Standardization of e.g Respiratory Documents • Main Outcomes: – Pre-selecting devices & preferred vendors – Standardization of documents (User Acceptance Testing, Data Management Plan, …) – Adaptation and enhancement of eLearning from Vendor – Definition of KPIs and Governance & Escalation Structure – Start-Up Package for CMs Experts Select Devices • Screen is large enough to display entire question and answers, to avoid possible scrolling bias. • Screen is large enough in height and width to accommodate translations, especially of voluminous languages such as German • Screen is bright and clear with legible text, numbers, buttons and scales. • The exact device selected will be available throughout trial duration, in order to avoid mid-study delays with cognitive debriefs. • Device has sufficient memory to host all diaries and questionnaires required of protocol. 19 Experts Select Devices, based on Critical Provider Requirements Data Management Data Security Flexible Data Change Process and Workflow? Consistency checks executed by provider? Integration with other eClinical Systems? Server Uptime Number of Redundant Servers Does the Device perform a Quality Check upon Data Transfer? Data Transfer options SAS, SASII, ASCII, SDTM, ‘Normalized’ tables and Oracle Clinical® formats? Device Are purchase and lease options available? Global Transmissions Management Global Trial Experience Type of transmission options: 3G WiFi, Internet, Analog Number of Sites which have used the vendor's ePRO system Is Logistics Management Are Regional Distribution in-house or contracted? Depots Available? Transmission Metrics Transmission experience in a given country – which option works best Number of Languages Number of Countries which have been used in which have used the the vendor's ePRO vendor's ePRO system – system 20 Additional Considerations • PRO/ePRO Questionnaires – • Modifying a paper diary or questionnaire to ePRO requires evidence to confirm the new instrument’s adequacy Vendor should provide an eDiary Design Tool – IRB and EC require screen shots or other similar instrument representations. • Mixing ePRO devices – fine • Switching ePRO devices – disastrous! 21 Some Recommendations • Lead by a team, not a single individual • Centralize the ePRO team • Retain and archive lessons learned and operational intelligence collected from ePRO trials • Establish PRO competence before implementing ePRO process • Enable ePRO to be the default mode of PRO data collection 22 Questions? How to implement an ePRO Strategy: A Best Practices Guide http://bit.ly/1adF1Cd 23