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Clinical Trial Timelines

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Presentation on theme: "Clinical Trial Timelines"— Presentation transcript:

1 Clinical Trial Timelines
Cornelia Kamp, MBA Executive Director Strategic Initiatives Clinical Materials Services Unit (CMSU) Clinical Trials Coordination Center (CTCC) University of Rochester

2 Agenda Drug Development Timeline Overview
Lifecycle of a Clinical Trial Sample Timeline Handout Key Timeline Milestones in the various phase of the lifecycle Keys to staying on Time

3 Drug Development Timeline Overview

4 Drug Development Process/Overall Timeline
Overall drug development process on average to bring one drug to market takes years Pre-clinical testing takes 1-3 years, on average 18 months Clinical research (phase I-III) takes 2-10 years, on average 5 years A single clinical trial in phase II-III will typically take anywhere from 1 year to 7 years from conceptual to publication) depending on therapeutic area and duration of individual subject participation. A phase III study in acute pain may be completed within 6 months whereas a study in PD looking for neuroprotection may take more like 5-7 years. NDA review takes 2 months to 7 years (on average 24 months) FDA approved 24 first of kind drugs in 2008 (vs. 18 in 2007, 22 in 2006 and 20 in 2005 (WSJ 1/2/2008). FDA missed the approval deadline for 32 out of 159 drug applications through 10/31/2008. Patents are good for 17 years..companys want to maximize their ability to have have an exclusive market for as long as possible, thus adhering to realistic yet stringent timelines is essential for drug development As individual researchers you may be faced with different types of pressures that will require adherence to a realistic timeline including: limited funding, need to publish to advance career, creating better treatments for your patients etc. Today, its all about bringing products to market, and compressing drug development timelines is critical to focused product development and commercialization.  Identifying, integrating and implementing cost effective development, regulatory, and quality strategies is a challenge for new firms especially those with biopharmaceutical and combination products.  It takes broad experience, a solid understanding about how to deliver,  knowledge of the latest strategies, and an ability to integrate a total system approach which delivers results.  While there has been lots of emphasis over the past several years to reduce the length, cost and risk of drug development there has been limited success in this area.

5 Drug Development Process
It costs about $802 million* (in year 2000 dollars) over 12 years to bring one medicine from discovery in a laboratory to the patient. For everyone one medicine that reaches the marketable stage, between 10,000-30,000 compounds must be screened. *Ref: DiMasi JA, Hansen RW, Grabowski HG. The price of innovation; new estimates of drug development costs. J Health Econ2003;22:

6 A Median Phase III study
Includes ~800 subjects 50 investigator sites ~700 days (2 years) from First Subject First Visit (FSFV) to Last Subject Last Visit (LSLV) Costs ~$25 million (including per subject fees, drug supply, laboratory, Project and Data management fees) or ~$36,000/day Ref: Li, Gen: Site Activation, The Key to more Efficient Clinical Trials; 2008 Advanstar Communications Inc. Gen Li: former head of R&D Operations for Pharmacia & Pfizer

7 Lifecycle of a Clinical Trial

8 Life Cycle of a Clinical Trial
Grant Award and/or Parent contract established Protocol finalized Model ICF finalized Sites selected Operations Manual/MOP completed CRFs finalized IRB approvals obtained Site subcontracts/ payment schedule in place Finalize Contracts with third party vendors (labs, ECGs etc.) DSMB established Build database Finalize Study drug packaging/labeling* Orientation or Initiation Meeting Database Locked Analysis Enroll subjects* Distribution of study drug to sites Answer Protocol/CRF questions Take incident calls SAEs Dosage Adjustments Premature Withdrawals Drug Disclosure Data query process Clean/Close database Transfer database to Biostatistics Perform primary/ secondary analysis Submit abstract Submit manuscript Submit CTR Post results on Post-hoc analysis Protocol Synopsis finalized Schedule of Activities finalized This is a standard life cycle for any clinical trail regardless of therapeutic area or phase (1-1V). The life cycle is broken down into 4 phases: Conceptual, Planning, Implementation and Analysis/Publication. Planning for completion of the various tasks via a detailed timeline and scope of work document As you move into planning and implementation the amount of work and number of players involved increases significantly and management of multiple aspects of the study become critical in ensuring adherence to an established timeline For most of the studies being conducted in Neurological disorders this lifecyle, not including the time to obtain funding is anywhere from 3-5 years and longer and for a phase III study. CONCEPTUAL PHASE PLANNING PHASE IMPLEMENTATION PHASE ANALYSIS/ PUBLICATION PHASE

9 The Process of Conducting Clinical Trials:
Fully understand the full lifecycle of any clinical trial, regardless of the phase (I-IV) or indication The process stays the same Love the process, not the compound under study Compounds are a “dime a dozen” and come and go. (Quote from: Michael Poole, MD Vice President, Wyeth) The process is here to stay

10 Keys to Staying on Schedule
Are developed in the conceptual and planning phase. Develop a REALISTIC timeline and workscope in the planning phase of a study Keep It Simple Stupid! whenever possible

11 Timeline and Work Scope
Create a scope of work document clearly delineating who is responsible for what: sponsor, SC, Project Team, External Vendors, Sites, Monitors Create a detailed timeline of all activities that need to complete in each phase of the Project Lifecycle Both documents will provide the roadmap for the overall project Tools for timeline development: Excel Microsoft Project SmartDraw Liquid Planner Pharmaceutical Development Project Management Tools (Erbian Research Inc.) Copyright © 2009 Clinical Trials Coordination Center/University of Rochester:  All Rights Reserved

12 To Ensure Adherence to the Timeline
HIRE a GOOD Project Manager Is highly organized Is remarkably flexible Has planned and executed a large birthday party (Ira Shoulson, MD), Bar-mitzah/Bat-mitzah or a large wedding Has Anal Retentive tendencies (OCD)..a good thing in this industry Can still see the forest through the trees Has excellent oral and written communication skills Can build strong relationships with all kinds of staff both internal and external to the institution Can influence people without a direct reporting relationship Is not afraid to raise issues early on and work on finding solutions Willing to put in long hours Is always planning at least 6 months ahead

13 It Takes a Small Army to Run a Study: with Excellent Communication
Steering Committee Sponsor Operational Team Project Manager Database Manager Information Analyst Administrative Support Biostatistican Programmer Meeting Planner Monitors Enrolling Site Team Data Safety Monitoring Board Vendor Teams

14 Conceptual Phase Timeline Milestones

15 Formalize the idea/obtain funding
Develop a Protocol Synopsis and Schedule of Activities (2-3 months) Develop full research plan following requirement for potential funding source (e.g. NIH, FDA, DOD, Pharmaceutical unrestricted educational grant, Foundation, or approval of internal pharmaceutical company budget etc.) Submit for funding and go through the review process (typically max of 2 submissions of the same idea) Can take anywhere from ~6-9 month to 4-5 years or longer In some cases funding does not materialize….

16 Planning Phase Timeline Milestones

17 Key Planning Milestones
Protocol Synopsis and Schedule of Activities Procurement of Drug Supply Set-up and maintain Trial Master File (TMF) Final Protocol Model Informed Consent Form (ICF) Develop patient recruitment materials: patient brochure; website; newspaper, TV and radio ads; call center scripts etc. Once the plan is created, the PM should manage the study according to this as well as the agreed to timeline. The sample timeline in your binder includes some standard industry variables for how long it typically takes for certain task to be completed. For each study you plan careful consideration needs to be given to the timeline with realistic milestones. Understanding how long it takes your site to obtain IRB approval as well as participating sites should be factored in as well as time to get signed contracts. Aileen Shinaman will spend more time on contracts later today. IRB approvals at academic institutions typically takes 60-90days while IRB approvals by for profit IRBS can take as littles as 15 to 30 days. You also need to take into account the 30 day time from submission of an IND before starting a study. Planning your orientation mtg such that within a week or so of the mtg sites are ready to start enrolling subjects, which means drug supply needs to be available. Having this meeting too early typically requires follow-up training meetings as people forget the materials. The items in red are the most critical if the study is pharmaceutically sponsored and often timelines are created based on set dates for FPI, which often have financial implications for the company with prior milestones planned backward from FPI.

18 Regulatory Submissions
IND submission(~2-4 wks after final protocol available) FDA approval/complete or partial hold status – (must wait 30 days before starting the study for FDA to respond) Most IRBs require proof of IND status via written documentation ( /formal letter) from the FDA that the trial may proceed Pros/Cons of submitting Final protocol/model consent to sites prior to IND/protocol approval from FDA Submission to other Regulatory authorities as applicable (e.g. Health Canada, European Union etc.)

19 Initiate Site Selection Process
Send Confidential Disclosure Agreement (CDA) to possible sites (must be returned before site selection materials can be sent) (~2 weeks to send and receive) Site selection questionnaire sent to sites with fully executed CDAs (completed ~1 week after final protocol synopsis is available)

20 Select Sites Based on: Notify selected and back-up sites of status
Access to patient population/geographic distribution Past performance of investigator/coordinator team Projected number of subjects/anticipated enrollment rate Receipt of FDA 483s Lack of competing studies Ability to attend orientation mtg Availability of required equipment or specialized staff Notify selected and back-up sites of status Notify sites not selected

21 Site Activation Drives Enrollment
Budget/Contract negotiation Gain Institutional Review Board (IRB) approval in the US or ethics Board approvals in Europe/Canada Collect other regulatory documents (e.g. FDA form 1572, CVs, financial disclosure etc.) Provide sites with clinical supplies (e.g. lab kits, drug supply) Patient Recruitment Begins once above elements are completed

22 Site Activation Enrollment cycle time varies by disease state and sponsor, but across disease states site activation accounts for 70% of enrollment cycle time Activation of a single center on average takes 100 days (3.3 months) 20-50% of studies have rescue missions where new sites are brought in late in the game to enhance enrollment Ref: Li, Gen. Site Activation the Key to More Efficient Clinical Trials. Pharmaceutical Executive, 12/12/2008.

23 Site Subcontract Responsiveness-NIH contract July 1997
Ref: Data from A. Shinaman, Clinical Trials Coordination Center. Unpublished data

24 Subcontract Response Rate-Industry Sponsored contract 2000
Ref: Data from A. Shinaman, Clinical Trials Coordination Center. Unpublished data

25 Data Management Creation of Case Report Forms (CRFs)/eCRFs
First draft of full set of forms within ~4 weeks of final protocol, final version available ~4 weeks after first draft Obtain appropriate permissions to use forms, often including purchase of such forms (e.g., Beck Depression Scale, SF-36) Include appropriate references on published forms (e.g. UPDRS, UHDRS, MMSE, PDQ39 etc.) Database creation/validation Cannot begin until final CRFs/eCRFs are available Takes ~6-8 weeks to complete Timeframe varies base on whether a CRF library is already available for most of the CRFs or if all is being created from scratch Create/Finalize Data Management Plan (DMP) First draft ~4 weeks after final CRFs available, with final DMP ~2-3 weeks after first draft

26 Operations Manual/Manual of Procedures (MOP)
Includes detailed operational instructions for the site on: SAE reporting Drug packaging, distribution and storage requirements Full complement of CRFs and instructions for completion Monitoring expectations Project Team contact list Laboratory procedures Contents of Regulatory binder Proper procedures for conducting various assessments First draft available within 4-6 weeks after final protocol Final MOP available for the Orientation mtg/Site initiation mtg Typically updated throughout the study via Study Newsletters or complete replacement of certain sections

27 Select and Contract with External Vendors
Central laboratory for safety labs PK analysis Central ECGs Electronic diaries Holter monitoring Manufacturer of study drug Primary and secondary drug packager and distributor Monitoring Obtain bids from ~2-3 vendors to compare prices/services early in planning All vendor contracts should be completed prior to Orientation mtg

28 The number one rate limiting step in any clinical trial is:
Study Drug!!! Study Drug!! ACTIVELY MANAGE ALL ASPECTS OF THE STUDY DRUG AS EARLY AS THE CONCEPTUAL PHASE (INITIAL GRANT SUBMISSION)

29 Drug Supply Items for consideration:
Purchase active and matching placebo or have donated? How will drug be delivered (e.g. Bulk shipment in drums, unit packaged, all at once, quarterly shipments) Secondary packaging/labeling and distribution requirements? Blindedness testing: Are active and placebo identical in: color, taste, smell, appearance, shape, size? Stability testing: ambient and accelerated: how many lots of each or is it even required? Expiry/retest issues? Storage requirements: ambient, refrigerated, light sensitive, moisture sensitive? Drug Accountability centrally and at site level Site SOPs to address all aspects of study drug receipt, dispensing, return etc. (overall accountability)

30 Sources for Drug Supply Delays
Lack of sufficient animal toxicology data Held up in manufacturing: impurities found, long queue, API not available, stability issues Problems matching active with placebo supplies Failure to place order with enough lead time Custom delays (e.g. shipment exported/imported from other countries)

31 Cosmetic Bottling (paneling) Problem
Paneling caused a 4 month delay in study start due to inspection time, Corrective Action Plan, and requirement for resupply

32 Establish Data Safety Monitoring Board (DSMB) and Charter
Select DSMB members Typically 3-5 independent scientists with no conflicts-of-interest and no other role in the study (should include: a biostatistican, disease expert, expert on drug under study, expert in body system with AE profile of greatest concern , ideally most have prior clinical trials experience) Create/Finalize DSMB charter Specifies exactly what the DSMB is charged to monitor, stopping rules for efficacy/safety, major areas of concern (e.g. renal, hepatic etc.) DMSB members and final charter should be in-place prior to FPFV

33 Register Trial with www.clinicaltrials.gov Before FPFV
Food and Drug Administration Amendments Act of 2007 or FDAAA), Title VIII, Section 801 mandates that a "responsible party" (i.e., the sponsor or designated principal investigator) register and report results of certain "applicable clinical trials": Trials of Drugs and Biologics: Controlled, clinical investigations, other than Phase I investigations, of a product subject to FDA regulation; Trials of Devices: Controlled trials with health outcomes of a product subject to FDA regulation (other than small feasibility studies) and pediatric postmarket surveillance studies. "Applicable clinical trials" generally include interventional studies (with one or more arms) of drugs, biological products, or devices that are subject to FDA regulation, meaning that the trial has one or more sites in the U.S, involves a drug, biologic, or device that is manufactured in the US (or its territories), or is conducted under an investigational new drug application (IND).

34 Orientation Meeting or Site Initiation Meeting
Depending on size of the study “training” of investigators, coordinators and other site staff can be accomplished via either mechanism Materials to be created include: Agenda Presentations to include: Study overview, review of inclusion/exclusion criteria, drug/device under study, GCPs, adverse event reporting, eCRF/CRF completion, use of eDC system, laboratory requirements, unique safety assessments, primary outcome measure, diaries etc.

35 Orientation Mtg Secure meeting space and lodging ~3-6 months prior to the planned mtg Timing of the mtg should be such that at least half of the sites have IRB approval and subcontracts in place Meetings held too soon are wasteful given staff turn-over, people forget etc. Typically requires additional training mtgs when sites are actually ready to go

36 Initiation Meeting Directly at the participating site; conducted by the lead monitor, project manager, and the PI or their designee Not conducted until individual site has IRB approval, subcontract in place and has received drug supply Allows for complete training of ALL staff at the site that have been delegated responsibilities per the “Delegation of Authority Log” Sites should be ready to start screening/enrolling subjects immediately following this training Format usually used for smaller studies (1-7 sites); phase I-II Most phase III studies use the Orientation mtg format where all investigators/coordinators attend the mtg and hear the same information Some pharmaceutical sponsor may have both a Orientation Mtg and a Site Initiation Meeting

37 At the Starting Line (6-9 months later)

38 Implementation Phase Timeline Milestones

39 Key Implementation Milestones
Drug Supply available at the site – (within days of the orientation mtg or at the initiation visit) FPFV = First Patient First Visit (typically a screening visit; within days of the orientation mtg) FPI = First Patient In (randomized) - (within days of the orientation mtg) Submit Press Release announcing study start FPLV = First Patient Last Visit - (determined by duration of treatment) LPI = Last Patient In (randomized) – [based on planned enrollment period. (# Subjects Enrolled/Site/Month)] LPLV = Last Patient, Last Visit Database Lock – (eDC: ~1-2 weeks following LPLV; paper: ~6- 8 weeks following LPLV)

40 Implementation Timeline Killer
ENROLLMENT DELAYS 86%: Percentage of studies in which enrollment is delayed 1 to 8 months 14%: Percentage of studies in which enrollment is completed on time Significant effort should be spent on identifying appropriate sites and setting up realistic enrollment expectations. Always have a back-up plan Be sure to train any back-up sites brought on board after study start and any new site staff at existing sites Ref:http://www.ciscrp.org/information/documents/101FactsaboutClinicalResearch.pdf

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43 Other Implementation Milestones
Continuous management of drug supply from FPFV to LPLV Develop Statistical Analysis Plan (SAP): Created within ~4 weeks of a complete Data Management Plan (DMP) being finalized Must be finalized BEFORE database lock and unblinding of study results Convene the Data Safety Monitoring Board (DSMB) Regularly during the conduct of the trial per the DSMB charter developed/finalized in planning Submit DSMB letters indicating findings following each meeting to the sites for submission to their IRBs

44 Other Implementation Milestones
Submit unexpected SAEs to the IND as they occur Submit Annual IND reports (per 21 CFR part ) Must be submitted annually within 60 days of the IND submission Submit required regulatory reports to other Regulatory authorities as required Submit Annual Progress Reports to Funding Agency Depends on the funding institute what information the report requires and timeline for submission (e.g., NIH requires annual reports that coincide with each contract year)

45 Analysis Timeline Milestones

46 Analysis Key Timeline Milestones
Top-line results Industry standard is 48 hours post DB lock Academic Institutions depends on Biostatistics group Full Analysis Typically 4-8 weeks post DB lock

47 Publication/ Regulatory Timeline Milestones

48 Full Abstract Develop and submit press release with findings Complete Manuscript Post Results on Share Results with Subjects Submit Final Clinical Technical Report (CTR) to the IND Submit Reports to other Regulatory Authorities as applicable

49 The Finish Line: Anywhere from 1-7 years later.
Driven mostly by: Enrollment Duration Duration of subject participation Adequate Drug Supply

50 Conclusion

51 Key Points to Remember Create a REALISTIC TIMELINE from day 1
There are many road blocks along the way that impact timelines Don’t be discouraged, just figure out how to go around, over, under or through the road block and you will eventually get there!!! Re-evaluate timelines along the way based on nature/timing of “roadblocks”

52 Failure to adhere to realistic timelines
Increases study budget Planned resources downstream may not be available (e.g. enrollment goes longer than planned, DM staff may not be able to lock the DB based on competing priorities) Reduces time for market exclusivity: every day of delay in getting to market = $ 2-3 million/day in lost revenue based on annual sales of a good drug $500M/year – blockbuster sales of $1B/year Delay in getting needed drugs to patients

53 Metrics Champion Consortium www.metricschampion.org
The MCC is an open, multidisciplinary, non-profit organization comprised of biotechnology, pharmaceutical, research institutions and service provider organizations The mission of the MCC is to develop, Performance Metrics within biotechnology and Pharmaceutical industry with the intent to jointly encourage performance improvement, effectiveness, efficiency and appropriate levels of controls for both Sponsors and Service Providers in support of the drug development process Metrics for: central laboratories, ECG , CRO and imaging; including standard timeline metrics

54 Backup Slides

55 PDUFA The Prescription Drug User Fee Act of 1992
PDUFA The Prescription Drug User Fee Act of Legislation passed by Congress authorizing the FDA to collect "user fees" for regulatory review of human drug applications. The FDA agreed to use the income from the fees to hire more reviewers to speed up drug review without compromising review quality.

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57 Post results on www.clinicaltrials.gov
Report results on (Sept 2008) Basic Results: Baseline characteristics, Primary and secondary analysis, statistical analysis Generally submission within 12 months of the earlier of estimated or actual trial completion date (of primary outcome) Adverse Event Reporting (Sept 2009) Expansion of results by rulemaking (Sept 2010)

58 Sharing Results with Subjects
In conjunction with Press Release, coordinate webnairs/teleconferences with subjects/families to discuss results and particularly impact on treatments* Notify subjects of study results via copy of the abstract and/or full manuscript Notify subjects of their individual treatment assignment This typically takes place months following subject completion in the study. Ensuring sites maintain accurate contact information for this follow-up is important. *Reference: Dorsey E. R., Beck C., Adams M., Chadwick G., de Blieck E.A., Mcallum C., Briner L., Deuel L., Clarke A., Stewart R., Shoulson I., and the Huntington Study Group TREND-HD Investigators. Communicating Clinical Trial Results to Research Participants. Arch Neurol. 2008; 65(12):

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