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Published byGeraldine Jordan Modified over 6 years ago
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Collaboration and Consensus – Standards Around Data, Definitions and Operational Workflow
Matt Wilson, RN Director CEC-SS-ACL DCRI
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Objectives: Standards Best Practices in adjudication? Data-Definitions
Operational workflow Guiding principles Start to Finish eCRF Charter Triggers Quality Metrics that matter
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The CEC Mission Provide HIGH quality adjudicated endpoint data with scientific rigor, efficiency and innovation by coordinating and conducting Systematic, Consistent, Unbiased, Blinded, and Independent Clinical Events Adjudication. Efficient Accurate Always Improving
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Are we saying the same things?
What should we adjudicate? Primary, Secondary, Events of Interest, Causality, Eligibility, etc. How should we identify (trigger) events for adjudication? Outcome pages, Lab data, Medical records, Free text, Hospitalizations, AE’s, SAE’s, etc. What should we collect? eCRF (patient profile report), DC summary, H&P, ER report, Lab slips, Image reports, EKG’s, Death Certificate, Autopsy report, Consult notes, MARS, etc. Who are our partners? Sponsor, CRO, ARO, Ops, Data, Stats, Reviewers, Sites, FDA, IRB, EC, SC, DSMB etc. What is quality? Key Risk Indicators, Currency, Traceability, Major Discordance, Missing data, Missing events, etc. Who is monitoring the eCRF? Site Management, CEC, Stats, Sponsor, Safety, Technology, etc.
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Key data elements, GCP, CFR, HIPPA, GDPR, IRB
Do we have standards? Key data elements, GCP, CFR, HIPPA, GDPR, IRB Quality-KRI’s Operational workflow Data-Definitions
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Guiding Principles - Defining Quality
Were all suspected events triggered as planned? Were all events processed per charter procedures? Were all adjudications data based accurately? Were all QC procedures performed/documented with identified issues addressed? Did any major SOP/WI/HIPAA/GCP/IRB violations occur?
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Start to Finish! Protocol Charter eCRF design Triggers Edit Checks/DVC
+Efficacy vs Safety? +Endpoint driven? Charter +Definitions? +SD table eCRF design +QB/EVENT Pages Triggers +Clinical Trigger spec Edit Checks/DVC +Stats/DM partners
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Definitions 2014 FDA Hicks KA et al: Circulation 2014 –
2012 Key Data Elements and Definitions for PAD – Fourth Universal Definition MI – TAVR VARC-2 Consensus document –
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Source Documentation When is it too Much? When is it not enough?
“Fine balance between getting enough information and getting ALL the information to review a case”
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Which way do we go? Source documentation vs. eCRF data
Source Documents eCRF data Comprehensive Reduce site burden Data Security (PHI considerations) Efficiency (cycle times, cost) Translations Consistency (same questions)
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Big Picture – what, when, where…
Recommended Event-Specific eCRF data/Source Documents Death and Hospitalization Events eCRF Clinical Event Narrative NT-pro-BNP results (if performed) Procedure reports; PCI/CABG (if performed) Right heart catheterization results (if performed) Cardiac Markers with ULN (if performed) Source Documents (tracked by CEC) Discharge Summary (if hospitalized) Autopsy Report (if performed) Event ECG’s pre, during, post (if performed) Neurology Consult notes (if performed) Urgent Heart Failure Visits Exam report Treatment plan Labs to confirm evidence of new or worsening HF ER or clinic visit note “We are quickly approaching an era of limited source data and a dependency on CRF data…the necessity of a good clinical narrative…is REALLY important… conventions that the sponsor and/or FDA agree upon re: adjudication from CRF data only will be important”
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Designing the Data Collection Process
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eCRF Best Practice: Quarterback Page
Captures Key Components/ Critical Variables Yes/No response required for each event type Dynamically creates event page to collect further details when event is answered ‘Yes’ Through telephone or clinic visit Recommend collecting no less frequently than every 3 months Important in later clinical phases
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eCRF Best Practice: Event/Endpoint Detail Page
Support the Endpoint Definitions Measurable and Objective Strategic “Net” to identify events Complements source documents Reduces source document collection Pertinent Information Consistent same questions Chronology of care Trigger on this page Death, Stroke, Myocardial Infarction, Bleeding, Congestive Heart Failure, Acute Pancreatitis, Neoplasms….
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eCRF Best Practice: CEC Relevant Pages
Hospitalization Page Strategic monitoring strategy Lab Value Pages Cardiac Markers, Troponin I/T, CK & CK-MBs Labs of Interest: HGB/HCT Transfusions Procedural Pages Cardiac Catheterization (CATH) Percutaneous Coronary Intervention (PCI) SAE/AE Pages
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No matter how good (or bad) your CRF is, if it’s flawed — you won’t get intended results.
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Design and Implement an effective CRF (data capture and edit checks)
Routine QC checks (involve Stats, DM, CEC, Site Management) Cross checks Lab data suspicious of event, no event reported Duplicate events (e.g. >2 in 1 week) Reconcile SAE/AE (coded terms) to CEC triggered events Negatively adjudicated events (follow up for potential SAE/AE) Data that you cannot algorithmically assess: Free text review; Hosp, SAE/AE pages, SAE labs) 2 Large ACS trials, DCRI methodology applied (possible Missed MI’s) 41,965 lab records, 2,247 possible triggers, 29 triggered & confirmed 10,269 hosp records, 370 possible triggers, 49 triggered & confirmed Source document review (Medical records submitted for adjudication, review for SAEs/additional endpoints)
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Operational Workflow –
CEC project staffing (Clinical team)? CEC PI, Members, PL, CTC, CTA, CDS Who trains who? CEC PI, CTC What are we training our CEC teams on? Protocol, Charter, Conventions, etc. How do we adjudicate? Phase 1, Phase 2, Single Clinician Review, Third Reviewer What qualifies a reviewer to adjudicate? TA/Clinical experience, CEC experience What % of cases reach committee? >30% retrain, assess for issues What if CEC is receiving more triggers than expected? Check your net, patient demographic Are the sites submitting the right SD in a timely manner? 2 weeks Are the sites responding to queries in a timely manner? 2 days Query escalation plan in place? Swat Team approach with CRAs, CEC, Sites, Sponsor Are there calls between site management and the CEC coordinators to discuss what’s needed on the more difficult cases? Who is responsible for cleaning the CRF? Site management
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Metrics that matter Currency % Query (10-15%) % Complete (80-90%)
Cycle Times Query to Clean (10-30 days) Clean to Complete (5-10 days) Discordance (Major disagreements) Site vs CEC (10-20%) CEC vs CEC (10-20%)
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Adjudication cycle times – how are we doing?
Event date to triggered* 10 days Triggered to assigned to reviewers 15 days Assigned to reviewers to case complete 5 days Adjudication cycle times – how are we doing? 30 days total Set targets: Query to Adjudication <30 days x-days, escalate Adjudication to Complete <10 days x-days, escalate * The event date to triggered can be dependent on visit windows
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Adjudication Completeness “Currency” – Gold 80%, Platinum 90%, Executive Platinum 95%
Event Types # Events Triggered # at Query # at Phase 1 Physician Review # Ready for Committee Review # at QC # at Re-Review # at No Action Needed # at Complete + # at No Action Needed # at Complete Bleed 219 23 15 3 4 178 174 Death 36 8 2 1 25 MI 6 18 16 Stent Thrombosis 14 Stroke 12 9 Totals 308 39 20 5 244 238 Troubleshoot problems: queries, translations, reviewer delays. Know where to push!
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Do I have enough to adjudicate the case?
Recommend a joint Ops/Reviewer strategy 1.) Ops tracking Quantify what is in the cases Assist with query process Active/End of trial metrics “what cases were missing x?” 2.) Reviewer assessment Answers the key question – “did I have enough?”
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Insufficient Source Documentation question and follow-up:
Entered by reviewers “reviewer form” Entered by querying team “tracking page”
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CEC Key Risk Indicators (KRI’s)
time between event occurred and event triggered time between "in query" to “ready for adjudication" time between Phase 1 and a) final outcome or b)phase 2 [overall] time between Phase 1 and a) final outcome or b)phase 2 [by adjudicator] time between Phase 1 disagreement and Phase 2 ratio of # agreement/#disagreement by adjudicator # documents received/# documents expected by site & event type # agreement events [sites and CEC]/#total events [sites and CEC] and event type
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Design/Implement plan early on, include key stakeholders (FDA, Sponsor, EC)
Methods used require validation steps Documentation is key (project plan, trigger spec, charter) Involve SMEs (CEC, Stats, DM, SM) Develop and Implement plan early on (startup/FPI) to avoid the following: Missed events Difficulty collecting data retrospectively Limit free text fields and train sites on effectively capturing clinical context in eCRF narrative Integrate your CEC and Safety teams for “Cross Talk” Real time reconciliation of reporting (CEC/Safety)
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