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Page 1: Business and Operational Risks in Pharmaceutical Information

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Business and Operational risks in handling pharmaceutical information

17TH November 2011

Adrian Hampshire, BioPharm

Parambir Singh, BioPharm

Rob van Manen, Oracle

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Risk – a definition

● a situation involving exposure to danger

● the possibility that something unpleasant or unwelcome will happen

(Oxford English Dictionary)

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Outline

● What are business and operational risks?

o Broad scope

• e.g. What risks do you run if you don’t have a particular system or process in place?

o Narrow scope

• e.g. What risks do you run when implementing a complex system or process?

● What are some of the impacts if a risk occurs?

● How can we reduce the risks?

● What do we do about residual risks?

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Key steps and processes involved in a clinical trial • Trial design and planning • Obtaining regulatory approval • Planning and manufacturing/acquiring study drug • Recruiting investigators (enrolment, screening, inclusion) • Site start-up • Recruiting patients • Administering drug • Registering results • Raising and responding to data queries • Monitoring safety • Monitoring site execution • Verifying source document • Assembling results • Reconciliation • Analysing results • Reporting the trial • Closing the study

Each of these steps involves an individual process that is more or less complex.

Each process is supported/enabled by one or more IT or manual systems.

Each step therefore carries a number of key risks.

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Key risks

1. The step is not executed at all Simple example: If there is no process and system

for monitoring safety, patients are put at risk.

2. The step is executed incorrectly or incompletely

Simple example: If the design of the trial is inadequate or inappropriate, the results of the study may not answer the question that the study was designed to answer.

Conclusion: We need a robust and complete set of

process and systems to support those processes throughout the lifecycle of the study.

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Change = Risk

Implementing a new process and system(s) = change

Change = Risk

Risks are: ● Strategic risks

● Programme risks

● Operational risks

● Project risks

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Management of risk

Four key actions: ● Identify the risk

● Assess the impact

● Reduce the impact

● Plan to handle the risks that can’t be eliminated

Optional fifth key action: ● Outsource the risk

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Outsourcing risk

Sponsor outsources the trial to a CRO ● The sponsor is paying the CRO to take on the risk, for a price.

Sponsor or CRO deploys a system to help manage any of the clinical trial processes ● They “outsource” a proportion of the risk to the developer/

vendor of the system, again, for a price.

In both cases, the organisation shares the risk with a supplier who, because they have executed the process many times or have built the software through many iterations over many years, consequently run a much reduced level of risk.

CAVEAT: If key processes of the trial are outsourced, we need to be clear who “owns” the risk and takes responsibility for addressing it.

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Commercial packages reduce risk

A pre-packaged solution: ● Built on best practices ● Delivers probably 80% of what the customer needs ● Gives the organisation the choice to o configure the system to meet the missing 20% o change their process such that the 80% provided by the pre-

packaged solution meets 100% of requirements

● Greatly reduces the risk because all prior implementations and the design choices and changes made as a result of these projects have already incurred those risks

● Reduces validation and testing requirements because much of this is address when the pre-packaged solution is constructed

● Has the potential to speed up the implementation by an order of magnitude. o Example: ASCEND reduces implementation time from 8-10

months to 8-10 weeks

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Two examples in detail

ASCEND ● Reducing risk by implementing a pre-configured

version of a complex CTMS solution (Siebel Clinical)

Parambir Singh, Vice President, Clinical Trial Management Solutions at BioPharm Systems

Argus Safety and Empirica Signal ● Reducing risk by implementing a commercially

available, proven and market-leading safety and risk management solution suite

● Rob van Manen, Master Principal Sales Consultant at Oracle HSGBU

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Introduction

A CTMS helps mitigate the risks of: ● Skipping a step

● Executing a step incorrectly

Siebel Clinical’s design is particularly helpful at mitigating risk ● Template-driven

A pre-packaged version of Siebel Clinical, such as ASCEND, further mitigates risk

● Industry standards and best practices

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Agenda

Topic

Introduction & Agenda

Recruiting Investigators

Site Start-Up

Recruiting Patients

Monitoring Site Execution

Closing the Study & Conclusion

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Recruiting Investigators

Assessment Templates: Standardized evaluation criteria and answer choices ● Ensure investigators are evaluated consistently and objectively

● Complete one assessment multiple times or several different assessments for each investigator

● Associate a percentage score with each investigator

Siebel Clinical

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Recruiting Investigators

Target Lists: Complex investigator searches ● Allow users to search for investigators:

o in the right location

o with the right patient population

o with the right experience

o with the right assessment scores

ASCEND

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Site Start-Up

Activity Templates: Standardized sets of tasks and documents ● Reflect content of SOPs

● Ensure same tasks are completed and same documents are collected across all sites

● Can have separate templates for each country to reflect different requirements

Siebel Clinical

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Site Start-Up

Activities & Document Tracking: Focused tracking areas ● Utilizing the SC separate views due to different tracking needs for

activities vs. documents

● Tailored fields and field dropdown choices in each view

● Document Tracking Screen which includes all documents also includes indication of what level the document is related to

ASCEND

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Recruiting Patients

Subject Visit Templates: Standardized subject visit schedules and payment amounts ● Created per protocol and applied to each site and patient

o Can be versioned to reflect protocol amendments

● Payment amounts can be modified at the site level (modifications are documented)

● Payment process ensures no visits are paid for more than once

Siebel Clinical

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Recruiting Patients

Subject Information: Improved tracking ● Able to record IRB Approval dates for protocol amendments that

do not affect the visit schedule and therefore do not require new Informed Consent

● Able to track individual subject treatment arms and change treatment arms mid-study

● Able to track details about subject-specific protocol deviations and adverse events

ASCEND

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Monitoring Site Execution

Trip Report Templates: Standardized tasks and questions ● Reflect content of SOPs

● One template for each type of visit

● Created centrally and then applied to each site visit record

● Ensure same information is recorded, tasks are completed, and questions are answered for each visit type across all sites

Siebel Clinical

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Monitoring Site Execution

Trip Report Completion: Expanded to include more information ● Separated yes/no questions from narrative response questions

● Allow relevant PD, SAE, Follow-Up Item, and CRF Tracking records to be imported as a snapshot in time

● Records complete approval history audit trail to comply with 21 CFR Part 11

ASCEND

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Closing the Study

Activity Templates: Standardized sets of tasks and documents ● Reflect content of SOPs

● Ensure same tasks are completed and same documents are collected across all sites

● Can have separate templates for each country to reflect different requirements

● Rollup views allow quick access to subject, site, and country/region statuses to confirm all child records are in a terminal status

Siebel Clinical

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Closing the Study

Activities & Document Tracking: Focused tracking areas ● Utilizing the SC separate views due to different tracking needs for

activities vs. documents

● Tailored fields and field dropdown choices in each view

● Document Tracking Screen which includes all documents also includes indication of what level the document is related to

ASCEND

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Conclusion

• Implementing a CTMS helps to mitigate risk by providing a central location for clinical trial management information

• Siebel Clinical is particularly helpful at mitigating risk due to its template-driven design

• A pre-packaged version of Siebel Clinical, such as ASCEND, further mitigates risk by adhering to industry best practices and including commonly-requested enhancements right out of the box

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Introduction

A case processing system can help mitigate process-related compliance risks, such as:

● Failing to comply with adverse reaction regulations

- Failing to report certain cases

- Failing to comply with regulatory reporting deadlines

A signal detection environment can contribute in mitigating product-related risks, such as:

● Failing to timely detect product-related adverse reactions

- Failing to perform correct clinical assessment of potential signals

- Failing to take appropriate action and document this

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Case Processing

Activities:

● Data collection and entry

● Coding

● Medical review

● Reporting

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Case Processing: Data Entry

Risks and safeguards: ● Incomplete data: Data completeness checking

- Avoid missing key information such as patient, product, event or reporter

● Incorrect data: Data correctness checking

- Dates and numbers

- Upper and lower boundaries

● Inconsistent data: Data consistency checking

- Starting and ending dates; continuing exposure/event

- Seriousness criteria

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Case Processing: Coding

Risks and safeguards: ● Incorrect coding

- Use of auto-encoders, supporting powerful multi-step coding

algorithms

- Use of coding review procedures

● Inconsistent coding

- Use of standard synonym lists

- Code propagation capabilities

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Case Processing: Medical review

Risks and safeguards: ● Incorrect assessment of reportability

- Providing all relevant information in an easily accessible way

● Undocumented assessments

- Importance of easy to use functionality to capture medical

assessment results (including audit trail)

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Case Processing: Regulatory reporting

Risks and safeguards: ● Reports not submitted

- Automatic report requests based on regulatory requirements

● Reports submitted too late

- Report tracking with reminder capabilities

● Incorrect report type, e.g. periodic versus expedited reporting

- Reportability assessment combined with automatic report requests

● Reports not adequately documented for auditing purposes

- Built-in report tracking and auditing

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Signal Detection

Background:

● Regulators have published signal detection guidance documents and are in the process of implementing signal detection requirements

● Regulators are performing quantitative signal detection themselves and have been confronting companies with potential signals

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Regulatory Guidance on Signal Detection

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Examples of Regulatory and Public-Private Initiatives

Europe: ● ENCePP (European Network of Centres for Pharmacoepidemiology and

Pharmacovigilance)

● IMI-PROTECT (Innovative Medicines Initiative - Pharmacoepidemiological Research on Outcomes of Therapeutics by a European Consortium)

● EU-ADR

US: ● Sentinel and Mini-Sentinel

● Observational Medical Outcomes Partnership (OMOP)

Japan: ● Mihari

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Signal Detection Activities by Regulators

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Signal Detection Activities by Regulators

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Signal Detection Activities by Regulators ● FDA

o Empirica Signal in production at CDER, CBER, CDRH and CFSAN - quarterly overview of potential signals currently under evaluation

o Empirica Study and WebSDM in production at CDER and CBER

● EMA – EudraVigilance

o In-house developed quantitative signal detection tools (PRR)

● MHRA

o Empirica Signal – Signal Management in production – Drug Analysis Prints

● MHLW – PMDA

o Developing quantitative signal detection tools as part of the Mihari initiative

● Other countries:

o Netherlands (Lareb): In-house quantitative signal detection tools (ROR)

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Signal Detection: Risks and Safeguards

Risks: ● Non-compliance with current regulatory guidelines and upcoming

regulations with respect to quantitative safety signal detection

● Previously unknown signals identified by regulators through quantitative safety signal detection

Safeguards: ● Implementation of processes and systems for standardized, systematic,

documented quantitative signal detection and signal management

● Application of methods and systems for data cleaning and signal detection as similar as possible to those used by the authorities

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Questions?