ReviewTechnical challenges in designing post-marketing eCRFs to address clinical safety and pharmacovigilance needs
Introduction
The electronic data capturing (EDC) technology and systems have enabled automated support for clinical study data collection, reporting, query resolution, randomization, and validation, among other features for the past two decades. There is a trend toward greater adoption of EDC tools in the clinical research industries though the EDC implementation has its sufferings such as: lack of global standardization, technology integration challenges, and certain resistance from sponsors/investigators to switch from paper based data collection (PDC) to EDC.
However, the rationale behind EDC is so strong and much accepted in the clinical research communities: eCRFs are filled and collected via computers connected to the world wide web to expedite the availability of accurate/complete data [1], [2]. EDC vendors need to take up the challenges to address some of the implementation issues via collaborating with sponsors: performance, usability, integration among Clinical data management system (CDMS), clinical trial management system (CTMS), and/or clinical safety system in order to compete and win market shares. Service-oriented architecture should be devised to meet the increasing and complex medical research by offering scalable and flexible system maintenance and new releases. Technology advance and collaboration among various clinical functional groups, regulatory agencies, standard consortiums, and the industry will push for more effective e-clinical research solutions and more interoperable EDC systems to realize several core benefits: time savings, cost reductions, and increased efficiencies.
Risk assessment during clinical product development needs to be conducted in a thorough and rigorous manner; however, it is impossible to identify all safety concerns during controlled clinical trials. Once a product is marketed, there is generally a large increase in the number of patients exposed, including those with co-morbid conditions and those being treated with concomitant medications. Therefore, post-marketing safety data collection and clinical risk assessment based on observational data are critical for evaluating and characterizing a product's risk profile and for making informed decisions on risk minimization. Regulators are demanding proactive surveillance programs that include comprehensive risk management plans and signal detection/analysis throughout a clinical product's lifecycle. Organizations that take the lead in developing a more proactive and long-term approach to manage the safety of their products, recognize that success requires a continuous, consistent process from preclinical research onward. This is achieved through developing a good clinical safety practice that shows the company was aware of and acted on every safety issue as it developed for a product or device [3].
A comprehensive literature review is undertaken to assess current industry approaches in eCRF design methodologies. The eCRF design principles, processes, standards, guidelines, and best practices for properly capturing clinical protocol and compliance-necessitated data has been reviewed, summarized, and presented from industry implementation perspective. Specifically, the issues confronted in the eCRF design of post-marketing studies using EDC tools are discussed; and, proposed technical considerations are presented and illustrated.
Refer to Fig. 1 to see a typical clinical data flow in a post-marketing study.
Section snippets
Real-world view on drug/device safety
A considerable number of clinical trials generally involve a very small, carefully selected patient population, which is hardly indicative of the much larger and diverse expanse of patients who may be exposed to a new product after regulatory agency approval and product launch. Therefore, the body of data accumulated during controlled clinical trials is not sufficient to adequately predict a product's future performance in the real world [4].
Adverse Event Reporting System is designed to support
eCRF development workflow
In general, the following data domains need to be collected for post-marketing safety reporting needs [7]
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Demographics (DM)
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Adverse Events (AE)
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Vital Signs (VS)
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Medical History (MH)
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Physical Examination (PE)
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Laboratory Test Results (LB)
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Prior and Concomitant Medications (CM)
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ECG Test Results (EG)
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Disposition (DS)
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Exposure (EX)
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Substance Use (SU)
Fundamental eCRF design principles should be followed regardless protocol or therapeutic unit:
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Develop as early as possible with a stable draft Protocol, based on
CDISC and CDASH standards
In recent years, there have been a number of interesting discussions and developments with clinical data standards such as Health Level Seven(HL7) and Clinical Data Interchange Standards Consortium (CDISC) [8]. The landscape of healthcare-related standards is large, complex, and interrelated with multiple players in this arena. Fortunately, CDISC has a “niche” in the development of standards for clinical research in having initiated a collaboration with the leading healthcare standards
Coding standards
The Medical Dictionary for Regulatory Activities (MedDRA) has been developed as a pragmatic, clinically validated medical terminology with an emphasis on ease-of-use data entry, retrieval, analysis, and display, with a suitable balance between sensitivity and specificity, within the regulatory environment. MedDRA is the international medical terminology developed under the auspices of the International Conference on harmonization of Technical Requirements for Registration of Pharmaceuticals for
Appropriate use of EDC technology
The recent focus on electronic data collection creates the temptation for companies to purchase a piece of software and expect to drop this into their operations and quickly gain the advertised advantages. In practice, however, this is rarely the case; most often, the purchaser realizes that there are many other complimentary pieces of the process that need to be aligned, and these changes ripple through the organization and end up being considerably more profound than anticipated [11].
The
Unanticipated adverse drug experience (UADE)
When a new drug is first marketed, findings regarding its efficacy and safety are commonly based on the experience of several thousand people who have been treated in controlled clinical trials. Despite extensive testing, rare adverse events (those that occur in less than one patient per thousand) can easily escape detection, and unforeseen interactions with coexisting clinical conditions or other drug therapies may remain unexplored. As a result, the characterization of the full safety profile
Conclusion
The market acceptance of EDC technology has fueled new demands for improvement, configurability, and intelligent features. The need to improve clinical efficiencies and accelerate study times continues to grow, driving industry sponsors to seek an eClinical environment that provides and promotes: flexible, speedy eCRF trial design and build; robust data management; real-time data visibility, reporting and analysis; and global trial management and study scalability [16], [17].
eCRF design is the
Conflict of interest
The author has disclosed that opinions or views expressed through this article represent individual perspectives only.
References (19)
- et al.
Adopting electronic medical records in primary care: lessons learned from health information systems implementation experience in seven countries
Int J Med Inform
(2009) - et al.
Informatics tools to improve clinical research study implementation
Contemp. Clin. Trials
(2006) - et al.
Data standards in clinical research: gaps, overlaps, challenges and future directions
J Am Med Inform Assoc
(2007) - et al.
The use of electronic data capture tools in clinical trials: web-survey of 259 Canadian trials
J Med Internet Res
(2009) - Miller E, Deleger S, Murphy J. Implementing and Managing Adaptive Designs for Clinical Trials. Accessed at...
Information technology in pharmacovigilance: benefits, challenges, and future directions from industry perspectives
Drug Healthc Patient Saf
(2009)Potential for conflict of interest in the evaluation of suspected adverse drug reactions — a counterpoint
JAMA
(2004)Observational data under the microscope
Appl Clin Trials
(2009)- et al.
Knowledge innovation and clinical operational excellence
Drug Inf J
(2009)
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