During this presentation, Ron Kershner, Ph.D. discussed the responsibilities of DMCs from the perspective of protecting patient safety and providing critical, independent oversight to key study objectives. Drawing on past clinical trials to illustrate key points, Ron addressed DMC operational considerations, such as meeting frequency and content, control of information, data cleaning issues and scope/format of data tabulations.
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The Role of Data Monitoring Committees
1. 2 0 11 FA L L B I O M E T R I C S W E B I N A R S E R I E S
The Role of Data Monitoring
Committees
Sept. 20, 2011 Presented by Ronald Kershner, Ph.D.
2. Ronald Kershner, Ph.D.
Vice President, Biostatistics and Data
Operations
25+ years of clinical research experience
– Includes over 24 NDAs in various therapeutic
areas
– Served on over 20 data monitoring committees
Authored more than 30 publications and
presentations with a recent focus on eClinical
technologies and independent data
monitoring committees
Ph.D. in Statistics from Cornell University
2011 FALL BIOMETRICS WEBINAR SERIES
3. Today’s Topics
3
1) Reasons for DMCs
2) Roles, objectives and set-up for DMCs
3) Operational considerations
4) Statistical considerations: p-value adjustments
5) Where companies get it wrong
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4. Reasons for DMCs
Ethics
Insurance
2011 FALL BIOMETRICS WEBINAR SERIES
5. Reasons for DMCs: Ethics
5
Oversight function to insure patient safety
Monitor and be able to quickly react to any
untoward safety events
2011 FALL BIOMETRICS WEBINAR SERIES
6. Reasons for DMCs: Insurance
6
Operational Issue
Provide oversight function of study progress
Insure study will have reasonable likelihood of
achieving basic objectives
– Futility probability
Early warning system for operational issues
– Critical design parameters
– Sample size considerations may warrant adaptive
design
Stop early
– No efficacy or unacceptable safety
– Early, compelling, untoward, unexpected efficacy
2011 FALL BIOMETRICS WEBINAR SERIES
7. Roles, Objectives and Set-up for
DMCs
DMC
Executive Committee
Data Analysis Center
2011 FALL BIOMETRICS WEBINAR SERIES
8. DMC Charter
8
Define roles and
responsibilities of
DMC members
Communication with
Executive Committee
Scope of data reviews
Structure and timing of
meetings
2011 FALL BIOMETRICS WEBINAR SERIES
9. Committee Roles
9
DMC Executive Committee
Review data tabulations Responsible for study
from ongoing clinical trial oversight and conduct
Deliberations are Membership: company,
confidential investigators
Make recommendations to Decision makers
Executive Committee
2011 FALL BIOMETRICS WEBINAR SERIES
10. DMC Members
10
Who to include: Who NOT to include:
Independent clinical members Company/sponsor/client
– Therapeutic area experts Study investigators
– No vested interest in Investigator’s company
company or outcome of contact
trial Individuals who can change or
Independent statistician influence patient recruitment
Individuals with data
classification responsibilities
Individuals who could control
or change study design,
objectives or planned
analyses
2011 FALL BIOMETRICS WEBINAR SERIES
11. Key Points
Comparing the Committees
11
DMC Executive Committee
Independent Company representation
Access to data Investigator representation
No decisions, (optional)
recommendations to NO access to data
Executive Committee Decision makers, based on
recommendations from
DMC
2011 FALL BIOMETRICS WEBINAR SERIES
12. Number of Meetings
12
Function of
– Recruitment rate
– Size of study
Can be more frequent for AEs
Conference calls, web conferences, or face-to
face
2011 FALL BIOMETRICS WEBINAR SERIES
13. DMC Meetings
13
Open Sessions Closed Sessions Minutes
Executive DMC Only Document
Committee Unblinded data deliberations
DMC review Confidentiality is
No unblinded data key
2011 FALL BIOMETRICS WEBINAR SERIES
14. Assure Confidentiality of Interim
Results
14
Case Study:
Sepsis
Potential blockbuster with estimated
$1B/year market potential
NYT: 12 Feb 1993
Centoxin
– Efficacy endpoint in pivotal study
changed based on knowledge of
interim results
– NDA terminated
2011 FALL BIOMETRICS WEBINAR SERIES
15. Data for DMC Member Review
15
What information needs to be provided to the
DMC members for meetings?
✓ Patient accounting
a)
✓ Demographics/medical history
b)
ALL OF
✓ Enrollment summaries
c)
THESE
✓ AEs/SAEs – coded summaries
d)
✓ Basic efficacy summaries
e)
2011 FALL BIOMETRICS WEBINAR SERIES
16. Operational Considerations
Keep review scope focused
– “Interim analysis” is not final analysis
Emphasize simple tables and graphics, not
listings
Information needs to be current
– Current is more important than clean
2011 FALL BIOMETRICS WEBINAR SERIES
17. Example: Lab Data
17
Hematology, LFTs
2-year study
Lab panels every month
6 LFTs X 24 visits = 144 displays
Don’t use: Normal range shift tables? Change
from baseline?
Consider: Use 1 table to display any value
outside a biologically significant boundary at any
time
– Biologically significant = 3 or 4X upper limit or
CDC toxicity level
2011 FALL BIOMETRICS WEBINAR SERIES
18. Plan for Rapid Retrieval of
Outcomes
18
Important to minimize time lag between CRF at site versus in-
house
EDC Paper CRFs
Very helpful alternative to Short forms, worksheets
paper Phone calls
Make sure data is entered Working/temporary
at the sites databases
Help Desk support
2011 FALL BIOMETRICS WEBINAR SERIES
19. Other Considerations
19
Resource intensive process, particularly for
paper CRFs
– Monitoring
– Programming
– Data Management
Additional analysis requests based on DMC
input and reviews
– More tables, ad hoc requests
Should company be made aware?
2011 FALL BIOMETRICS WEBINAR SERIES
20. Statistical Considerations:
p-value Adjustments
When DMC looks at interim data, p-value
adjustments are necessary
– Avoid over reaction to early trends
– Maintain nominal alpha level of 0.05 for the
final analysis
2011 FALL BIOMETRICS WEBINAR SERIES
21. P-value adjustments
21
Multiple looks require an adjustment to the p-
value
Need to control overall Type I error rate
Type I error = 0.05 for one look
= 0.14 for 5 looks
= 0.20 for 10 looks
2011 FALL BIOMETRICS WEBINAR SERIES
22. Control type I error and maintain
nominal 0.05 alpha for final
analysis
22
Interim analyses utilize p-values at levels of
approx. 0.0001 at each look versus 0.05 at each
look
e.g., 6 interim analyses (6 looks):
Final alpha = 0.05 – 6*0.0001 = 0.0494
2011 FALL BIOMETRICS WEBINAR SERIES
23. Z Values for Clofibrate-Placebo
Differences in Proportion of Deaths
by Month
23
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24. Key Points
24
There are sound reasons to have a DMC
monitor ongoing data
P-value adjustments need to be made
P-value adjustments for interim looks can be
very small and final alpha can be maintained
very near 0.05
2011 FALL BIOMETRICS WEBINAR SERIES
25. Where Companies Get it Wrong
Administrative analyses
DMC for safety only
Blinding the DMC
2011 FALL BIOMETRICS WEBINAR SERIES
26. Administrative Analyses
26
Look at data with no intent to modify study
Look at data for operational (“insurance”) issues
Since no intent to change, no adjustment of p-
values should be necessary
If efficacy data are involved, adjustment is
needed
– Always a potential to overreact to early trends
– Major red flag
2011 FALL BIOMETRICS WEBINAR SERIES
27. Safety Only?
27
Should DMCs be used for review of safety only?
✗ Yes
a) DMC needs access
both efficacy and safety
✓ No
b) to assess risk and benefit
2011 FALL BIOMETRICS WEBINAR SERIES
28. Restrict Monitoring for Safety Only
28
Case Study:
AMD
Limited Phase II dosing information
First major entry into patients was
two large Phase III studies
– Limited safety data
Efficacy endpoint: mean difference of >
2 lines between treatment and placebo
after two years of therapy
2011 FALL BIOMETRICS WEBINAR SERIES
30. Restrict Monitoring for Safety Only
30
Case Study:
AMD
Results: only 1 of 2 studies
showed significance
Reason: high placebo response
rate
2011 FALL BIOMETRICS WEBINAR SERIES
31. Blinding of Data
31
Does the data need to be blinded for the DMC
review?
✗ Yes
a) Not an FDA or ICH requirement
Imposed by companies to:
– “Prevent bias”
✓ No
b) – “Avoid over reaction to early
trends”
2011 FALL BIOMETRICS WEBINAR SERIES
32. ICH E9
32
Interim analysis requires unblinded access to
treatment group assignments - 4.1
Interim analysis …involves access to …
unblinded data and results - 4.5
2011 FALL BIOMETRICS WEBINAR SERIES
33. Controlling Bias…Overreaction
33
The DMC does not make decisions
DMC has no vested interest (unlike company)
Monitoring boundaries are in place
Degree of empowerment of DMC comes from
Executive Committee and is described in the
Charter
2011 FALL BIOMETRICS WEBINAR SERIES
34. Summary
Patient safety is key
DMC is an independent group
Charter describes roles and
responsibilities
Monitoring boundaries are needed
DMC needs to be unblinded and needs to
assess both benefit and risk
2011 FALL BIOMETRICS WEBINAR SERIES
35. Upcoming Webinars
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Register at www.premier-research.com/webinars
▪ IVR/IWR…More than just Randomization
11 October at 11:00 am EDT
Speakers: Bruce Bailey and Ryan Michaud
▪ Streamlining Data Management Start-up
15 November at 11:00 am EST
Speaker: Cheryl Silva
▪ Strategies for Implementing CDISC
13 December at11:00 am EST
Speaker: Thomas Kalfas
2011 FALL BIOMETRICS WEBINAR SERIES
36. Questions?
Ronald Kershner, Ph.D.
Vice President, Biostatistics and Data Operations
Centre Square West
1500 Market Street, Suite 3500
Philadelphia, PA 19102
Telephone: 215.282.5444
ron.kershner@premier-research.com
2011 FALL BIOMETRICS WEBINAR SERIES