The CDISC/FDA Integrated Data Pilot: A Case. Support an Integrated Review



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The CDISC/FDA Integrated Data Pilot: A Case Studyin Implementing CDISC Standards to Support an Integrated Review d Wise Technologies Chris Decker Life Sciences Director

Overview Pilot Mission and Goals Summary of the Pilot Data Analysis Methodology SDTM Findings ADaM Findings Integrated Findings Define.xml Updates Deliverables, Pilot Status, and Timelines

Team Members Thank you! Co Leaders: Chris Decker, Steve Hirschfeld, Yuguang Zhao Veterans: Rookies: Victims (FDA): Greg Steffens Nate Friemark Adam Huang Asif Taiyabi Karen Wade Thaddea Dreyer Joyce Korvick Thomas Marciniak Nancy Snow Aileen Yam Eric Qui Sandy Lei Ian Fleming Deven Dharm Bob Dainton Ann Krebs Arline Nakanishi Ugochi Emeribe Richard Lewis Lex Jansen Brian Mitchell Geoff Mann Carrie Mazzrillo Ramana Setty Archie Chaudhari Frank Roediger Pam Cahalin Ana Szarfman Gwen Zornberg Mina Hohlen Patty Garvey Amy Malla (CBER) Crystal Allard (CBER) Jingyee Kou (CBER) Gale Heavner (CBER) Jessica Kim (CBER)

Integrated Data Pilot Mission The mission of the CDISC Integrated Data Pilot is to demonstrate that a data submission created using CDISC Harmonized Standards will meet the needs and expectations of FDA reviewers in conducting an integrated review of data from multiple studies and compounds.

CDISC Pilot Goals Assess the applicability of the CDISC models to integrate data Identify any issues/questions to be addressed by the CDISC Teams Validate the components of the CDISC models can effectively be used together Evaluate the most current CDISC models including SDTM, ADaM, ODM/Define.xml, and Trial Design Anything that Becky or Dave asks us to do

Overview of Pilot Data 3 compounds/8 studies Multiple Clinical trials Population included children with hypertension Trial Designs Pharmacokinetics trials Randomized double blind blindtrials Artificial test data composed of de identified and randomly modified data; provided as SDTM practice datasets

Overview of Pilot Data Documentation provided: One page summary of each study including study design schedule De identified data sets Initial domains provided: DM, AE, VS, EX, CM, DS, SC, PC, LB, MH

Analysis Approach Different then conventional analysis Limited by availability of documentation Decided to provide a integrated review of patient experience Not an ISS Not a comparison of Drug vs. Placebo Abnormal Events compared to Exposure

Analysis Approach Events include both adverse events, abnormal laboratory values, and abnormal vital signs Final abbreviated reports with descriptive statistics only Used standard reference ranges for vital signs and laboratory values All summaries will use ADaM domains Events Overall and by exposure, age, and gender

Metadata Framework Metadata collected in Excel spreadsheets Converted to SAS data sets and used for validation, adding attributes, t and dfi define

SDTM Development Data was supplied in SDTM like format Still took 3 months to clean it up Most of the issues were just bad data typical legacy data issues Interpretation of SDTM Derived ddata Baseline Flags

ADaM Development Cross team members made communication easier Used the current draft ADaM Implementation Guide Model open to interpretation significant discussions back and forth Implementation Guide is still draft 6, 9,12 months to hash through all these changes

ADaM Development Defining analysis subgroups robust and useful for everyone (ranges, variables, numeric/character) Defined three analysis subgroups both character and numeric Followed naming conventions in ADaMIG Treatment variables How to implement TRTxP variables for the more complex multi phase studies Include TRTxP only if it used in the analysis? We included everything Defining Phases within ADaM Analysis Phases/Visits not the same as SDTM (EPOCH/VISIT) Naming conventions? APHASE/AEPOCH?

ADaM Development Relationship between SDTM and ADaM What variables should you copy from SDTM to ADaM? Used din Analysis? Supportive? We only copied what was used in analysis If used in Analysis should we rename, A prefix? We renamed. Analysis Flags within ADSL ADSL Flags Confusion over flag rules subject level, parameter level, record level population flags, other flags Y, N, null or all of the above Defined multiple flags for abnormal AEs, Vital Signs, and Labs Record Level Flags Analyzed records or records that could be analyzed? Second flag to identify records that met a certain criteria. Defined as flag but should have probably used the Criteria rules

ADaM Development - Integration Building integrated ADaM using study ADaM How to define the metadata Proof of concept defined two major changes Exposure quartiles Definition of EPOCH across studies Challengesin Integrating differentstudy designs Led to defining integration for similar designs Other issues identified (e.g. time variables)

Integrated ADaM Summary Having Standardized ADaM made it easier However, still need to address differences Study designs Differences in data collected Integrating the standard was more efficient but still required additional work Where and what metadata do we define?

Define.xml Tasks Worked with XML Technologies team to provide support for row level metadata Adding extension for Analysis Results Metadata based on Pilot 1 findings New style sheets and a PDF rendering of the define.xml for human readable format

Define.xml Value Level Explored multiple ways to support metadata First method involved extending define Seemed to work Ran into challenges capturing value level methods Redoing theimplementation based on define group feedback within existing define schema

Define.xml Analysis Results Capturing metadata for analysis results Added in first Pilot as an one off extension Worked with Define team for formal extension

Package Challenges Separate define files for SDTM and ADaM? Issues with the size of the files in first Pilot No real good solution for linking SDTM to ADaM or integrated data to the individual study data Storage of style sheets and define files

Final Deliverables Individual Studies SDTM domains and ADaM domains for 4 studies (NEW) Summary tables and Study Report for studies 1/2 Define files for SDTM and ADaM/Analysis Results Integrated Data ADaM domains for similar study designs within Compound A and across Compound A Clinical Study Report for Compound A Define files for Integrated ADaM/Analysis Results

Project Status Completed first two studies including data, tables, report, anddefinefiles define files Momentarily delivering first two studies to the FDAfor review Working on Integration of Compound A Integrated data and reports by end of the year (subject to change) g) Project report available beginning of 2010 (subject to change)

Pilot Summary Volunteer projects are hard Deliverables added during the process Testing a lot of different parts that are moving Models are open for interpretation lead to a variety of ways of doing it Provided good feedback to CDISC teams Define is powerful/flexible but can used in different ways Following standards leads to many efficiencies but there is still work Need to work on improving the process of defining and executing Pilots