Finding the Right Mentor

Quality mentorship is essential for a successful career in cardiothoracic surgery. From the premedical phase to the position of senior faculty, there are many benefits to having mentors who can provide insight, promote career advancement and facilitate professional opportunities. It is important to distinguish between a mentor and sponsor in seeking this career guidance because both are beneficial but serve different purposes. By being clear about one's professional goals, the mentor-mentee relationship can be optimized and lead to a fulfilling and productive career.

Implementation of Regulation (EU) No 536/2014 as a Non-commercial Sponsor: An Internal Survey and a Descriptive Analysis of Timelines

INTRODUCTION

To safeguard the safety and interests of subjects participating in clinical trials, their conduct is heavily regulated. The EU Clinical Trials Regulation (CTR) 536/2014 brings fundamental changes that will require sponsors to adapt their current way of working. One major change is the significant shortening of the permitted reply timelines to requests for information (RFI), which may require adaptations to established processes within an organisation. This study aimed to assess these reply timelines at the European Organisation for Research and Treatment of Cancer (EORTC), a non-commercial sponsor. Additionally, it aimed to investigate how the impact of the different CTR requirements is perceived by the organisation's staff.

METHODS

A retrospective analysis was performed to assess the length of reply to grounds of non-acceptance (GNA) timelines. Questionnaires were circulated to internal staff to assess their views on the impact of important changes the CTR introduces on the organisation's processes.

RESULTS

The average reply time to comments from regulators was 27.5 days, which is longer than the 12-day time limit required by CTR, which indicates that the organisation's processes require re-optimization to allow efficient activation of trials compliant with the new legislation. The majority of the staff that completed the questionnaire assessed the impact the CTR would have on the organisation to be positive. Finally, there was a large consensus about the changes related to the submission timelines, transition period and the user management of the Clinical Trial Information System (CTIS) having a very important impact on the organisation as a whole. Participants referred to the streamlined process of a clinical trial in different countries as foreseen in the CTR, as an aspect that would benefit the organisation.

DISCUSSION

For all retrospectively studied timelines, the average timelines to reply combined for competent authorities (CA) and ethics committees (EC) were longer than the 12 days allowed under the CTR. EORTC will have to adapt internal processes to meet the time limit imposed by the CTR without compromising its scientific integrity. The questionnaire respondents had the required expertise to provide an opinion on the CTR's impact on the organisation. There was a large consensus about the changes relating to the submission timelines having a very important impact on the organisation. This observation is in line with the results of the retrospective part of this study.

CONCLUSION

Based on the results of the retrospective and prospective parts of the study, it is clear that the shorter reply timelines are the main factor that will affect the organisation. EORTC has spent significant resources in adapting its processes to comply with the CTR's new requirements. Experience with the first studies under the new regulation can be utilized to implement further process adaptations.

Predictors of premature termination and completion of randomized controlled trials

Randomized clinical trials (RCTs) have a key role in progressing biomedical research and guiding clinical decision making, but premature termination remains high (up to 30%), raising concerns regarding funding expenditure and resource allocation. This brief report sought to identify variables associated with RCTs' premature termination and completion.

[Clinical trials with investigational medicinal products-initial experiences with the new EU clinical trial regulation 536/2014 and challenges and opportunities for contract research organisations]

The new authorisation procedure for clinical trials on medicinal products according to Regulation (EU) No 536/2014 (Clinical Trial Regulation - CTR) became applicable in the European Union and the European Economic Area on 31 January 2022. All involved parties communicate digitally via a specially programmed IT system, the Clinical Trial Information System (CTIS), provided by the European Medicines Agency (EMA). This article highlights the cooperation between sponsors and Contract Research Organisations (CROs) when applying the CTR and CTIS.First experiences and observed trends are described focusing on user administration in CTIS and on activities related to the protection of personal data and commercially confidential information (CCI) when clinical trials are published. Challenges for CROs are multifaceted and are discussed from different angles. For example, it is necessary for CROs to temporarily maintain a Quality Management System that serves both "systems": clinical trials under the EU-Directive 2001/20 as well as under the CTR. CTR and CTIS offer not only new tasks for CROs; they often become advisors for sponsors on the basis of their extensive experience, for example, regarding the cooperation model between sponsors and CROs and/or the strategic model for submission of a clinical trial. The article concludes with a look into possible future sponsor outsourcing strategies.

Comparison of Good Clinical Practice Inspection Processes for Marketing Applications Between the United States Food and Drug Administration and the European Medicines Agency

BACKGROUND

The U.S. Food and Drug Administration (FDA) and European Medicines Agency (EMA) began collaboration on Good Clinical Practice (GCP) inspections for marketing applications since 2009. The main characteristics of the GCP inspection processes between FDA and EMA were never evaluated. This is the first analysis comparing the GCP inspection processes between the two agencies.

METHODS

We examined and analyzed the key characteristics of the GCP inspection processes, including the geographical distribution, inspection types and timelines from application submission to final inspection reporting for marketing applications from September 2009 through December 2015.

RESULTS

Fifty-five shared applications were included for analysis. For these applications, a total of 433 GCP inspections were conducted in 47 countries. Most clinical investigator (CI) inspections were conducted in regions outside of each agency's own regulatory jurisdiction, while most sponsor/contract research organization (CRO) inspections were conducted in the U.S. by both agencies. Twenty-eight shared applications included common sites inspected by both agencies. There were 15 joint inspections conducted for seven of these applications and the remaining applications had common sites inspected by both agencies at separate times. Of the joint inspections, 73% were conducted in the U.S and 20% in the E.U. The median time from submission of an application to generation of final inspection reports was 232 days for FDA and 204 days for EMA, with no significant differences noted among applications with and without common sites.

CONCLUSION

The inspection processes and timelines between the two agencies were similar, providing support for continued FDA-EMA GCP collaboration.

Effect of sponsor on enrollment criteria in non-small cell lung cancer clinical trials

BACKGROUND

Inclusion and exclusion criteria in clinical trials are used to mitigate the effects of confounding variables on study outcomes. In 2017 and 2021, ASCO and the Friends of Cancer Research published recommendations to loosen enrollment criteria in cancer clinical trials to improve generalizability. The purpose of this study is to determine if the source of funding influences the degree of transparency and selection of inclusion and exclusion criteria.

METHODS

Phase 2 and 3 non-small cell lung cancer (NSCLC) drug trials on clinicaltrials.gov were grouped into one of three sponsor categories: industry, government/cooperative group, and academic. Strictness of specific criteria and the level of transparency in listing organ function requirements were analyzed using Fisher Exact tests. Independent sample t-tests were used to assess the variability in total number of criteria.

RESULTS

Organ function requirements listed on clinicaltrials.gov are more often vague or incomplete in industry sponsored trials compared to government/cooperative group (p = 2.3 × 10-10, α = 0.01) and academic (p = 1.8 × 10-4, α = 0.01) sponsored trials. Industry sponsored trials more often excluded patients with worse performance status scores compared to government/cooperative group sponsored trials (p = 5.7 × 10-6, α = 0.01).

CONCLUSION

Industry sponsored NSCLC drug trials are more likely to exclude patients with worse performance status and are less transparent in listing complete study requirements on clinicaltrials.gov.

POLICY SUMMARY

Unnecessarily strict enrollment criteria are increasingly seen in clinical trials sponsored by industry. Regulators responsible for drug approvals should note when studies deviate from ASCO and Friends of Cancer Research framework and question the external validity of study findings with overly narrow enrollment criteria when making decisions on drug approvals.

Descriptive Analysis of Good Clinical Practice Inspection Findings from U.S. Food and Drug Administration and European Medicines Agency

Background

The United States Food and Drug Administration (FDA) and European Medicines Agency (EMA) have collaborated in good clinical practice (GCP) inspections since September 2009. The two agencies operate under different regulatory frameworks for GCP oversight. No systematic assessments of GCP inspection findings have been reported.

Methods

We identified common inspections of clinical investigators, sponsors, and contract research organizations conducted by both agencies in support of marketing applications that had the same trial data submitted between 2009 and 2015. We grouped inspection findings into deficiency areas. We reviewed and compared these findings and calculated concordance rate for each deficiency area.

Results

Twenty-six clinical investigator sites and 23 sponsors/contract research organizations were inspected by both agencies in support of 31 marketing applications during this period. For FDA, the most common GCP findings were deficiencies related to Protocol Compliance for clinical investigator inspections and Trial Management issues for sponsor/contract research organization inspections. For EMA, deficiencies related to Documentation (including Trial Master File) were the most common findings for both clinical investigator and sponsor/contract research organization inspections. There was high concordance, of approximately 90%, for deficiencies related to Protocol Compliance for clinical investigator inspections and Trial Management for sponsor/contract research organization inspections between the two agencies. There was a concordance rate of about 70% for Documentation deficiencies for both clinical investigator and sponsor/contract research organization GCP inspections.

Conclusion

GCP inspection findings from 49 common clinical investigator and sponsor/contract research organization inspections were comparable, providing support for continued FDA-EMA GCP collaboration.

An FDA Analysis of Inspected Entities After Receiving Official Action Indicated Letters for Good Clinical Practice Violations

BACKGROUND

Limited research has been conducted to examine whether clinical investigators (CIs), sponsors (SPs), contract research organizations (CROs), and sponsor-investigators (SIs) continue conducting clinical trials following issuance of FDA Official Action Indicated (OAI) letters. FDA issues OAI letters for significant regulatory violations. The objective of this study was to evaluate the status of inspected entities who received OAI letters in the conduct of Center for Drug Evaluation and Research (CDER)-regulated clinical trials (CRCTs).

METHODS

This cross-sectional study included an analysis of inspectional data from CDER's Good Clinical Practice (GCP) inspections for OAI letters issued from October 1, 2010, to September 30, 2015, with an in-depth analysis of post-OAI status of inspected entities, including OAI follow-up inspections.

RESULTS

Of the 2248 GCP letters issued during this period, 104 (4.6%) OAI letters were sent: 95 (4.2%) to CIs (91% of OAIs), 7 (0.3%) to SPs (7% of OAIs), and 2 (0.08%) to SIs (2% of OAIs). Majority of OAI letters were issued as a result of a for-cause inspection. Five CIs were excluded from analysis. No OAI letters were sent to CROs. Only 30% of CIs (27 out of 90) continued to conduct CRCTs. OAI follow-up inspections were completed for these CIs resulting in 16 No Action Indicated (NAI), 11 Voluntary Action Indicated (VAI), and no OAI letters. Majority (64%) of the VAI letters noted repeated but not significant violations.

CONCLUSIONS

Majority (70%) of CIs who received an OAI letter were no longer conducting CRCTs at the time of follow-up. Of the 27 CIs continuing CRCTs, 16 (59%) OAI follow-up inspections resulted in NAI classifications and 11 (41%) in VAI.

Team sponsors in community-based health leadership programs

Purpose The purpose of this article is to share the lessons learned about the role of team sponsors in action-learning teams as part of community-based health leadership development programs. Design/methodology/approach This case study uses program survey results from fellow participants, action learning coaches and team sponsors to understand the value of sponsors to the teams, the roles they most often filled and the challenges they faced as team sponsors. Findings The extent to which the sponsors were perceived as having contributed to the work of the action learning teams varied greatly from team to team. Most sponsors agreed that they were well informed about their role. The roles sponsors most frequently played were to provide the teams with input and support, serve as a liaison to the community and serve as a sounding board, motivator and cheerleader. The most common challenges or barriers team sponsors faced in this role were keeping engaged in the process, adjusting to the role and feeling disconnected from the program. Practical implications This work provides insights for program developers and community foundations who are interested in building the capacity for health leadership by linking community sponsors with emerging leaders engaged in an action learning experience. Originality/value This work begins to fill a gap in the literature. The role of team sponsors has been studied for single organization work teams but there is a void of understanding about the role of sponsors with multi-organizational teams working to improve health while also learning about leadership.

Association Between Financial Conflicts of Interests and Supportive Opinions for Erectile Dysfunction Treatment

A conflict of interest (COI) is a situation in which a person has competing loyalties or interests that make it difficult to fulfil his or her duties impartially. Conflict of interest is not categorically improper in itself but requires proper management. A SCOPUS literature search was performed for publications on the efficacy/safety of Phospho-Di-Esterase Inhibitors (PDEIs) for treating erectile dysfunction. A categorization tool (CoOpCaT) was used to review and classify the publications as supportive/not-supportive for the discussed active ingredient and reporting or not reporting a COI for that specific drug or for the remaining PDEIs (i.e. competitors). Multivariable binary logistic regression was performed. In the 419 selected records the prevalence of supportive opinions was higher when a COI for the index label was declared. The CoOpCaT showed good internal consistency, discriminative validity and intra/inter-rater agreement. The strongest predictor for a supportive opinion was the total number of financial COIs for the index label. A mild protective effect of the total number of financial COIs for any competitor label was noted. Financial COIs have frequently been associated with bias, and the measures currently adopted to restrain it lack effectiveness. Some evidence for monitoring and/or compensating this bias is reported here, but the ultimate solution remains distant.

Bioanalytical method transfer considerations of chromatographic-based assays

Bioanalysis is an important part of the modern drug development process. The business practice of outsourcing and transferring bioanalytical methods from laboratory to laboratory has increasingly become a crucial strategy for successful and efficient delivery of therapies to the market. This chapter discusses important considerations when transferring various types of chromatographic-based assays in today's pharmaceutical research and development environment.

Evaluating alcoholics anonymous sponsor attributes using conjoint analysis

Alcoholics Anonymous (AA) considers sponsorship an important element of the AA program, especially in early recovery. 225 adult individuals who had experience as either a sponsor, sponsee, or both, participated in a hypothetical sponsor ranking exercise where five attributes were varied across three levels. Conjoint analysis was used to compute part-worth utility of the attributes and their levels for experience, knowledge, availability, confidentiality, and goal-setting. Differences in utilities by attribute were found where confidentiality had the greatest overall possible impact on utility and sponsor knowledge had the least. These findings suggest qualitative differences in sponsors may impact their effectiveness. Future research on AA should continue to investigate sponsor influence on an individual's overall recovery trajectory.

Development, implementation and critique of a bioethics framework for pharmaceutical sponsors of human biomedical research

Pharmaceutical human biomedical research is a multi-dimensional endeavor that requires collaboration among many parties, including those who sponsor, conduct, participate in, or stand to benefit from the research. Human subjects' protections have been promulgated to ensure that the benefits of such research are accomplished with respect for and minimal risk to individual research participants, and with an overall sense of fairness. Although these protections are foundational to clinical research, most ethics guidance primarily highlights the responsibilities of investigators and ethics review boards. Currently, there is no published resource that comprehensively addresses bioethical responsibilities of industry sponsors; including their responsibilities to parties who are not research participants, but are, nevertheless key stakeholders in the endeavor. To fill this void, in 2010 Eli Lilly and Company instituted a Bioethics Framework for Human Biomedical Research. This paper describes how the framework was developed and implemented and provides a critique based on four years of experience. A companion article provides the actual document used by Eli Lilly and Company to guide ethical decisions regarding all phases of human clinical trials. While many of the concepts presented in this framework are not novel, compiling them in a manner that articulates the ethical responsibilities of a sponsor is novel. By utilizing this type of bioethics framework, we have been able to develop bioethics positions on various topics, provide research ethics consultations, and integrate bioethics into the daily operations of our human biomedical research. We hope that by sharing these companion papers we will stimulate discussion within and outside the biopharmaceutical industry for the benefit of the multiple parties involved in pharmaceutical human biomedical research.

Eli Lilly and Company's bioethics framework for human biomedical research

Current ethics and good clinical practice guidelines address various aspects of pharmaceutical research and development, but do not comprehensively address the bioethical responsibilities of sponsors. To fill this void, in 2010 Eli Lilly and Company developed and implemented a Bioethics Framework for Human Biomedical Research to guide ethical decisions. (See our companion article that describes how the framework was developed and implemented and provides a critique of its usefulness and limitations.) This paper presents the actual framework that serves as a company resource for employee education and bioethics deliberations. The framework consists of four basic ethical principles and 13 essential elements for ethical human biomedical research and resides within the context of our company's mission, vision and values. For each component of the framework, we provide a high-level overview followed by a detailed description with cross-references to relevant well regarded guidance documents. The principles and guidance described should be familiar to those acquainted with research ethics. Therefore the novelty of the framework lies not in the foundational concepts presented as much as the attempt to specify and compile a sponsor's bioethical responsibilities to multiple stakeholders into one resource. When such a framework is employed, it can serve as a bioethical foundation to inform decisions and actions throughout clinical planning, trial design, study implementation and closeout, as well as to inform company positions on bioethical issues. The framework is, therefore, a useful tool for translating ethical aspirations into action - to help ensure pharmaceutical human biomedical research is conducted in a manner that aligns with consensus ethics principles, as well as a sponsor's core values.