In clinical trials, there are usually different committees established to ensure the study protocol is executable, to ensure the integrity of the study, to monitor the safety of the clinical trial participants. The most common one is the Data Monitoring Committee (DMC) - previously called Data Safety Monitoring Board (DSMB), which is critical for conducting the interim analysis for safety or for efficacy (whether the interim results are too good (overwhelming efficacy) or futility (unlikely to achieve the statistical significance if the trial continues)). In FDA's Guidance for Clinical Trial Sponsors "Establishment and Operation of Clinical Trial Data MonitoringCommittees", DMC was defined as the following:
A clinical trial DMC is a group of individuals with pertinent expertise that reviews on a regular basis accumulating data from one or more ongoing clinical trials. The DMC advises the sponsor regarding the continuing safety of trial subjects and those yet to be recruited to the trial, as well as the continuing validity and scientific merit of the trial. When a single DMC is responsible for monitoring multiple trials, the considerations for establishment and operation of the DMC are generally similar to those for a DMC monitoring a single trial, but the logistics may be more complex. For example, multiple conflict of interest determinations may be needed for each DMC member.
In this same guidance, two other clinical trial committees were mentioned to be compared with the DMC: Steering Committee (SC) and Endpoint Adjudication Committee (EAC). EAC may be called Clinical Endpoint Committee (CEC).
Clinical Trial Steering Committees In some clinical trials the sponsor may choose to appoint a steering committee; this committee may include investigators, other experts not otherwise involved in the trial, and, usually, representatives of the sponsor. A sponsor may delegate to a steering committee the primary responsibility for designing the study, maintaining the quality of Contains Nonbinding Recommendations 7 study conduct, ongoing monitoring of individual toxicities and adverse events, and, in many cases, writing study publications. When there is a steering committee, the sponsor may elect to have the DMC communicate with this committee rather than directly with the sponsor. Interactions between the steering committee and the DMC consist primarily of discussions during "open sessions" (see Section 4.3) of DMC meetings and the communication of recommendations following each DMC review of the trial. More extensive interactions might occur when early termination is being considered, or when external forces (e.g., announcement of results of related studies) impact the ongoing trial.
Endpoint Assessment/Adjudication Committees Sponsors may also choose to establish an endpoint assessment/adjudication committee (these may also be known as clinical events committees) in certain trials to review important endpoints reported by trial investigators to determine whether the endpoints meet protocol-specified criteria. Information reviewed on each presumptive endpoint may include laboratory, pathology and/or imaging data, autopsy reports, physical descriptions, and any other data deemed relevant. These committees are typically masked to the assigned study arm when performing their assessments regardless of whether the trial itself is conducted in a blinded manner. Such committees are particularly valuable when endpoints are subjective and/or require the application of a complex definition, and when the intervention is not delivered in a blinded fashion. Although such committees do not share responsibility with DMCs for evaluating interim comparisons, their assessments (if performed at frequent intervals throughout the trial with results incorporated into the database in a timely manner) help to ensure that the data reviewed by DMCs are as accurate and free of bias as possible.
In FDA guidance for Industry "Safety Assessment for IND Safety ReportingGuidance for Industry", a separate committee, Safety Assessment Committee or SAC, in short, was proposed. The SAC was defined as
"... a group of individuals chosen by the sponsor to review safety information in a development program and tasked with making a recommendation to the sponsor regarding whether the safety information must be reported in an IND safety report"
In a separate Guidance for Industry, "Sponsor Responsibilities— Safety Reporting Requirements and Safety Assessment for IND and Bioavailability/Bioequivalence Studies", the term 'Safety Assessment Committee" was not used, but the responsibility of a 'safety assessment team' was discussed.
All of these committees can be established to ensure patient safety and study integrity. The responsibilities across these committees are sometimes overlapped. The table below is created to compare these committees side by side:
|
Data Monitoring
Committee (DMC) |
Steering
Committee (SC) |
Clinical
Event Committee (CEC) |
Safety
Assessment Committee (SAC) |
Alternative names |
Data Safety
Monitoring Board (DSMB) Data Safety Monitoring
Committee (DSMC) |
|
Event
Assessment Committee (EAC) Event
Adjudication Committee (EAC) |
|
Responsibilities |
Monitoring
for effectiveness, safety, study conduct; Executing the adaptation rules for
adaptive designs; making recommendations for study modification, pause,
termination |
Designing the
study, maintaining the quality of study conduct, ongoing monitoring of
individual toxicities and adverse events, and, Helping the sponsor to execute
the study (for example enrollment); Writing study publications. |
Reviewing
important endpoints reported by trial investigators to determine whether the
endpoints meet protocol-specified criteria |
Reviewing
safety information in a development program; Performing aggregate safety
analyses; and making recommendations regarding whether the safety information
must be reported in an IND safety report |
Participating
in study design and protocol development |
May provide
the comments on the protocols |
Yes |
May provide
inputs related to the clinical events to be adjudicated |
Limited to the
safety reporting section of the study protocol |
External |
Usually external |
External |
External |
Usually internal
within the sponsor |
Independent |
Usually independent |
Usually not independent |
Independent |
Independent of
the study team |
Review aggregate
data |
Safety and
maybe also Efficacy |
Secondary
review |
Usually not |
Safety data
only |
Blinding |
Unblinded to
the treatment assignments. DMC can review fully unblinded data |
Blinded |
Usually blinded |
Blinded |
Participating
in clinical trial result reporting/publication |
Usually not |
Yes |
Usually not |
Usually not |
Documents |
DMC Charter DMC
Statistical Analysis Plan |
SC Charter is
optional |
CEC Charter,
Operational Manual, May employ a computer system to facilitate the
adjudication |
Safety Surveillance
Plan |
1 comment:
When a bias is possible, clinical trials are typically designed as double-blind studies to avoid conscious and unconscious bias in safety and efficacy assessment. Full access to the treatment assignment may also be requested by the drug safety group or pharmacovigilance group (PVG). They claim that full access to the treatment assignment is required for reporting serious adverse events.
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