| Literature DB >> 33283069 |
Antonella Bacchieri1, Andrea Rossi2, Paolo Morelli3.
Abstract
The COVID-19 virus diffusion is, nowadays, global and any clinical trial is potentially affected by the direct and indirect consequences of the COVID-19 during the pandemic. Any step, from protocol design to result's disclosure, needs to be revised to assess the impact of the COVID-19 on the study, evaluate the potential risks, and establish a mitigation plan. We have developed a series of recommendations, belonging to our experience in any aspect of clinical trials. We hope that the Risk and Mitigation actions for clinical trials during COVID-19 Pandemic (RiMiCOPa) will help all clinical trial professionals, patients, auditors, and assessors to ensure effective data management, statistics, and medical writing standards while conducting clinical trials in the pandemic.Entities:
Keywords: COVID-19; Clinical trials; Mitigation actions; Risk mitigation
Year: 2020 PMID: 33283069 PMCID: PMC7703225 DOI: 10.1016/j.conctc.2020.100682
Source DB: PubMed Journal: Contemp Clin Trials Commun ISSN: 2451-8654
Study Contingency & Risk Mitigation Plan (RiMiCOPa) statement for studies conducted in the COVID-19 pandemic – General aspects.
| Area | Risks | Mitigation actions | Urgent (Yes/No) |
|---|---|---|---|
| General | |||
| Guidance documents in addition to EMA and FDA guidelines | Certain Countries/Regions may have issued their guidance documents. A certain disease may require specific guidance; for example, the International Society For Heart And Lung Transplantation (ISHLT) has issued a document on patients with chronic lung/heart disease and transplant, mechanical circulatory support, and pulmonary vascular disease [ | Check the existence of guidance documents specific to COVID-19 impact/management in the therapeutic area. | Yes |
| Data Monitoring Committee (DMC) | If a DMC is not in place, consider implementing an independent DMC, as recommended by both EMA and FDA, with the responsibilities detailed in the “EMA - Points to consider on implications of COVID-19 on methodological aspects of ongoing clinical trials” [ | Yes | |
| Delay in study timelines | Delays in study timelines are expected as a consequence of many factors: EC meetings canceled, administration offices closed and not able to revise or sign CTAs, delays in protocol and IC amendment implementation, delays in patient recruitment, delays in data entry/cleaning/query resolution, backlog when the situation will be back to routine, etc. | The impact of these delays on the scheduled activities and their financial implications have to be carefully evaluated. An appropriate plan has to be stated. Publicly available data on clinical trial registries must be updated. The specific impact on different areas is discussed below. | Yes |
Abbreviations: DMC = Data Monitoring Committee; EC = Ethical Committee; CTA=Clinical Trial Application; IC=Informed Consent.
RiMiCOPa statement for studies conducted in the COVID-19 pandemic – Data Management.
| Area | Risks | Mitigation actions | Urgent (Yes/No) |
|---|---|---|---|
| Data Management | |||
| Impact of COVID-19 pandemic on patient safety | Patient safety is paramount and at the heart of every decision, regardless of any potential consequences for an ongoing trial. | The Investigators must continue collecting adverse events and other protocol-specified safety data (depending on the study) from the participants through alternative means, e.g., phone contact, virtual visit, alternative location for assessment, local labs, or imaging centers. | Yes |
| Other changes in study conduct | Contingency measures, such as delay of scheduled visits, withdrawal of trial participants, implementation of new methods for data collection (see more detailed list under Statistics) may be needed. | It is important to collect pragmatically and systematically information on pandemic-related measures and whether and how trial patients or trial conduct were affected, as well as on the sub-populations of exposed/non-exposed, and infected/non-infected patients. Sponsors and clinical investigators should document and report in CSR how restrictions related to COVID-19 led to the changes in study conduct and duration of these changes. | Yes |
| Protocol deviations | COVID-19 pandemic is likely to introduce more protocol deviations than normal. | Pre-plan how systematic deviations, due to the measures to face with the COVID-19 pandemic, are captured. Given the large expected number of such deviations, consider the use of | Yes |
| Missing data | An increase in missing data is expected. | It is important to capture specific information in the CRF explaining the reason(s) for the increased number of missing data, including the relationship to COVID-19. | Yes |
| Availability of technological tools at sites | IT systems and any other technological tools or the support for these systems may become temporarily unavailable. | Assess the continued availability of, and support for, information technology systems and any other technological tools that are needed to support the trial. | Yes |
| Changes in on-site monitoring visits | Monitors may not be able to access the trial sites for on-site visits as planned during the COVID-19 pandemic. | If planned on-site monitoring visits are no longer possible, the sponsor should consider optimizing the use of central and remote monitoring programs to ensure oversight of clinical sites. | No |
| Informed Consent | There may be a need to re-consent participants already included in the trial. | Define how to document this re-consent, especially if obtained through alternative ways. For example, if oral consent was obtained by phone, it could be supplemented with email confirmation. Then, normal consent procedures should be applied as soon as the patients can visit the site. | Yes |
| Impact of changes in IMP distribution on treatment compliance assessment | Changes in the distribution of the IMP may be necessary. | Assess the impact of any alternative shipping/returning of IMP on the evaluation of treatment accountability and patient compliance to treatment administration. | No |
Abbreviations: CRF=Case Report Form; CSR=Clinical Study Report; DMP = Data Monitoring Plan; DVP = Data Validation Plan; IMP= Investigational Medicinal Product; IT=Information Technology; SAE=Serious Adverse Event.
RiMiCOPa statement for studies conducted in the COVID-19 pandemic – Statistics.
| Area | Risks | Mitigation actions | Urgent (Yes/No) |
|---|---|---|---|
| Statistics | |||
| Changes in study conduct | Possible measures to be evaluated by Sponsors and Investigators are as follows: | The impact of protocol changes on clinical data quality, reproducibility, and interpretability needs to be accurately assessed. All planned modifications and additional analyses should be documented in the SAP before data unblinding. | Yes |
| Endpoint definition | It might be necessary to replace in-person endpoint assessment with remote assessment or extend the protocol-defined window of time for assessing the endpoint or include/remove components from a composite endpoint. New intercurrent events [ | The impact of any change in endpoint definition, either through a change in methods or a change in timing, should be carefully evaluated in sensitivity analyses. | Yes |
| Missing data/Increase in drop-out rate/Reduced length of follow up/Increase in variability | An increase in missing data is expected. As a result of the reduced quality of data, variability is likely to increase. | It is important to evaluate these aspects prospectively to assess the need to re-evaluate the trial's sample size. | Yes |
| Protocol deviations | COVID-19 pandemic is likely to introduce more protocol deviations than normal. | Before locking the database, the sponsors should address how protocol deviations related to COVID-19 will be handled in the pre-specified analyses in the SAP. | No |
| Difficulties in obtaining the investigational product at all or selected sites | COVID-19 pandemic is likely to cause problems in the supply of the investigational product. | Unavailability of the study treatment may be considered a pandemic-related intercurrent event (see above). | No |
| Presence of heterogeneous populations | Three patient groups will be likely created (pre, during, and post COVID-19), at least in the areas with significant COVID-19 infection spread: some patients were present in the trial before the start of the pandemic, some during the pandemic while possibly exposed to associated measures, and some after the end of the pandemic. | The external validity of trial outcomes may be affected by the presence of different trial populations. | No |
Abbreviations: SAP=Statistical Analysis Plan.
RiMiCOPa statement Study Contingency & Risk Mitigation Plan for studies conducted in the COVID-19 pandemic – Medical Writing.
| Area | Risks | Mitigation actions | Urgent (Yes/No) |
|---|---|---|---|
| Medical writing | |||
| Clinical Study Report | COVID-19 effects on the clinical trial must be described to let the regulatory authorities able to evaluate how the pandemic has affected the timelines, quality, and results of the study. | All changes and implications related to the COVID-19 pandemic must be described in the appropriate sections of the CSR (or in a separate study-specific document). Describe all the contingency measures implemented during the COVID-19 disruption to manage the study conduct. Document how restrictions related to COVID-19 led to the changes in study conduct and the duration of these changes. Provide a list of all participants affected by the COVID-19 related study disruption by unique subject number identifier and by investigational site, and a description of how the individual's participation was altered. Describe analyses and corresponding discussions that address the impact of the implemented contingency measures (e.g., trial participant discontinuation from investigational product and/or study, alternative procedures used to collect critical safety and/or efficacy data) on the safety and efficacy results reported for the study. Describe all changes that were needed to the planned protocol analyses as a result of the contingency measures and the following implications (for example, changes in the primary efficacy analysis, sample size re-assessment, etc.). Describe the effects of the measures implemented during the COVID-19 disruption on the quality of the study (if applicable). | Depending on the stage of the study |
| Publications from the study | COVID-19 effects on the communication plan must be evaluated. | All changes and implications related to the COVID-19 pandemic must be described in the appropriate sections of any disclosure/publication describing the clinical trial outcomes, to let the reader able to understand the effects of the COVID-19 pandemic on the timelines, results, and quality of the study reported in the disclosure/publication, in addition to GPP recommendations [ | Depending on the stage of the study |
| Study protocol | COVID-19 effects on the communication plan must be evaluated. | All changes and implications related to the COVID-19 pandemic must be described in the appropriate sections of the study protocol. | Depending on the stage of the study |
Abbreviations: CSR=Clinical Study Report; GPP = Good Publication Practice.