| Literature DB >> 34590417 |
Greg A Jicha1, Erin L Abner2, Steven E Arnold3, Maria C Carrillo4, Hiroko H Dodge5, Steven D Edland6, Keith N Fargo7, Howard H Feldman8, Larry B Goldstein9, James Hendrix10, Ruth Peters11,12,13, Julie M Robillard14, Lon S Schneider15, Jodi R Titiner4, Christopher J Weber4.
Abstract
BACKGROUND: Consensus guidance for the development and identification of high-quality Alzheimer's disease clinical trials is needed for protocol development and conduct of clinical trials.Entities:
Keywords: Alzheimer's disease; Delphi; clinical trial; consensus; dementia
Mesh:
Year: 2021 PMID: 34590417 PMCID: PMC8960469 DOI: 10.1002/alz.12461
Source DB: PubMed Journal: Alzheimers Dement ISSN: 1552-5260 Impact factor: 16.655
Opening Delphi topics and questions developed by the facilitator/chair
| 1. Scientific justification |
| a. Irrespective of whether you agree with the premise or pre‐trial data, is there sufficient justification for the trial? |
| b. Does the data have to come from one lab or more? One site or more? |
| c. Should the data be published or accessible prior to trial engagement? Or should it be shared with the participants in other ways, and if so what are the checks to ensure validity? |
| 2. Regulatory issues |
| a. Is trial registration important (both US and international)? |
| b. Are IRB or other human subject protection certifications important? |
| c. Is funding or funding source important? |
| d. Are conflicts of interest for the investigators important? |
| 3. Conduct |
| a. Should the trial population be defined? How should recruitment be conducted? Are there ways recruitment is conducted that call into question the validity of the clinical trial? |
| b. Should the intervention be defined? Multi‐component testing and supplement packages versus personalized medicine? |
| c. Should the duration of the trial be defined? As long as you pay you can continue to engage? |
| d. Should outcomes be prespecified? |
| e. Should the participant have to pay? If so, what is reasonable to pay for and what is not? Limits? |
| f. Do we need placebo? If so, should one be able to influence the decision to be randomized to the placebo versus control group? |
| 4. Off‐label treatment versus clinical trial? |
| a. What differentiates an open‐label trial from recurrent off‐label use of a treatment? |
| 5. Perceptions of approval delay |
| a. Why should a person or investigator wait for a drug to be tested and approved before being given access to it? |
| b. Humanitarian use? |
| 6. Do results need to be published? Shared in other ways? |
| 7. Other? |
Abbreviation: IRB, institutional review board.
Areas of agreement in round #1 of the Delphi process
| Issue/topic | Agreement % (yes/no) |
|---|---|
| Intervention should be defined | 100/0 |
| Outcomes should be prespecified | 100/0 |
| All research‐related activities including the trial drug and or intervention should be paid for by the trial | 100/0 |
| Participants may be responsible for time committed to the trial, travel costs, and standard of care for the medical condition under study and other medical conditions the subject may have in a legitimate clinical trial | 100/0 |
| Risk‐benefit information need not be included in advertising, but is necessary in the consent and consent processes | 100/0 |
| Public‐facing materials should specify whether the use of a medicine is off‐label or part of a clinical trial | 100/0 |
| Using experimental medicines to support the “Right to Try” Act is appropriate, outside of clinical trial engagement | 100/0 |
Areas of disagreement in round #1 of the Delphi process
| Issue/topic | Agreement % (yes/no) | Discussion |
|---|---|---|
| Justification for the trial shared with participants | 61/39 | Pros |
| • Participants should be made aware of the rationale for why they are potentially receiving an unapproved medication or intervention | ||
| Cons | ||
| • Providing too many details of the trial including outcomes may skew data by facilitating study of outcome measures or enhancing placebo effects | ||
| Should the participant have to pay | 80/20 | Pros |
| Not all studies have adequate grant support and yet the study may be important to do | ||
| Cons | ||
| • The study should pay for all research‐related costs | ||
| • Participants may have to subsume costs for travel, time spent, and standard of care diagnostic procedures and treatment for their condition | ||
| • Financial interests of the investigator and site should be made clear to the research participant and their surrogate | ||
| Need for placebo | 80/20 | Pros |
| • The inclusion of a placebo arm is necessary for absolute determination of the safety and efficacy of treatments in Phase II & III studies | ||
| Cons | ||
| • High‐quality Phase I and open‐label studies may provide a wealth of information justifying the design | ||
| • Placebo may not be needed for studies in which the natural history is well known and subject characteristics are matched to historical data | ||
| Risk/benefit in advertising | 86/14 | Pros |
| • Open and full disclosure is recommended whenever possible, and is mandated as part of the full consent process | ||
| Cons | ||
| • Full disclosure may be too extensive for limited advertising efforts in terms of cost and ability to convey detailed information | ||
| Differentiating open‐label trial from off‐label use | 86/14 | Pros |
| • All use of experimental (unapproved) therapies should specify whether the use is part of a clinical trial or is being provided off‐label, potentially as a “Right‐to‐Try” effort | ||
| Cons | ||
| • Off‐label use and retrospective data analysis can provide important insights and should not be discouraged | ||
| Importance of testing a medicine before using it in clinical practice | 86/14 | Pros |
| • Off‐label use of an approved or experimental (unapproved) medicine or intervention may provide an important option to patients to treat otherwise incurable conditions | ||
| Cons | ||
| • Off‐label use of medicines (approved or experimental) does not include the safety precautions and oversight of safety inherent in clinical trials. Understanding such safety issues and ensuring proactive safety monitoring is part of the reason why clinical trials are recommended in lieu of off‐label use | ||
| Importance of an open‐label extension (OLE) | 57/43 | Pros |
| • OLEs guarantee every subject the opportunity to have access to the experimental medicine irrespective of the need for placebo | ||
| • OLEs allow for additional safety and efficacy analysis that may help move experimental medicines forward | ||
| Cons | ||
| • OLEs may be used coercively to guide engagement in one trial over another competing study |
Areas of agreement in round #2 of the Delphi process
| Issue/topic | Agreement % (yes/no) |
|---|---|
| Justification for the trial shared with participants without overindulging details that may skew results | 100/0 |
| Disclosure of funding source is important | 100/0 |
| Disclosure of COI for study investigator is important | 100/0 |
| Trial population should be defined | 100/0 |
| Intervention should be defined | 100/0 |
| Duration of trial should be defined | 100/0 |
| Coercive subject payments | 100/0 |
| Sharing and publication of data | 100/0 |
Abbreviation: COI, conflict of interest.
Final CHADS consensus recommendations
| Recommendation | Rationale |
|---|---|
| 1. High‐quality clinical trials should be designed and conducted to be adherent to the reporting principles specified in the published CONSORT statements and basic HSP standards mandated by regulatory authorities. | Regulatory oversight and reporting of results guidances are well established and should be adhered to in all instances. |
| 2. Adequate justification for the trial should be made available to participants including full disclosure of all positive and negative findings, as well as the lack of any relevant data that may influence their decision to participate. | Incomplete justification, presentation of only selected data, and/or the failure to present prior negative data precludes adequate disclosure of study rationale. |
| 3. Outcomes should be prespecified, but specifics may not necessarily be made available to participants to avoid bias in outcome measures. | To avoid statistical bias, changes in outcome measures should only be made prior to data analysis. To prevent “self‐study” by participants, discrete information on specific outcome measures may be withheld, but general descriptions should be provided. |
| 4. Participants may subsume costs for time committed to the trial, travel costs, and standard of care for the medical condition under study and other medical conditions the subject may have, but should never be responsible for research‐related costs or the experimental medication under the guise of a trial. | Charging patients for study procedures is a clear sign that the study may not be funded, undergone previous peer review, or may be “predatory” for financial gain by the investigators. Charging for the use of experimental or off‐label medicines should be considered “for‐profit” indicating that it is not part of a legitimate clinical trial. |
| 5. Risk/benefit disclosures are not necessarily required for advertisement but should be mandatory in consent processes. | While good clinical practice and HSP requires full disclosure of risk/benefit considerations, such information may be too detailed to be included in routine trial advertisements. |
| 6. Public‐facing materials should specify if the use of a medicine is off‐label or part of a clinical trial. | Describing the objective of treatment is necessary in delineating whether the use of an experimental or unapproved medicine/intervention is part of a clinical trial or off‐label use. |
| 7. The use of experimental medicines or off‐label use of approved medicines, in the spirit of the “Right‐to‐Try” act, should not be subject to guidances for clinical trial regulation or oversight. | Off‐label use as part of the “Right to Try” Act, should be specified as treatment that is not part of any clinical trial. |
| 8. Disclosure of trial registration, HSP oversight, funding source, and COI for the investigators is necessary. | It is critical that potential participants in any clinical trial understand the regulatory oversight and potential for financial benefit that may be driving the investigator to encourage their participation beyond their primary health interests. |
| 9. The trial should have a protocol in which the trial population (I/E criteria), intervention, duration are prespecified and made available to potential participants. | To avoid statistical bias, changes in trial design should only be made prior to data analysis. Participants should not be coerced into changes into continued participation if trial population indications, study intervention, or duration are changed after consent procedures have been finalized. Such changes should be conveyed and reconsent obtained with full disclosure of why such changes have been made to maintain the legitimacy of the trial. |
| 10. Trial participants should not be unduly influenced by payments, enhanced access to medical services which they may not otherwise receive, or other enticements for engagement. | While HSP protections including regulatory oversight provide such protections, the committee noted that there may be a great deal of variation in compensation for trial engagement. While this may at times be related to degree of funding, scrutiny of significant outliers in compensation may help indicate legitimate versus suspect clinical trial conduct. |
| 11. Participants should be informed that the trial results will be published or otherwise made available to the public and research community, and the investigator should be mandated to do so. | If a trial is legitimate, it should be prepared to share and or publish the data derived from research participation. Preconceived intent to collect data on participants receiving off‐label use of unapproved medications or interventions indicates an attempt to bypass regulatory oversight, suggesting a lack of legitimacy for the clinical trial. |
Abbreviations: COI, conflict of interest; CONSORT, Consolidated Standards of Reporting Trials; HSP, human subjects protections; I/E, inclusion/exclusion.