Dan Shiu July 28, 2012 May 10, 2012 · The use of case report forms that incorporate SDTM-standard...
Transcript of Dan Shiu July 28, 2012 May 10, 2012 · The use of case report forms that incorporate SDTM-standard...
Agenda
Overview of major CDISC standards
Common implementation strategies and tools
FDA (CDER) guidance and concerns
Lessons learned
A Glance of CDISC Standards CDISC is a global, open, multidisciplinary, non-profit organization that
has established standards to support the acquisition, exchange, submission and archive of clinical research data and metadata.
PRM CDASH
LAB
SDTM
SEND
ADaM
Controlled Terminology
ODM XML
Define.xml
CDASH – Implementation
CDASH (Clinical Data Acquisition Standards Harmonization) defines basic standards for the collection of clinical trial data
Implement in EDC system to directly map CRF forms/folders/fields to SDTM domains/visits/variables
EDC edit checks can be built based on SDTM checks to catch conformance issues early
CDASH – Domains Adverse Events (AE)
Comments (CO)
Prior and Concomitant Medications (CM)
Demographics (DM)
Disposition (DS)
Drug Accountability (DA)
ECG Test Results (EG)
Exposure (EX)
Inclusion and Exclusion Criteria (IE)
Laboratory Test Results (LB)
Medical History (MH)
Physical Examination (PE)
Protocol Deviations (DV)
Subject Characteristics (SC)
Substance Use (SU)
Vital Signs (VS)
CDASH – SDTM Mapping
Scenario 1: Central ProcessingScenario 2: Local Processing Scenario 3: Central Processing with Secondary Site Assessment of Clinical Significance
CDASH – FDA Guidance “… The use of case report forms that incorporate SDTM-
standard data elements (such as with CDASH-style case report forms) allows for a simplified process for creation of SDTM domains. This approach is preferred to the alternative of collecting data in a non-standard format and then converting to SDTM format after the trial (legacy data conversion). Legacy data conversion is often complex and difficult, and CDER has received submissions in which reviewers have occasionally encountered difficulties while reviewing converted data.”
SDTM – Implementation SDTM (Study Data Tabulation Model) benefits regulatory agency:
Reviewers can be trained to work with the standardized data more effectively with less preparation time
Support FDA‘s efforts to develop a repository for all submitted trial data Support standard review tools to access, manipulate, and view the
source data
To create SDTM from raw data: Standard mapping specifications Maximal macros/utilities to execute mapping Minimal custom programming
To validate SDTM conformance: WebSDM/Janus rules OpenCDISC Validator
To validate SDTM mapping: Independent programming Risk-based QC
SDTM – FDA Guidance Custom Domains: “Prior to creating a custom domain,
sponsors should confirm that the data do not fit an existing domain …”
EPOCH: “Please include the variables EPOCH for every clinical subject-level observation …”
SE Domain: “The Subject Elements domain should be included …”
Column Length/Size: “Lengths/Sizes of columns should not arbitrarily be set to 200. For example, if your USUBJID column has a maximum length of 18 being used throughout the dataset, the USUBJID’s column size should be set to 18, not to 200.”
ADaM – Implementation ADaM (Analysis Data Model) datasets are source data plus
derived data , i.e. ADaM = (SDTM-) + derivation: To support statistical analysis by simplifying the programming steps
necessary to perform an analysis (a.k.a. analysis-ready) To enable traceability from analysis results presented in the CSR
back to the original data elements collected in the CRF and represented in SDTM datasets
To create ADaM from SDTM: Standard mapping specifications Maximal macros/utilities to execute mapping Minimal custom programming
To validate ADaM conformance: CDISC ADaM validation rules OpenCDISC Validator
To validate ADaM derivation: Independent programming Risk-based QC
ADaM – Mapping Specification Challenge for Parameter Value-Level Metadata
PARAM AVAL BASE AVALCAT CRIT CRITFL
LAB XYZ (mg/dl)
Calculate as medianvalue of multiple measures if present
Calculate as average of all pre-baseline measures
CT of: HIGH, NORMAL, LOW
Value is > 120 Y or N
LAB ABC (g) Select maximum value if multiplemeasures are present
Select value immediately prior to 1st dose
CT of: PANIC HIGH, TELEPHONE PANIC, PANIC LOW,
RATIO OF XYZ / ABC
AVAL of LAB XYZ divided by AVAL of LAB ABC
BASE of LAB XYZ divided by BASE of LAB ABC
65<=ratio<=80 Y or blank
From CDISC ADaM document:
In reality you want a dataset like this:
ADaM – FDA Guidance “… the submission of data in SDTM format does not
eliminate the need for submission of analysis datasets, whether in the ADaM format (preferred) or in an alternative format.”
“Analysis datasets should be derivable from the SDTM datasets, in order to enable traceability …”
“In addition to the variables specified for ADSL …, it is expected that the sponsor will include multiple additional variables representing various important baseline patient characteristics.”
“It is often useful for sponsors to provide their programsused to create ADaM datasets to help clarify how exactly they were created.”
Controlled Terminology –Implementation
Data values for CDISC standards-specified variables should use the CDISC Controlled Terminology, which is maintained and distributed as part of NCI Thesaurus
CDISC Controlled Terminology standards have been developed from CDASH, SDTM, SEND, and ADaM
Implementation must be built into EDC, SDTM/ADaM mapping, and validation tool
Controlled Terminology – Guidance
FDA: “For variables for which no standard terminology exists, or if the available terminology is insufficient and needs to be extended, the sponsor may propose their own terminology.”
CDISC: “All possible values for the variable within the trial should be included in the define.xml, except in the case of external dictionaries.” What would be included in define.xml for a female-only
study? F=Female M=Male UNKNOWN=Unknown UN=Undifferentiated
Define.xml – Implementation Define.xml is a Data Definition Document describing the
content and structure of submission data in a machine-readable format (.xml)
To create define.xml OpenCDISC Validator
Custom-built macros/utilities to collate all submission artifacts (datasets, mapping template, aCRF, Reviewer’s Guide, SAP, TLG, analysis programs)
To validate define.xml WebSDM/Janus rules
OpenCDISC Validator
Define.xml – ADaM Parameter Value-Level Metadata Challenge
From CDISC ADaM document:
Variable Metadata for Dataset ADLB
Variable Name
Variable Label
Variable Type
Display Format
AVAL Analysis Value
float 7.3
Parameter Value Level Metadata for ADLB.AVAL
Variable Value
(Where PARAMCD=)
Label
(Where PARAM=)
Variable Type
Display Format
Source / Derivation
AVAL XYZ LAB XYZ (mg/dl)
float 7.3 Calculate as median value of multiple measures if present
AVAL ABC LAB ABC(g)
float 7.3 Select maximum value if multiple measures are present
AVAL RXYZABC RATIO OF XYZ / ABC
float 7.3 AVAL of LAB XYZ divided by AVAL of LAB ABC
AVAL HYS1FL Elevated Transminase
float 7.3 <blank>
AVAL HYS2FL Elevated
Transminase
and Elevated Bilirubin
float 7.3 <blank>Orange are PARAM represented by *DEFAULT*Yellow are other non-default PARAMS
But the define.xml should display:
Define.xml – FDA Guidance “A critical component of data submission is the define file.
A properly functioning define.xml file is an important part of the submission of standardized electronic datasets and should not be considered optional.”
“As a transition step, CDER prefers that sponsors submit both the define.pdf and define.xml formats. The define.pdf is primarily for printing purposes and need not include hyperlinks.”
“…, sponsors should make certain that every data variable’s codelist, origin, and derivation is clearly and easily accessible from the define file. An insufficiently documented define file is a common deficiency that reviewers have noted.”
“Please provide supporting documentation that describes the non-standard terminology that is used. The define.xml is the preferred mechanism for documenting such terminology issues.”
CDISC Submission Package in eCTD
Tabulations SDTM datasets (.xpt) SDTM annotated CRF Define.xml Define.pdf Reviewer’s Guide
Analysis ADaM datasets (.xpt) Define.xml Define.pdf Reviewer’s Guide Analysis programs
(.sas) SAP TLG
Lessons Learned – Maintain a CDISC Study Registry Current CDISC standard versions
CDASH: 1.1 SDTMIG: 3.1.3 (released 7/16/2012, TR and TU under review) ADaMIG: 1.0 Define.xml: 1.0 Controlled Terminology
CDASH: 6/29/2012 SDTM: 6/29/2012 ADaM: 7/22/2011
Software tools/macros/utilities/templates versions Keep track of versions of CDISC standards used for each
study can help: Plan for migration Document the Reviewer’s Guide
Lessons Learned – Maintain a CDISC Standard Hierarchy
Implementing CDISC standards on project-by-project basis is:
Inefficient
Inconsistent
Difficult for ISS and ISE
Confusing to regulatory agency
Standard Hierarchy
CDISC Sponsor TA Product Study Analysis
References CDISC: http://www.cdisc.org
FDA CDER Common Data Standards Issues: http://www.fda.gov/downloads/Drugs/DevelopmentApprovalProcess/FormsSubmissionRequirements/ElectronicSubmissions/UCM254113.pdf
Medidata Rave: http://www.mdsol.com/products/rave_overview.htm
Kinship EXACT: http://kinshiptech.com/products.htm
OpenCDISC Validator: http://www.opencdisc.org