Data Management and OpenClinica® Infrastructure…..from scratch Elisa L Priest, MPH Manager of Clinical Trials Baylor Health Care System Dallas, Texas May 11, 2011
Background I’ve given advice to small groups trying to develop g g p y g p an FDA compliant data management infrastructure. These groups are often looking at OpenClinica because it is open source and freely because it is open source and freely available. However, OpenClinica is just one small part of the data management infrastructure that needs to be developed. This presentation d t b d l d Thi t ti describes the process that Baylor Health Care System has gone through in the past 4 years to y g g p y develop an FDA compliant data management infrastructure to support investigator‐initiated trials. trials
Overview • • • • •
Business Need Business Need Document Requirements Evaluate existing infrastructure l i i i f Phase 1: Basic Infrastructure Phase 2: More Infrastructure
• Lessons Learned
BUSINESS NEED BUSINESS NEED
Business Need Business Need • One small FDA regulated Phase II trial: – Original plan – In‐house DBMS – Would require extensive programming and validation to comply with FDA regulations
Then… • One larger FDA regulated, multi‐site Phase II Trial – Larger trial with similar startup timeframe – Multi‐site trial introduces complexity into data management
• One larger non‐FDA regulated, multi‐site Trial
Business Need Business Need
to capture and manage clinical data in to capture and manage clinical data in electronic format in a manner that meets FDA requirements meets FDA requirements
DOCUMENT REQUIREMENTS DOCUMENT REQUIREMENTS
Document Requirements Document Requirements • Regulatory (FDA) requirements Regulatory (FDA) requirements – Investigator initiated (Investigator = Sponsor)
• Data Management requirements Data Management requirements – Paper based Eventually EDC – Multi‐site – Multiple Trials – Different phases and therapeutic areas
• Additional business requirements
Regulatory Requirements Regulatory Requirements • 21 21 CFR part 11 CFR part 11 • Guidance for Industry: Computerized Systems Used in Clinical Investigations, May 2007 g , y • Guidance for Industry: Part 11, Electronic Records’ Electronic Signatures‐ g Scope and Application, August p pp g 2003 • General Principles of Software Validation; Final Guidance for Industry and FDA Staff, January 2002
Data Management Process Requirements • • • • • • • • • •
Creation of Entry Screens that mimic paper CRF y p p Edit checks Generate queries Manage discrepancies (queries/SECs) Study lock Extract data Coding dictionaries (MedDRA) E External data loading l d l di Paper tracking/process tracking Reporting Reporting
EDC versus Paper Requirements EDC versus Paper Requirements •
EDC‐ Electronic Data Capture Trial
•
Paper‐based Trial
– Generally longer study start‐up – Sites may begin enrollment before db is fully developed – All database building completed around the time of first patient in – Extensive edit checks built into forms (out of range, invalid, logic checks)
– Need data entry screens as the first sets of data come in (after first sets of data come in (after CRFs are monitored against source) – Edit checks on entry (usually too late for verifying source) late for verifying source)
– Study Coordinators enter data at site – Specialized data‐entry staff – Monitors compare source with electronic forms l f – Need 10‐12 weeks from Final Protocol
– Monitors compare paper CRF with source – Need 8 Need 8‐12 12 weeks from final CRF weeks from final CRF
Additional Business Requirements Additional Business Requirements • Training/Customer Support Available Training/Customer Support Available • IT support available • External Hosting l i
EVALUATE EXISTING EVALUATE EXISTING INFRASTRUCTURE
Existing Infrastructure Existing Infrastructure • Human Resources Human Resources – One Access database programmer – One data manager/ SAS programmer One data manager/ SAS programmer
• Health Care System IT network • SAS • Microsoft Access
Existing Infrastructure Existing Infrastructure Basically No data management infrastructure Basically…..No data management infrastructure
PHASE 1: BASIC INFRASTRUCTURE PHASE 1: BASIC INFRASTRUCTURE
Phase 1: Basic Infrastructure Phase 1: Basic Infrastructure • • • •
Data management/Data Capture Software Data management/Data Capture Software Software Training Define Data Management Processes fi Develop SOPs
You should also have a Documented Plan! You should also have a Documented Plan!
Phase 1: Software Phase 1: Software
Software Training
Validation
DM Processes Training
SOPS
Software Review Process Software Review Process • Business needs/ Requirements Business needs/ Requirements • Determine priorities for software system: Determine priorities for software system: – Time: When must you have the solution in place? y p – Budget: What dollar figure must you not exceed? – Value: To what extent does the product have to meet your needs? – Scalability: how long do you expect to use this product?
Software Infrastructure Software Infrastructure Review
Training
Develop SAS abstraction b t ti
Choose
Purchase
*Validation
Installation of Installation of multiple environments
Validation Plan Validation Plan • Review Review Validation Documentation Provided by Validation Documentation Provided by Akaza Research • Develop User Requirements Develop User Requirements • Develop Performance Qualification Test Plan • Develop or modify additional documentation • Perform validation according to plan and document
Timeline
July 2007
• Review Regulations
Fall 2007
• Software Software Requirements and Requirements and Evaluation
Spring 2008
• BIS software recommendations • PO for OpenClinica for BIIR
Fall 2008
• Installation of OpenClinica at BIIR
Fall 2009
• IHCRI requirements for OpenClinica
Spring 2010
• RFP for OpenClinica and PO started • Data Management SOPs
Sept 2010 October 2010
• PO Approved • OpenClinica Installed • Validation Project Began
November 2010
• Site Audit of Akaza
December 2010
• Finalization of Validation Plan
May 2011
• Continue “moving towards compliance”
Phase 1: DM Processes Phase 1: DM Processes
Software Training
Validation
DM Processes Training
SOPS
Data Management Processes and Phases of Research h f h Concept & & Design
Statistical Statistical Analysis
Reporting
Preliminary tests of data collection tools/process SAS or other Exposure, outcomes, Data Management Plan (DMP)‐ Id data programs confounders identified confounders identified requirements and standards and processes requirements and standards and processes Finalize data collection tools edit checks DMP Finalize data collection tools, edit checks, DMP
Reports and publications
Pl Planning i
E Execution i
Edit checks/cleaning Estimates of Determine measurement Id all variables used in protocol and event Build electronic capture (database, spreadsheet) effect table Analysis Validate e‐capture Statistical requirements for documentation Id all data from statistical analysis plan variables Collect data
Id all data for required reports: DSMB
Data receipt/tracking
Id all external data sources (charts, lab Data entry/ verification measures, ect) Document variable formats Id edit checks for variables
Queries and corrections Edit checks/cleaning Coding
Data collection tools: paper Case Report Data transfers from/to Forms (CRFs) Annotated CRF
Data integration Data integration Data process reports SAS or other programs
Estimates of effect E ti t f ff t
Termination
Archive data Archive A hi documents Metadata/docs Make data available for re‐ il bl f use
Developing Data Management Processes Draft SOP creation??
OC Training OC Training
Develop OC Expertise + + Use previous Experience
DM Process Training
Create DM Processes
Refine Processes
SOP creation
Standardize Standardize Processes across studies
Developing Data Management Processes • May be different for EDC vs. Paper May be different for EDC vs Paper – May need SOPs for both
• Start Start as simple as possible and then add as simple as possible and then add processes as need • Does not need to be perfect at first Does not need to be perfect at first • Depending on software capabilities, may need additional infrastructure for tracking forms additional infrastructure for tracking forms, queries… – Access Access based study database for tracking data based study database for tracking data management processes including forms and queries
Developing Data Management Processes • Our approach: Our approach: – Develop processes and familiarity with OpenClinica with a paper with a paper‐based based process process – Test EDC capabilities in a subset of patients to ensure clinical site comfort ensure clinical site comfort – Move to full EDC in future trials after infrastructure development p Paper
Paper + EDC
EDC
EDC first‐‐Why EDC first Why not? not? • Infrastructure for EDC Infrastructure for EDC – Knowledge/Expertise of OpenClinica – Provide Training for Clinical Site Provide Training for Clinical Site • General data entry training Study‐Specific Specific data entry training data entry training • Study
– Provide Support for Clinical Site • Answer questions when needed Answer questions when needed
– IT infrastructure for site – Maintenance of security/permissions Maintenance of security/permissions documentation
EDC first—Why EDC first Why not? not? • Infrastructure for EDC Infrastructure for EDC – Edit Check programming – Additional validation Additional validation – User acceptance testing completed by clinical site – eCRFs CRF ready for production (and validated) by d f d ti ( d lid t d) b time of study start
Why SOPs? Quality: GCP 5.1 Why SOPs? Quality: GCP 5.1 • The sponsor is responsible for implementing and gq y q y maintaining quality assurance and quality control systems with written SOPs to ensure that trials are conducted and data are generated , d documented (recorded), and reported in t d( d d) d t di compliance with the protocol, GCP, and the applicable regulatory requirements. applicable regulatory requirements. ICH Guideline for Good Clinical Practice E6(R1) 1996
Data Management SOPs Data Management SOPs • SOPs on DM Processes: all phases of research SOPs on DM Processes: all phases of research – Study Planning/Start up – Execution • • • • •
Filing/Storage Paper work flow Paper work flow Paper tracking Discrepancies/Queries Data Extract
– Study closure/ Archiving
Data Management SOPs Data Management SOPs • Create Listing of all SOPs needed Create Listing of all SOPs needed – caBIG – Good Clinical Data Management Practices from g the Society for Clinical Data Management – Practical Guide to Clinical Data Management (Prokscha)
• Prioritize Listing • Create SOPs • Responsibilities for personnel
Data Management SOPs Data Management SOPs • 25 Priority 1 SOPs 25 Priority 1 SOPs • Around 400 hours of creation time SOPs – SOPs (versioned) – Procedure descriptions/work instructions (not versioned) – Template Forms
SOPs
Scheduling
Scheduling
• Estimated Effort vs. duration – – – –
Draft Committee Review Committee Review Editing/Final Committee Review and sign off Executive Review and sign off
Example Weekly Schedule and Tasks Example Weekly Schedule and Tasks • This week 05/17/2010 • Writing: Due to Executive on 06/04/2010 – Study Database Data editing – Data Cleaning and Review
• Reviewing: Due to Review this week. Due to Executive on 5/28/10 – Database design and Creation (Change name to Study Database Design and Creation) Design and Creation) – Study Database Validation – Study Database Edit Check Programming
• Final Final Editing Monday/Tuesday/Wednesday: Due to Executive Editing Monday/Tuesday/Wednesday: Due to Executive 05/21/2010 – CRF Forms and Flow Management – Data Management Roles and Responsibilities g p
SOP on Programming SOP on Programming
Phase 1: Basic Infrastructure Phase 1: Basic Infrastructure • Maturity of Training Maturity of Training 1 Person Trained d
“Informal Informal Training Training” of of others as needed
• Training Topics – Data entry a ae y – Study Setup – Data Principles Data Principles – CRF Creation
Baylor‐specific Baylor specific standardizedtraining
Train the Trainer h
Develop ‘customized’ Develop customized training for each study
PHASE 2: MORE INFRASTRUCTURE PHASE 2: MORE INFRASTRUCTURE
Phase 2: More Infrastructure Phase 2: More Infrastructure • • • • •
Infrastructure Strategic Planning Infrastructure Strategic Planning EDC Support Data Management SOPs: Priority 2/3 SO i i 2/3 Data Management Training Data Management Competencies – Job Descriptions Job esc p o s – Training Matrix – Personnel Development Plans Personnel Development Plans
Lessons Learned: Implementing Clinical Trials in OpenClinica® Elisa L Priest, MPH Manager of Clinical Trials Baylor Health Care System Dallas, Texas May 11, 2011
Lessons Learned: Implementing Clinical Trials in OpenClinica l l l l II will review my experience building will review my experience building infrastructure using OpenClinica. Specifically, lessons learned while implementing multiple lessons learned while implementing multiple investigator initiated trials in OpenClinica. This will include organizing and tracking eCRF will include organizing and tracking eCRF development, versioning eCRFs, and creating paper CRFs compatible within the OpenClinica paper CRFs compatible within the OpenClinica framework
Lessons Learned: Overall Lessons Learned: Overall • Organization • Documentation • Change is certain!! g
Paper CRFs Paper CRFs • Read Read the protocol the protocol • Create your own study event chart • Compare the provided study event chart (if C h id d d h (if there is one) with yours to identify di discrepancies i • Identify/Organize data into repeating modules Identify the eCRF sections and headers • Identify the eCRF, sections, and headers
Study Event Chart/ CRF Matrix Study Event Chart/ CRF Matrix
Paper CRFs Paper CRFs • Recreate paper CRFs to be more compatible with OC interface – Listen to your gut: reformat if necessary!
• Be consistent in formatting to represent – eCRF title – Section S i – Headers
• Limit the number of columns • Limit unnecessary repeating groups (for data extract) • Be consistent in answer choices (1‐yes, 2‐no) B i t ti h i (1 2 )
Formatting of eCRF and Sections Formatting of eCRF and Sections
Paper CRFs Paper CRFs • Require Require testing of pCRFs testing of pCRFs with hardcopy proof with hardcopy proof that they have been tested • Send only PDFs to review Send only PDFs to review • Use a draft watermark and only remove it once CRFs are approved CRF d • Versioning and tracking changes is critical
Organizing and Tracking eCRFs Organizing and Tracking eCRFs • Use Use study event chart format study event chart format • Track initial design, testing, versioning • Track response options and response options k i d i text • Be consistent on response options and text across eCRFs in a study
Tracking development Tracking development
R Response Options O ti
eCRF development • Be organized and consistent Be organized and consistent – Naming folders and files – Naming variables across eCRFs Naming variables across eCRFs – Response Options and text
eCRF development • Develop in stages – – – – –
Local environment: Development and 1st testing Review and approval by second person Upload into testing environment Upload into testing environment Testing with real data by at least 2 different staff Versioned and uploaded into production
• Cannot Cannot change variable labels, types, response options change variable labels types response options rename variable • Versioning/change control is time consuming
pCRFs and eCRFs and eCRFs versioning • Link paper CRF versions with eCRF Link paper CRF versions with eCRF versions. versions
Lessons Learned Lessons Learned • You will make mistakes ou a e sta es • Learn from your mistakes Learn from your mistakes • Use the community Use the community – Prevent mistakes – Help others prevent mistakes p p – Contribute to Mantis when you find a potential problem
Thanks! • Dr. Sunni Barnes
• Consultants – Suzanne Prokscha – Dr. David Hardison
• IHCRI Clinical Trials Team IHCRI Clinical Trials Team – – – – – –
Monica Anand Tyson Bain Candice Berryman y Kristen Rose Deepa Putuvakkat Alicia Turoff
• Akaza Research
Thank you! Thank you! Elisa L Priest, MPH Manager of Clinical Trials Baylor Health Care System Dallas, Texas
[email protected]