draft title gates mri experience utilizing a site audit ... · of your study sites relative to your...
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Gates MRI Experience Utilizing a Site Audit Selection Tool Derived from the MCC Site Selection/Conducting Scoring Tool
Maryann Livolsi, GCP Compliance Leader
Bill & Melinda Gates Medical Research Institute
Linda B Sullivan, Executive Director
WCG-MCC
Meet the Presenters
Maryann Livolsi – Bill & Melinda Gates Medical Research Institute, GCP Compliance Leader responsible for fostering and promoting GCP compliant environment, supporting a culture of quality, regulatory compliance and continuous inspection readiness. Over 29 years of experience in clinical research operations and quality assurance at small biopharmaceutical and large pharmaceutical companies.
Linda Sullivan is Co-Founder & Executive Director of WGC’s Metrics Champion Consortium (MCC), an industry association dedicated to leading the drug-development enterprise in adoption and utilization of standardized metrics and benchmarks to drive performance improvement. She has more than 30 years of experience helping healthcare and clinical research organizations improve processes that strengthen financial and quality outcomes.
Agenda
• Background Gates Medical Research Institute Mission
• Business Need Identified for Investigator Site Audit Selection
• Project Approach
• Risk-Based Auditing Tool Development
• Risk – Based Auditing Tool Implementation Results
• Future Considerations
• Summary
Introducing Gates MRI
September 2020
© 2019, Bill & Melinda Gates Medical Research Institute. All rights reserved.
Maryann Livolsi, Sr. Director GCP Compliance
s
Location Cambridge, MA (HQ), Seattle
StructureFully funded by a grant from
the Gates Foundation
Size ~67 as of January, 2020
Portfolio
Quality
Management
System
Quality and compliance systems implemented; first audit completed
Initial focus on TB drugs, BCG booster, malaria vx with novel adjuvants, shigella vaccines, MNCH portfolio
5
/ GATES MRI AT A GLANCE
DISCOVERY/
RESEARCH TRANSLATIONAL DEVELOPMENT
LATE-PHASE DEVELOPMENT
Lead candidate
optimization, pre-
clinical development,
working with early
research partners
GxP studies through
clinical POC in
the target population,
working with translational
development partners
Effective handoff
to late-phase
development partners
© 2020, Bill & Melinda Gates Medical Research Institute. All rights reserved.
/ the Foundation: We seek to execute
6
Alliances such as
TB Drug
EnablingTool
Development
InfluencingRegulatory
policy
InfluencingDelivery
and Pricing
Project Leadership
Global Partnerships
Program Strategy
Gates
MRI
• We share a common belief: all lives have equal value.
• Wholly-owned subsidiary of the foundation with secure
funding (15-year business plan and operating budget).
• The foundation’s extensive skills, expertise and long-
standing relationships across academia and industry
provide synergy.
• We are committed to bringing the latest industry
innovations to bear in our collective work.And many other capabilities…..
EnablingDrug Discovery
© 2020, Bill & Melinda Gates Medical Research Institute. All rights reserved.
Target
Validation
Pre-Clinical
Phase 1
Phase 3
Phase 2 Innovative
Clinical Trials
Translating from
Preclinical to
Development
CMC
Nonprofit
Biotech Model
Bridging
Innovation from
Private Sector
Translational
Medicine
Assay
Development
7
Our focus is translational medicine: advancing novel drug and vaccine candidates from the laboratory to human studies. Funneling many possible ideas into a few viable solutions is the most challenging stage of the research and development process, but we embrace this challenge.
We learn continuously from everything we do. If one, two, or 100 ideas don't turn into solutions today, they yield insights that help us succeed tomorrow.
/ Our Approach
8
"The best way to predict the future is to
invent it."
- Alan Kay
Business Need, Project Approach, Risk-Based Auditing Tool Development
Evidence –Based Decision
Making
Target Auditees Based on
Performance & Risks
Focus: HSP, Data Reliability,
The quick brown fox
jumps over the lazy dog.
Business Need: Risk – Based AuditingNew non-profit biotechnology company faced with many challenges
• Starting TB vaccine and drug clinical trials• Sites in South Africa
Gates MRI is small and still developing systems to support our clinical trial oversight processes
5Fundamental project management skills Of 2019
1 2 3 4 5
FDA presentation at MCC SummitBenchmark
Research
Initial Assessment
Information aligned with Gates MRI experiences and
approaches
Assessment Analysis
Leverage the MCC Site Selection Tool
and Metrics
Contacted Linda Sullivan
Substituted Quality Indicators as the
Risk Score
Risk Based Auditing Tool
Initial site audits based on their Risk
Score
ID of Sites
Project Approach: Investigational Site Risk – Based Auditing
Weighted Criteria Individual Site Scores Country & Site List Composite Scores
Criteria weighted as to relevance per protocol before
beginning scoring process
Each site is rated (Y/N) on a standard set of site
quality criteriaTool calculates score based on responses
Individual sites can be excluded from country & site list composite scoresComposite scores reported for all sites and selected sites only
MCC Site Selection & Site Study Conduct Quality Scoring Tool Key Features
Site Selection Quality (SSQ) which helps you evaluate the quality of the sites you plan to initiate. This tool should be used prior to selecting any sites for your protocol.
Site Study Conduct Evaluation (SSCE) tool which helps you evaluate the ongoing performance of your selected sites. This tool should be used during study conduct and/or study close.
MCC Site Selection & Site Study Conduct Quality Scoring Tool –Key Features
These Tools are
Linked
Scoring CriterionImportance to success of this protocol
Weight
(click on criterion to see a list of useful scoring questions and
related MCC metrics)
None
(0)
Low
(1)
Moderate
(2) Critical (3)
1 Site is meeting enrollment goals with evaluable subjects
2 Site has stable research staff and re-training is seldom required
3 Site is compliant with sponsor/CRO, ethical, legal, privacy requirements
4Site is able to produce quality, timely data (query rate is not an outlier
with study and/or regional norms)
5 Site resolves data queries per required timelines
6 Site is compliant with dosing/device use requirements
7 Site is compliant with management of drug/device supply
8 Site has demonstrated state of regulatory agency inspection readiness
9 Site is compliant with reporting and management of safety events
10 Site performs procedures in compliance with protocol requirements
11 Site handles and maintains equipment per protocol requirements
12Site's vendor data and vendor/sponsor escalation requirements are
satisfied
13 Site is compliant with/does not deviate from the study protocol
14 Site is compliant with applicable GCP requirements
Total of all weights 0
Number of criteria scored 0
©2011 Metrics Champion Consortium, Inc. All rights reserved
MCC Site Audit Selection Draft Tool – Key Features
14
att
rib
ute
s
Weight the importance of attributes
Click on criterion to see a list of
useful scoring questions and
related metrics
Select Y/N if expectations met
©2020 Metrics Champion Consortium, All rights reserved
Criterion Weighting
MCC Site Audit Selection Draft Tool – Key Features
Criteria from the weighting worksheet
Each one links to listing with useful scoring
questions and related metrics
Tool generates score using criteria weighting
established in criteria weights tab
©2020 Metrics Champion Consortium, All rights reserved
MCC Site Audit Selection Draft Tool – Key Features
Criterion from the weighting worksheet
Each one links to listing with useful scoring
questions and related metrics
Risk Based Auditing Tool Development
The initial categories were based on the metrics the CRO was collecting at each site and included:
# Enrolled
Participants
% Screen failed
Number of early discontinuations participants
( a QTL)
Number of participants missing QFT testing at required visit (a QTL)
% Protocol Deviations
Site reporting SAEs late
Query Status
Risk-Based Site Auditing Selection Tool
Provide evidence-based insights to understand the strengths and weaknesses of your study sites relative to YOURprotocol. • There are 14 criteria that a site must meet to
be successful• There is an option of selecting the 14 that
are most and least critical to the success ofYOUR protocol
• You should amend, as indicated, based on your critical data, processes, and other protocol-related risks, etc.
• Use this tool to select sites for an audit
Risk – Based Auditing Tool Implementation Results
Risk-Based Auditing Tool: Implementation Results
• Positive Outcomes• Successfully repurposed the Site Selection Tool
to a Site Audit Selection Tool• Utilized study specific assessments including
QTL criteria• Identified sites for audit selection using the
risk score• It is a work in progress as we grow our clinical
study portfolio• Issues:
• Data was assessed based on third month of the quarter to plan audits for next quarter
• Data is not normalized across sites• Due to lack of experience with the sites we did
not have any historical data to contribute to assessment
• Study specific criteria time consuming and prevents ability to assess study site risk scores across a program
budgeting
scheduling
communication
ThoughtLeadership
Implement
exe
cutesu
pp
ort
plan
Plan
Utilize KQIs from investigator sites as criteria to assign a risk score to each site
Execute
Adapt the MCC Site Selection Tool to create a Site Audit Selection Tool for active clinical studies.
Implement
Replaced the Site Selection Criteria with study specific KQIs for TB vaccine study
EvaluatePilot was success for initial site risk scores but use of normalized data is required for better on going assessment of sites during active studies
Summary
Future ConsiderationsAdding Leading Indicators
Next Update:Leading vs Lagging Metrics
Normalization has a variety of meaning in
statistics. In the context of metrics, it refers to
adjusting the scale used to make it easier to
compare values. Typically, this is accomplished
by dividing a count value by a relevant factor to
enable easier comparison. That relevant factor
is termed a normalization factor.
©2020 Metrics Champion Consortium, All rights reserved
Next Update:Leading vs Lagging Metrics
Lagging metrics provide information you can use for future trials or for baselining process-improvement efforts. They are typically generated after a finite step or a trial is completed.
Leading metrics provide information you can use during study conduct and should be defined to give as early a signal as possible so you can take action quickly to avoid the indicated issue and/or minimize its consequences. The normalization factor used can significantly impact how early a signal is detected. In some cases, the normalization factor that works well for a lagging metric is not the best option for a leading metric.
©2020 Metrics Champion Consortium, All rights reserved
Do Site Performance Metrics Need to be Modified When Used During Study Conduct?
Does the opportunity for the measurement increase over time?
When assessing an activity where the opportunity for an event to occur changes over time, you should consider including a time component as part of normalization.
©2020 Metrics Champion Consortium, All rights reserved
This is an important factor to consider when comparing site performance during study conduct if sites have patients enrolling at differing time points
Do Site Performance Metrics Need to be Modified When Used During Study Conduct?
Item being
Measured
Lagging Metric
Normalization
Factor
Leading Metric
Normalization
Factor
Rationale
Adverse EventsRandomized
Patient
Patient-Week
(data collection
with ePRO)
Patient Visit
(data collection at
patient visits)
Each week a patient is on the
study provides an opportunity
for AEs.
The number of Patient Visits
could also be used –
depending on the data flow.
Protocol
Deviations
Randomized
Patient
Patient-Week
Patient Visit
Each week a patient is on the
study provides an opportunity
for protocol deviations.
Patients with
premature drug
discontinuation
Randomized
patients
Patient-Weeks
Patient Visits
Each patient visit provides an
opportunity for the decision
to discontinue drug.
The number of Patient-Weeks
could also be used but may
not be as effective.
©2020 Metrics Champion Consortium, All rights reserved
Thank You! Please submit questions to the presenters using
the submit question link
Maryann LivolsiGCP Compliance Leader Bill & Melinda Gates Medical Research Institute
Liz Wool, CCRA, CMT PresidentWool Consulting Group, Inc.
Join us at the Summit for a “live” Risk-Based Auditing Community Discussion Group where participants will
discuss how organizations decide which vendors and/or investigative sites to audit?