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Technology-enabled Global
Harmonization of Safety
Reporting using Local Laws
Think Globally. Report Locally.
2
Speaker
Steven Beales
Senior Vice President, IT
Market Owner, Safety Solutions
Today’s Speaker
3
The views and opinions expressed in
this presentation and any related
discussion(s) are solely those of the
individual presenter(s) and do not
express the views of and opinions of
Roche or WCG.
4
Lack of Global Harmonization
in Reporting Rules is Drug
Safety’s No. 1 Challenge *
What are we going to learn today?
+ 97% solved based on individual Site and IEC rule exceptions
Roche has solved it +
* Clinical Trials 2017, Vol 14
14% SUSARs met criteria
FDA Study Audit
Increases cost
5
Increases site burden
Why is it important to learn this now?
$2m for Safety Reporting
1 Roche Study
80% Sites receive > 20
Safety Reports per Month
Increases compliance risk
6
Have worked with Roche for 9
years building solutions to
this Global problem
In March 2017, we launched
Clinical Trial Safety Portal 2.0
(CTSP)
Why Listen to Me?
7
* Roche Internal Estimate
$80 million*
* Verified on-time delivery to
trained user
99%*
* WCG Calculation
10 hours
per week*
Year 1 Cost
Savings
Sites in
Compliance
Reduction in
Site Burden
Our results after 1 year of CTSP 2.0
8
The Problem
9
* CTTI IND Safety Advancement Project Investigator Survey 2015
20% of Sites refused to
process SUSARs
Fear of Regulatory
Repercussion
Indeterminate Causality
Lack of Global
Harmonization
IND Safety Reporting is a “failed system” *
47% reduction in US SUSARs
3 out of 5 countries have
unique rules
10
The Solution
11
Business users
must be able to
set up the rules.
Configuration of business rules must be ‘simple’
process that doesn’t need IT or coding skills.
Roche created their own process and system
Realizing Local Country Laws will never harmonize
Making the Complex feel Simple
12
Bacon Bits
e.g. Creamy Salad
Dressing
Picking Wrong Options
Opting-out
Leads to Bad Behavior
Allowing sites, CROs and
ECs to set Preferences
The Wrong Way – Take Whatever You Want
13
3% Exception Rate
Central Safety Profile with
Local Options for Countries to
Choose
Find the patterns in each
country’s regulations
The Right Way – Picking off The Set Menu
14
• All internationally recognized safety documents for IMP
compounds for Investigators and IRB/IECs on Interventional
Studies
Availability
• Alerting Options are set globally
Standardization &
Transparency
• Each country defines country alerting rules from the global
alerting options
• All safety documents available in system
Customization &
Flexibility
• Alerted that new safety documents are available based on the
country alerting rules.
• Can receive “all alerts” if required.
Investigator & Ethics
Committee
Clinical Trial Safety Portal
15
Quality Oversight
Accountabilities Fragmented Process Compliance
Resources
Sites/IRB/IECs Study Teams Monitors
Over-Distribution
Fragmented Process Multiple Interpretations of local law Study Level Distribution
Lack of Global Harmonization
Unclear rules Accountabilities Consistency and Application
Roche before CTSP
16
• Single end to end process
• All studies, countries and partners
Global Process
• 1 Safety document per recipient – for all studies
Compound Level Distribution
• Global Standards
• Safety Document Characteristics
• Country Rules
Aligned Global vs Local Law
• Relevant safety details up front
• Training
• All information is available
Direct Distributions to the Principal Investigator
Roche after CTSP
17
“Just ask the affiliates.
They know what they need”
Raw Intelligence is not
operationalizable
Needed rigorous guidelines to collect Country Rules to
avoid “we’ve always done it this way” syndrome
Mistakes We Made
Retrain CROs, Sites, ECs and Internal Staff on new
processes or you won’t realize the benefits
18
If we can, so can you
Follow Roche’s Process
It feels Overwhelming but is Solvable
Own it – Drug Safety/Clinical Operations
Acknowledge you have a problem
What can you do to take action now?
19
Speaker
Steven Beales
sbeales@epharmaolutions.com
610-834-6209
https://www.linkedin.com/in/stevenbeales/
@stevenbeales
Q & A Session

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Think globally. act locally

  • 1. Technology-enabled Global Harmonization of Safety Reporting using Local Laws Think Globally. Report Locally.
  • 2. 2 Speaker Steven Beales Senior Vice President, IT Market Owner, Safety Solutions Today’s Speaker
  • 3. 3 The views and opinions expressed in this presentation and any related discussion(s) are solely those of the individual presenter(s) and do not express the views of and opinions of Roche or WCG.
  • 4. 4 Lack of Global Harmonization in Reporting Rules is Drug Safety’s No. 1 Challenge * What are we going to learn today? + 97% solved based on individual Site and IEC rule exceptions Roche has solved it + * Clinical Trials 2017, Vol 14
  • 5. 14% SUSARs met criteria FDA Study Audit Increases cost 5 Increases site burden Why is it important to learn this now? $2m for Safety Reporting 1 Roche Study 80% Sites receive > 20 Safety Reports per Month Increases compliance risk
  • 6. 6 Have worked with Roche for 9 years building solutions to this Global problem In March 2017, we launched Clinical Trial Safety Portal 2.0 (CTSP) Why Listen to Me?
  • 7. 7 * Roche Internal Estimate $80 million* * Verified on-time delivery to trained user 99%* * WCG Calculation 10 hours per week* Year 1 Cost Savings Sites in Compliance Reduction in Site Burden Our results after 1 year of CTSP 2.0
  • 9. 9 * CTTI IND Safety Advancement Project Investigator Survey 2015 20% of Sites refused to process SUSARs Fear of Regulatory Repercussion Indeterminate Causality Lack of Global Harmonization IND Safety Reporting is a “failed system” * 47% reduction in US SUSARs 3 out of 5 countries have unique rules
  • 11. 11 Business users must be able to set up the rules. Configuration of business rules must be ‘simple’ process that doesn’t need IT or coding skills. Roche created their own process and system Realizing Local Country Laws will never harmonize Making the Complex feel Simple
  • 12. 12 Bacon Bits e.g. Creamy Salad Dressing Picking Wrong Options Opting-out Leads to Bad Behavior Allowing sites, CROs and ECs to set Preferences The Wrong Way – Take Whatever You Want
  • 13. 13 3% Exception Rate Central Safety Profile with Local Options for Countries to Choose Find the patterns in each country’s regulations The Right Way – Picking off The Set Menu
  • 14. 14 • All internationally recognized safety documents for IMP compounds for Investigators and IRB/IECs on Interventional Studies Availability • Alerting Options are set globally Standardization & Transparency • Each country defines country alerting rules from the global alerting options • All safety documents available in system Customization & Flexibility • Alerted that new safety documents are available based on the country alerting rules. • Can receive “all alerts” if required. Investigator & Ethics Committee Clinical Trial Safety Portal
  • 15. 15 Quality Oversight Accountabilities Fragmented Process Compliance Resources Sites/IRB/IECs Study Teams Monitors Over-Distribution Fragmented Process Multiple Interpretations of local law Study Level Distribution Lack of Global Harmonization Unclear rules Accountabilities Consistency and Application Roche before CTSP
  • 16. 16 • Single end to end process • All studies, countries and partners Global Process • 1 Safety document per recipient – for all studies Compound Level Distribution • Global Standards • Safety Document Characteristics • Country Rules Aligned Global vs Local Law • Relevant safety details up front • Training • All information is available Direct Distributions to the Principal Investigator Roche after CTSP
  • 17. 17 “Just ask the affiliates. They know what they need” Raw Intelligence is not operationalizable Needed rigorous guidelines to collect Country Rules to avoid “we’ve always done it this way” syndrome Mistakes We Made Retrain CROs, Sites, ECs and Internal Staff on new processes or you won’t realize the benefits
  • 18. 18 If we can, so can you Follow Roche’s Process It feels Overwhelming but is Solvable Own it – Drug Safety/Clinical Operations Acknowledge you have a problem What can you do to take action now?