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Maintaining Trial Integrity During COVID-19: Some Statistical Rules of Thumb
The COVID-19 pandemic is having a substantial impact on many ongoing clinical studies in all phases of product development. Numerous difficult decisions are being made and steps are actively being taken to ensure the safe execution, or future resumption, of ongoing studies. While patient safety is paramount and should drive all study conduct related decisions, many of these decisions can impact the interpretability of estimates of efficacy at study conclusion. Changes that may seem innocuous on the surface can have a substantial impact on trial integrity, including the validity and reliability of results. Careful consideration, in consultation with a statistician, should be given to the impact that protocol changes, visit schedule amendments, collection methods, and incomplete or missing information will have on the final analysis and interpretation of results.
The FDA Guidance on Conduct of Clinical Trials of Medical Products during the COVID-19 Pandemic makes several thoughtful recommendations regarding methods to maintain the integrity of ongoing clinical studies through the COVID-19 pandemic. While the considerations raised are important to ongoing studies in all phases of clinical research, many of the issues raised take on added importance in the randomized phase 3 confirmatory trial setting. Changes to study design, assessment methods, and visit schedules, in addition to the possibility of higher rates of missing or incomplete information, may make it difficult to obtain an unbiased estimate of differences between treatment and comparator groups in these pivotal efficacy studies.
It is heartening to recognize that some of the study conduct and data-related issues we are presently confronting, including a few of the concepts discussed in the Guidance document, are not new to clinical research and are issues that investigators, protocol sponsors, and statisticians confront frequently, albeit under less difficult circumstances.
While a statistician should be consulted, we are providing some statistical rules of thumb (some are covered directly in the Guidance document) surrounding considerations related to data collection and missing/incomplete information in ongoing studies during the COVID-19 pandemic.
1. Keeping in mind that patient safety is paramount, efforts should be made to collect as much efficacy data as possible within the parameters of the current protocol. Though there will be exceptions, collecting data outside of a visit window or after treatment discontinuation is preferable to collecting no efficacy information whatsoever.
2. Changes to the protocol design may be needed to limit the amount of missing or incomplete efficacy information. However, some changes in study conduct may warrant changes to the planned primary analysis or additional sensitivity analyses.
3. It is important that the reasons for missing data, incomplete data, and patient discontinuations are captured directly, and in an easily identifiable manner, in the case report form. More specifically, this information should be collected in a manner that is readily accessible for analysis and at an appropriate resolution for the degree of missingness (e.g., instrument, visit, patient).
4. Previously unplanned analysis to assess the power of the study before continuing with enrollment may be appropriate. Mature studies which are close to planned enrollment may be sufficiently well-powered to stop early.
5. In many cases, it is likely that incomplete or missing information as a result of COVID-19 conveniently fall into the category of ignorable missing data. The plan for handling missing data due to COVID-19 should be described in the SAP. Sensitivity analyses that explore the missing data space should be planned and documented in the SAP prior to database lock.
6. Documentation in the protocol and SAP are of critical importance. For blinded studies, all decisions and changes to planned data collection, assessment, and analysis should be finalized in advance of database unblinding.
As described in the Guidance, amendments to key elements of efficacy data collection, assessment, and/or analysis should be discussed with the appropriate reviewing division. In consultation with a statistician, study sponsors should prepare now for regulatory interactions to discuss and gain agreement on any proposed changes.


