Building Better Clinical Trials through Enhanced Stewardship and Transparency
Co-Authored by Carrie D. Wolinetz and Mike Lauer
Dr. Mike Lauer is the NIH Deputy Director for Extramural Research and blogs about NIH research funding policies and data at his blog, Open Mike.
NIH is the largest public funder of clinical trials in the United States. As stewards of this research enterprise, we have been actively listening and discussing how to overcome hurdles and shortcomings that we, and others in the research community, have identified. If you’ve been following the conversation, you’ll know that NIH already has implemented some key reforms to enhance clinical trial stewardship. Today, in a Viewpoint Essay published in the Journal of the American Medical Association (JAMA), we provide an overview of how these reforms, and new initiatives, fit in to the broader picture of building a better clinical trial enterprise through better stewardship, accountability, and transparency.
Figure 1 illustrates the clinical trial “lifespan”, and key opportunities for improving the quality and efficiency of clinical trials – opportunities that translate into more innovative and robust clinical trial design, and accelerated discoveries that will advance human health. NIH is leading a multi-faceted effort that addresses shortcomings and challenges throughout this lifespan, including the application and award process; the scientific review of trial applications; post-award management and oversight; sharing of trial data; and dissemination of research results information to the public.
Some key highlights from our essay:
- Good clinical practice training. New NIH policies issued today establish Good Clinical Practice (GCP) training expectations – effective January 1, 2017 -- for investigators involved in NIH-supported trials, as well as for NIH staff who design, oversee, manage, or conduct clinical trials. There are many providers of GCP training, and institutions have the flexibility to choose the training program that is the best fit with their existing programs (some universities already include GCP in their institutional training requirements, for example).
- Changes to clinical trial applications. A new NIH policy issued today requires that the research community submit grant applications requesting support for clinical trials in response to clinical trial-specific funding opportunity announcements (FOAs). This policy is targeted to apply to applications submitted for due dates on or after September 27, 2017. This change will allow NIH to readily identify proposed clinical trials, to ensure that key pieces of trial-specific information are submitted with each application, and to ensure that trial-specific review criteria are uniformly applied. To give NIH institutes and centers flexibility across their different scientific areas, each NIH IC will be developing clinical trial FOAs that address their research funding priorities and strategic goals. There will be commonalities across FOAs, in that all clinical trial applications will need to contain key clinical trial-specific elements, such as protocol information. This change will mean that you will no longer be able to submit an application requesting support for a clinical trial on one of our parent announcements. You will need to identify an FOA that clearly invites clinical trial applications. We will publish reminders in the NIH Guide and NIH Extramural Nexus. Read today’s NIH Guide Notice for more information.
- Enhancing clinical trial registration and summary results information reporting. A new HHS regulation released today specifies requirements for clinical trial registration and summary results information reporting. NIH also issued a policy today that complements the federal regulation and sets the same reporting expectations for all NIH-funded clinical trials whether or not they are subject to the regulation (to include, for example, phase 1 studies of FDA regulated products as well as studies of interventions not regulated by FDA, e.g., behavioral interventions.) Read more in a New England Journal of Medicine paper authored by NIH staff, and we’ve also written more about this change in a separate blog post published today.
- Use of a single institutional review board for multi-site studies. This NIH policy, issued in June 2016, will streamline and expedite institutional review board (IRB) review of clinical trials conducted across multiple sites. The policy establishes the expectation that a single IRB will be used for multi-site research as of May 25, 2017. (Read an earlier Under the Poliscope post describing this change.)
- Clinical trial protocol template. To expedite both NIH and federal regulatory oversight processes, NIH, in collaboration with FDA, is developing a clinical trial protocol template for phase 2 and 3 Investigational New Drug (IND)/Investigational Device Exemption (IDE) clinical trials. NIH plans to encourage its use as a way to organize and standardize key details that should be included in clinical trial protocols. NIH is reviewing public comments and working toward an updated version of the template this fall and plans to develop an electronic clinical trial protocol template thereafter.
We encourage you to read our JAMA article, and the articles linked from this blog, for more information. We will continue to harmonize the establishment, conduct, and follow-through of clinical trials research in the upcoming months and years. As described in the JAMA article, clinical trials have evolved and improved over time, resulting in impressive advances, but there are still challenges that we must address. The suite of complementary activities described here intends to help fulfill our mission of improving health through scientific discovery, while preserving the public trust in research through efficient and transparent clinical trials.
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