
FIGURE 3-1 While the number of senior NIAID/NIH tenured investigators is relatively stable, the number of NIAID/NIH tenure-track principal investigators is decreasing.
SOURCE: Lane, 2009. Courtesy of John Gallin, 2009 (unpublished).
cause publishing results from this work is easier, and the difficulties of getting a clinical trial protocol approved can be avoided. Accordingly, NIAID has created a protocol development program to decrease the burden of regulatory and administrative requirements and optimize the use of existing clinical research tools. The program’s goal is to allow investigators to focus on their work as clinical scientists rather than having to serve as operations managers of a complex regulatory process. When investigators provide a robust scientific idea with a strong hypothesis, appropriate endpoints, and a sound study design, NIAID’s Office of the Clinical Director helps them navigate such regulatory issues as ethics review, technology transfer, safety concerns, and interactions with Institutional Review Boards (IRBs) and the FDA. This support can help investigators implement a trial successfully. In addition to principal investigators, multidisciplinary support staffs are necessary to complete a clinical trial successfully. Biostatisticians, epidemiologists, laboratory technicians, and administrative support personnel are just a few of the types of staff needed.
The importance of involving knowledgeable staff throughout a study was highlighted in a discussion of cardiovascular and depression clinical trials. Califf referred to the crucial role of a well-trained, intelligent data monitoring committee tasked with evaluating interim trial results. Data fluctuations revealed by interim trial monitoring require analysis but do not always
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2
ChAllENgES IN ClINICAl RESEARCh
250
223
210 202
200
150
100
74
53
42
50
0
Tenured Tenure Track
FY 2003 FY 2008 FY 2009
FIGURE 3-1 While the number of senior NIAID/NIH tenured investigators is
relatively stable, the number of NIAID/NIH tenure-track principal investigators is
decreasing.
SOURCE: Lane, 2009. Courtesy of John Gallin, 2009 (unpublished).
cause publishing results from this work is easier, and the difficulties of get-
Figure 3-1
ting a clinical trial protocol approved can be avoided. Accordingly, NIAID
R01728
has created a protocol development program to decrease the burden of
regulatory and administrative requirementsector
redrawn as v and optimize the use of existing
clinical research tools. The program’s goal is to allow investigators to focus
on their work as clinical scientists rather than having to serve as operations
managers of a complex regulatory process. When investigators provide a
robust scientific idea with a strong hypothesis, appropriate endpoints, and
a sound study design, NIAID’s Office of the Clinical Director helps them
navigate such regulatory issues as ethics review, technology transfer, safety
concerns, and interactions with Institutional Review Boards (IRBs) and the
FDA. This support can help investigators implement a trial successfully.
In addition to principal investigators, multidisciplinary support staffs are
necessary to complete a clinical trial successfully. Biostatisticians, epidemi-
ologists, laboratory technicians, and administrative support personnel are
just a few of the types of staff needed.
The importance of involving knowledgeable staff throughout a study was
highlighted in a discussion of cardiovascular and depression clinical trials.
Califf referred to the crucial role of a well-trained, intelligent data monitor-
ing committee tasked with evaluating interim trial results. Data fluctuations
revealed by interim trial monitoring require analysis but do not always
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0 TRANSFORMINg ClINICAl RESEARCh IN ThE UNITEd STATES
indicate that a trial should be discontinued. For instance, when death is the
primary outcome of a trial, data fluctuations may indicate an adverse effect
on mortality of the treatment being studied or a regular clinical occurrence
unrelated to the study drug. Califf noted that if it were not for a particularly
well-informed data monitoring committee, the ISIS-2 (Second International
Study of Infarct Survival) trial would have been most recently discontinued
at 5,000 patients, with aspirin showing an adverse effect on mortality.
William Potter, most recently Vice President of Translational Neuroscience,
most ,
Merck Research Labs, Merck & Co., Inc., indicated that in the depression
studies in which he has been involved, interim data that indicate a possible
adverse effect usually result in a trial’s being discontinued.
Because clinical trials are conducted in an ad hoc fashion, and study
personnel of varying professional quality are recruited and trained anew
at each site, inconsistencies in trial execution across sites are not unusual.
Woodcock explained that the failure to execute a clinical trial successfully
is often attributable in part to the fact that ensuring proper execution of a
single trial is no one’s full-time job. The core activities of a clinical trial are
largely supplemental responsibilities assigned to a variety of staff in addi-
tion to their full-time work.
Califf noted that clinical investigators often are unsupported by their
academic institutions and are left largely to their own devices to design a
trial and gather the necessary resources. The major reason for this lack
of support, he suggested, is that clinical research is not widely respected
among academics as a truly intellectual endeavor. Califf explained that,
while investigators who are leading large, multisite trials predicted to have
a major impact on clinical practice enjoy such respect, this is not the case
for those conducting less visible work or just starting out in their research
careers. A number of workshop participants expressed their support for
rewarding academic researchers who conduct clinical trials. Early career
development at the graduate and postgraduate levels could create incentives
for more experts to enter the field of clinical research.
NEED TO NAVIGATE ADMINISTRATIVE
AND REGULATORY REQUIREMENTS
The internal requirements of an academic institution, federal agency,
or pharmaceutical company for reviewing multiple aspects of a clinical
trial can significantly delay its initiation. In the case of an academic institu-
tion conducting a clinical trial for a pharmaceutical company, the internal
review processes of both organizations are involved. In addition to such
internal requirements, myriad federal and state regulatory requirements
affect the conduct of clinical trials. Adhering to these many requirements
is a significant challenge for investigators. Moreover, the delays incurred
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ChAllENgES IN ClINICAl RESEARCh
increase the time cost of a trial and decrease its overall efficiency. U.S.
academic institutions typically take longer to navigate the approval pro-
cess (i.e., from budget/contract to IRB approval) compared to private or
academic institutions abroad. The protracted timeline to approve a clinical
trial through U.S. institutions is one reason industry sponsors look outside
the United States to initiate studies.
Institutional Review Board Approval
Gaining IRB approval is a requirement of the clinical trial process.3
Lane’s survey of intramural NIH investigators revealed that the top four
barriers to clinical research are:
• Ethical/IRB approval,
• scientific review/protocol approval,
• interaction with industry and issues with technology transfer, and
• adequacy of resources.
Lane noted that there is often a lack of clarity among investigators re-
garding the roles and responsibilities of different oversight bodies. In focus
groups with the investigators polled, it became clear that IRB missions can
be difficult to interpret. Institutions have used IRBs for risk management
above and beyond what is required for human subjects research, and in-
cluded in their purview travel policies, conflicts of interest, and other man-
agement issues. Investigators often do not know or understand what the
IRB expects of them, and the IRB decision-making process can be lacking in
timeliness and accountability. Investigators reported that if the IRB process
results in a request for changes to a trial, they often lack the resources to
fulfill the request.
Paul Hébert, Editor-in-Chief of the Canadian Medical Association Jour-
nal (CMAJ) and critical care physician at the Ottawa Hospital, commented
on the difficulties associated with IRB ethics review. A key concern is that
IRBs are accountable only to their own institution and not to the greater
public good. Hébert suggested that, to improve the regulatory system, IRBs
should be held accountable to the community for the decisions they make.
Moreover, decreasing the regulatory burden surrounding clinical trials does
not need to be a zero-sum game. For example, decreasing the number of
ethics reviews for a trial from 50 to 10 would be a substantial improvement
over the current situation.
3 An IRB is tasked with reviewing a clinical trial protocol to ensure that the study is con-
ducted ethically and study participants are not likely to be harmed. An IRB can decide whether
a clinical trial should continue as planned or changes should be made.
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2 TRANSFORMINg ClINICAl RESEARCh IN ThE UNITEd STATES
Carla Greenbaum, Director of the Benaroya Research Institute Diabetes
Program and Clinical Research Center, shared her experiences and insights
into the IRB process from the perspective of diabetes research. She noted
that regulations vary by geographic location. Depending on location, for
example, IRBs have different answers to the question of when research
in children is appropriate, and they differ as well in how clinical research
terms and phrases such as “minimal risk,” “slightly greater than mini-
mal risk,” and “benefit” are defined. Geographic variation is also seen in
IRB definitions of reportable adverse events, definitions of equipoise4 and
whether a proposed study satisfies this requirement, and rules regarding
whether permission can be granted for clinical trial samples to be retained
indefinitely by the pharmaceutical sponsor versus NIDDK. Because multiple
IRB approvals are required for most large, multisite clinical trials, these in-
consistencies in IRB determinations and standards across the country com-
plicate and delay the process of conducting a clinical trial and can inhibit
the ability of investigators to implement the same trial protocol across all
study sites—a critical factor for developing valid trial results.
Informed Consent
Informed consent refers to the process and documents associated with
educating individuals on the details of a clinical trial and potentially gain-
ing their consent to participate in the study.5 Obtaining informed consent
from each subject in a clinical trial requires a significant amount of time.
The informed consent process includes developing appropriately worded
consent documents, discussing the documents and the clinical trial process
with individual patients, obtaining the required patient signatures on the
documents, and keeping track of the paperwork generated throughout the
enrollment process.
As an example of the time and effort necessary to satisfy informed
consent requirements, Greenbaum described a hypothetical scenario from
her experience in diabetes research. A family consisting of two parents and
four children, one with diabetes, decides to be screened for participation
in a diabetes prevention study. The consent process for this family requires
a total of 8 separate consent forms, each 6 pages long and requiring 16
signatures, plus 5 Health Information Portability and Accountability Act
4 Equipoise is the point at which a rational, informed person has no preference between two
(or more) available treatments (Lilford and Jackson, 1995). In clinical research, the ethical
concept of equipoise is satisfied when genuine uncertainty exists as to the comparative thera-
peutic benefits of the therapies in each arm of a clinical trial.
5 The documents and conversations involved in the consent process explain the details of the
clinical trial, including its purpose, the treatment procedures and schedule, potential risks and
benefits, alternatives to participation, and the rights of participants (NCI, 2010).
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ChAllENgES IN ClINICAl RESEARCh
(HIPAA) forms. This paperwork is in addition to the extensive monitoring
and compliance that accompany the consent process.
Greenbaum stressed the irrationality of the current situation in which
an individual’s ability to participate in clinical research is dictated by
geographic location. As a result of the level of local control exerted over
clinical research, patients who frequent a hospital or medical center in one
area of town may have access to certain clinical trials, whereas those at a
hospital across town do not. For instance, some clinical trials organized
through TrialNet are not approved at one institution in Greenbaum’s area
because it is their policy that studies should not be conducted in children
until the therapeutic approach has first been demonstrated to work in
adults.
Protracted Time from Protocol Approval to Trial Activation
Administrative burdens are not always imposed on investigators by
external laws and regulations. As Lane noted, many bottlenecks arise in-
ternally and are imposed by institutions that are home to the research
workforce. In the government-sponsored Occluded Artery Trial (OAT), for
instance, it took 3 years from the first NIH steering committee meeting to
the start of the trial. Because clinical research relies on substantial human
effort that incurs large labor costs, the timeline for a clinical trial affects
overall cost. DiMasi and colleagues estimated that in 2000, the average
cost to develop a new drug was $802 million, and time costs associated
with the length of research and development accounted for half of this cost
(DiMasi et al., 2003).
For the pharmaceutical industry, protracted timelines increase cost
and reduce revenue as medications typically have a finite life before los-
ing patent protection and creating an opportunity for generic competitors.
Moreover, when a trial addresses a question important for medical prac-
tice, increasing the time it takes to obtain an answer can reduce the impact
of the results. Musa Mayer, breast cancer survivor, advocate, and author
(AdvancedBC.org), commented that if clinical trials are subject to significant
delays, the standard of care can move on in the absence of phase III data.
Thus, obstacles and delays in clinical trials move health care further away
from evidence-based practice. Moreover, if the time lag is significant, the re-
sults of a lengthy, expensive trial may already have been rendered irrelevant
by changes in clinical practice when they finally become available.
The one-off nature of trial organization, mentioned by a number of
workshop participants as a major barrier to the efficient conduct of tri-
als, is one factor leading to prolonged trial startup times. Years can elapse
from the time researchers begin talking about a study idea to the point at
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TRANSFORMINg ClINICAl RESEARCh IN ThE UNITEd STATES
which they assemble the appropriate investigators, develop collaborations,
establish study sites, and initiate the trial.
Renzo Canetta, Vice President of Oncology Global Clinical Research,
Bristol-Myers Squibb, provided an example of the internal administrative
burdens faced by industry. Historically, Bristol-Myers Squibb has required
8 months, or 34 internal review cycles, to produce and activate a new study
protocol. Recent efforts to improve the review cycle have been aimed at
reducing this internal process to 150 days (5 months). Some individual
institutions have exhibited greater flexibility and have been able to further
streamline the protocol approval process. The University of Arkansas has
a 70-day timeline for activating a new trial, while M.D. Anderson Cancer
Center has a project under way (Project Zero Delay) to turn protocols
around in 46 days, according to Canetta.
Case Report Forms
Collecting data for each participant in a clinical trial efficiently and
accurately and according to the study objectives is essential for regulatory
compliance, as well as the success of the research effort. The case report
form (CRF) is the tool used by investigators to collect patient information
throughout a clinical trial. Data Safety Monitoring Boards (DSMBs) are
tasked with ongoing monitoring of the data collected in CRFs. A portion
of the monitoring costs for a trial is directly linked to the complexity of the
CRF developed for that trial. Complex CRFs with many data points are
more expensive to monitor than simpler CRFs. A number of workshop par-
ticipants noted that efforts to simplify CRFs so they include only the neces-
sary, biologically relevant details of the trial could decrease trial costs.
Beyond the cost issue, the lack of standardized CRFs and trial pro-
cedures can create chaos in some study sites. Woodcock reflected on a
recent meeting with the FDA and contract research organizations (CROs)
in which the CROs openly discussed the monitoring of study sites. Among
the problems they reported, many sites were not conducting critical study
procedures correctly or entering all of the data required by the study pro-
tocol. According to Woodcock, poor understanding of the study protocol
is a common problem in clinical trials and can lead to sloppy data collec-
tion and poor data quality. Califf suggested that expending resources and
enrolling patients in a clinical trial that does not yield useful information
could be considered unethical.
Clinical investigators may be trained to use multiple CRFs depending
on the number of trials in which they participate. To reduce costs, Canetta
suggested developing a standardized, electronic CRF for use across the
research enterprise. Doing so would benefit all stakeholders—government
and industry included—because it would help clinical investigators do their
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ChAllENgES IN ClINICAl RESEARCh
job more efficiently. Cooperative groups supported by the National Cancer
Institute (NCI) are currently using standardized CRFs, and the Cancer Bio-
medical Informatics Grid (caBIG) online network is developing a library of
standardized CRFs to be used throughout oncology trials.
RECRUITMENT AND RETENTION OF PATIENTS
A core function of a successful clinical trial is finding patients who fit
the predetermined eligibility criteria and getting them to participate. Each
disease area addressed during the workshop (cardiovascular disease, de-
pression, cancer, and diabetes) has a unique patient base for clinical trials,
and the issues that affect patient enrollment in trials can vary according to
features of the disease. In addition, workshop participants identified chal-
lenges to patient recruitment that transcend disease status.
Patient Education
Mayer presented the results of a Harris Interactive Survey of 6,000
cancer patients that found that 85 percent were unaware that participation
in clinical trials was even an option. Of the patients surveyed, 75 percent
said that if participation in a clinical trial had been offered, they would have
been receptive to the idea. Of those aware of clinical trials and offered the
possibility of participation, 71 percent chose not to participate. However,
almost all who participated were satisfied with the experience. Thus, ac-
cording to these survey results, patients’ preconceived notions about trial
participation could pose a barrier to clinical trial enrollment.
Greenbaum noted that the socioeconomic status of patients plays a role
in whether they decide to enroll in clinical trials. In addition to income and
education, patients’ access to health care services and the network of social
support patients have to help them cope with their disease can affect their
connection to the medical system and their interest in clinical research.
As Mayer noted in her presentation, the online patient network she has
developed for metastatic (advanced) breast cancer is composed primarily
of younger, better educated, less diverse, and more affluent individuals as
compared with the general population. Thus, higher socioeconomic status
is associated with having the resources, knowledge, and motivation to seek
information about a disease, including access to clinical trials.
Patient Recruitment
According to Woodcock, sites for clinical trials are frequently selected
on the basis of where the investigators are located, as opposed to where
the patients are, creating difficulties in patient recruitment. When patient
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6 TRANSFORMINg ClINICAl RESEARCh IN ThE UNITEd STATES
recruitment is impeded, the trial is delayed, sometimes by years, until the
number of patients required by the study protocol can be enrolled. Once
a trial protocol has been activated, the recruitment of patients requires a
significant amount of time and money. Canetta reported that the ability to
recruit patients into a trial successfully is similar for the pharmaceutical
industry and NCI. Regardless of the trial sponsor, recruitment of patients
who meet the requirements of the protocol is difficult: in one study of 14
cancer centers approximately 50 percent of study sites failed to recruit a
single patient (Durivage et al., 2009). Thus, patient enrollment can directly
affect the number of trials that are completed.
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4
Clinical Trials in Cardiovascular Disease
T
o inform the workshop discussion of ways to improve the overall
clinical research enterprise in the Unites States, speakers offered
insight into their research efforts in the four disease-specific areas
noted in Chapter 1. Gaining an appreciation of the differences in clinical
trials by disease helped participants identify aspects of the clinical research
enterprise that are working well and those that are not. According to
clinicaltrials.gov, cardiovascular trials currently account for 10 percent
of all clinical trial participants. The acute nature of many of the health-
related events associated with cardiovascular disease and the large number
of individuals with the disease make this area of medical research unique
in important ways. Presentations summarized in this chapter described a
number of different approaches to conducting clinical research in the area
of cardiovascular disease and illuminated the overall evolution of clinical
trials in this area as compared with other disease areas. This first of four
chapters on clinical trials in disease-specific areas begins with a discussion
of clinical research models for coronary syndromes. Next, the Thrombolysis
in Myocardial Infarction (TIMI) Study Group is discussed as an academic
research organization model—a type of clinical research network. The Na-
tional Institutes of Health (NIH)—sponsored Occluded Artery Trial (OAT)
is then presented as an example of the unique strengths and weaknesses of
government-sponsored trials. Finally, the chapter summarizes a discussion
of the usefulness of large, simple clinical trials in cardiovascular disease.
CLINICAL RESEARCH MODELS FOR CORONARY SYNDROMES
Acute coronary syndromes (ACS) is a broad term referring to a group
of conditions ranging from unstable angina, to myocardial infarction (heart
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TRANSFORMINg ClINICAl RESEARCh IN ThE UNITEd STATES
attack), to sudden cardiac death. The condition depends on the degree to
which the coronary artery has been obstructed and the health effects the
obstruction has caused. A diagnosis of ACS is made by evaluating the re-
sults of an electrocardiogram (ECG) and the presence or absence of certain
enzymes in the body.
Clinical research efforts in ACS provide a useful model for examining
large, multicenter effectiveness trials in an acute, life-threatening disease.
Robert Califf, Vice Chancellor for Clinical Research and Director of the
Duke Translational Medicine Institute, reflected on the notable successes
of the ACS field in translating basic science into early clinical trials, and
then into definitive trials that evaluate outcomes related to key clinical
questions. Once effective treatments have been identified and disseminated,
the final step is measuring their uptake in hospitals and making the results
publicly available, which improves adherence to the treatments. A 2004
study examining hospital compliance with quality guidelines (those of the
American College of Cardiology/American Heart Association) and in-hospi-
tal mortality rates revealed that a 10 percent increase in guideline adherence
corresponded to an 11 percent reduction in mortality rates (Peterson et al.,
2004). Califf also cited papers based on data from a national registry of
myocardial infarction showing that U.S. hospitals show close to 100 percent
uptake of evidence-based therapies for ST elevation myocardial infarction
(STEMI) and non-ST elevation myocardial infarction (non-STEMI) at both
hospital admission and discharge. The result has been an approximately 30
percent reduction in the risk of death if a patient presents at a hospital with
chest pain. Califf stressed that, to establish evidence-based therapies that
individuals and institutions can be held accountable for using, clinical trials
should be focused on answering the critical questions in that disease area;
conversely, trials that are poorly designed and seek to answer peripheral or
irrelevant questions should be avoided.
Califf reflected on the evolution of clinical trials in ACS. Califf was
part of a small group of people who formed the TAMI Group to address
the area of STEMI trials. The group received a small amount of money
($100,000) from Genentech to conduct a randomized controlled trial
(RCT) with 340 participants. The trial protocol, or study plan, included
three cardiac catheterizations per subject, and the trial results were pub-
lished in the New England Journal of Medicine. Califf highlighted this
example of an early ACS trial because he believes the same trial could not
be conducted today given the extremely high cost of conducting trials and
the large number of patients now required for cardiovascular outcome
trials.
The International Study of Infarct Survival (ISIS) group at Oxford had
a similar early trial experience that Califf likewise claimed could not be
replicated in today’s clinical trial environment. The minimum sample size