PhRMA Changes for Data Committee Guide
Pharmaceutical Research and Manufacturers of America (PhRMA) says it recognizes that data monitoring committees (DMCs) have a unique role in clinical trial oversight and can provide specialized expertise to evaluate emerging safety and efficacy data for ongoing clinical trials. Responding to an FDA draft guidance on the use of data monitoring committees in clinical trials, PhRMA makes these general recommendations:
- revise the guidance to acknowledge that DMC charters may reference the protocol and statistical analysis plan as including the schedule and basis of planned interim analyses, rather than including this information directly in the DMC charter;
- update the guidance to clarify that sponsors need not adjust the significance level of the final analysis to account for multiplicity specifically because the DMC is provided with access to accumulating, unblinded summary efficacy data in the context of their routine assessment of the emerging benefit/risk profile of the study drug;
- revise the guidance to address unique and practical considerations for the use of DMCs in early-stage trials;
- remove discussions of “adaptation committees” from the draft;
- clarify what entities FDA considers to be “all parties involved” in determining whether actions dictated by the adaptation plan are considered reasonable by all parties involved; and
- consider including examples where it would be appropriate for a sponsor to make changes to trial design and would be doing so based on knowledge of the treatment arm assignment.
PhRMA also provides specific comments on the draft.