Regulatory Open Forum

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  • 1.  How Pharmaceutical Clinical Trials work

    Posted 14-Feb-2020 16:55

    Coming from a predominantly education-centered research institution, we don't see many drug studies. Occasionally we do, but we outsource them to commercial IRBs.

    That said, I do have a general question about Phase 1 drug studies (or any phase):
    Is it typical for a pharmaceutical company to pay university hospital PIs and/or large research institution PIs to recruit, consent, and administer their investigational drugs and collect biospecimens, but NOT actually have these PIs play any additional role in the study?

    For example, after all the interventions are completed, all the data and documents would be immediately sent back to the pharmaceutical company for analysis and the research institution is then complete with the project and closes out their study with their IRB with no further involvement.

    This is new to me but seems to be a bit of a conflict because:

    1) There are no findings to present to the IRB in the closure/final report.
    2) Why wouldn't the pharmaceutical company just use their own internal docs to run the trial?

    3) If our PI is the one holding the IND, does this cause some concern?

    Are there any other considerations I should be aware of?



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    Tamiko
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  • 2.  RE: How Pharmaceutical Clinical Trials work

    Posted 15-Feb-2020 09:30
    There is generally a difference in the manner of which a Phase 1 trial is run as compared to Phase 2 and 3 trials.  Often times a Phase 1 trial is conducted at one site (Phase 1 Unit) and most of the activities from subject recruitment, drug administration, subject observations, laboratory testing, data analysis and issuing the study report are performed at that site on behalf of the study sponsor (the Pharmaceutical Company).  For Phase 2 and 3 trials, the majority and conducted as multi-center trials, using a CRO to assist the coordination, logistics and monitoring the study across all participating study sites.  In the above scenarios, the pharmaceutical company submits the IND and the PI at each of her /his study site ensures that IRB approves and oversees subject safety and is updated on status of the trial at the site and provided safety information as required by the responsible IRB.  Now regarding your question:  It's typical for clinical trials intended to support the marketing and approval of a drug or biologics product to be financially supported by a pharmaceutical company.  This financial support includes payments to the PI and research center to conduct the study. Each party (PI, IRB, CRO and study sponsor) have unique roles and responsibilities which together help prevent any conflicts of interest.  If a PI holds the IND, he/she is responsible for all aspects of the study.  Pharma companies may financially support these PI-Sponsored studies but they generally not used to provide primary evidence for supporting the marketing approval of a drug or biologic product.

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    Michael Trapani
    Senior Consultant
    Monroe Township NJ
    United States
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  • 3.  RE: How Pharmaceutical Clinical Trials work

    Posted 16-Feb-2020 01:25
    Edited by Julie Omohundro 16-Feb-2020 09:14
    [Deleted pending further information from Tamiko.]

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    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
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  • 4.  RE: How Pharmaceutical Clinical Trials work

    Posted 16-Feb-2020 07:32

    What you describe (with one major difference) is pretty normal. The company hires the PI/site to conduct the study and pays accordingly. This is how most phase I units functions. Of course, there is nothing to prevent the PI to negotiate more involvement if they so wish. In academic environment publication rights might be important and something to be negotiated - although in the setting of a phase I it would not be surprising if the company will want to delay any publications. 


    The IRB is not concerned about the results of the study. It is concerned about the risk/benefit ratio to participants. As long as they interactions with the participants is complete and all safety issues are addressed prior to closure of the study with the IRB it should not be a problem.


    However, if the PI holds the IND it is a completely different ball game, as the PI is completely responsible to the entire life cycle of the protocol and is the one who need to report the results back to the FDA, as well as all other Sponsor obligations.



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    Shy Shorer MD, MBA, EJD
    Director, Office of Sponsor and Regulatory Oversight
    Center for Cancer Research
    National Cancer Institute
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  • 5.  RE: How Pharmaceutical Clinical Trials work

    Posted 16-Feb-2020 08:31
    Edited by Julie Omohundro 17-Feb-2020 15:24
    I deleted my first response, and also much of this response, when I remembered that Tamiko had posted here once previously, also about "conflicts of interest," but never responded to any of the questions that were posed by members of the forum in their effort to give her informed responses.  So I think I will say no more until Tamiko has had a chance to clarify:

    What is the PI's involvement with the HUMAN SUBJECTS in terms of assessing and managing any safety issues?

    When you say that, once "after all the interventions are completed, all the data and documents would be immediately sent back to the pharmaceutical company," do you mean that the PI gets and reviews all the data first, or that the data are sent directly to the sponsor?  (Sent "back" implies the sponsor had it first and then sent it to the PI, who would now send it back.)

    Will the PI sign a 1572?


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    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 6.  RE: How Pharmaceutical Clinical Trials work

    Posted 18-Nov-2022 20:45
    Oh dear! I didn't see any of these responses until now! I think my notifications weren't working. I had been wondering this whole time "why didn't anyone respond..." haha. I am so sorry! It may be too late, but here are the answers:

    The PI's involvement with the Human Subjects is ZERO. Just a data provider. Pull the records from the chart and send them off to the sponsor. That's about it. Well, to be fair, also do the admin work of getting the contract signed.

    My apologies for poor wording. When I said, once "after all the interventions are completed, all the data and documents would be immediately sent back to the pharmaceutical company," I mean that the PI also reviews all the data and may conduct her own (or duplicate) the analysis, but essentially the data are sent directly to the sponsor.

    No, the PI will NOT sign a 1572. She believes none are necessary or relevant for her.

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    Tamiko Eto
    Research Compliance and IRB Manager
    Milpitas CA
    United States
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  • 7.  RE: How Pharmaceutical Clinical Trials work

    Posted 17-Feb-2020 08:23
    1) IRBs generally do not receive the results of a clinical trial except for the required safety information. Even in the case of Phase 1 studies with one site, some of the data, such as pharmacokinetics of the drug, is not even available to the investigator since the samples are assayed at a different location. I don't see any conflict in this process as each party in the research is fulfilling their unique role.

    2) The pharmaceutical company usually designs the study and analyzes the results using either their internal resources or consultants. In the past pharmaceutical companies did have their own Phase 1 units where employees of the company ran the study, but it is not particularly cost-efficient. Most Phase 1 studies are free-standing for-profit units.

    3) A PI holding an IND is not a cause for concern - any time that an investigator wants to conduct a study of a new drug that is not paid for by a commercial sponsor will need to have an IND to conduct the study.

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    Glen Park PharmD
    Executive Director, Regulatory Affairs and Quality Assurance
    Jersey City NJ
    United States
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