Clinical Research Nurse: Supporting the Research & Protecting the Rights & Welfare of Study Volunteer

Hi, I am Mansi Shah, a clinical research nurse with over 9 years of experience. I started my practice in 2013 at Sterling Hospital after completing my GNM nursing course.

I have been working with Veeda since 2015.

As a clinical research associate, my day mainly constitutes of assisting in research activities and ensuring volunteer safety, protection, and that volunteers are well supported throughout the research study.

Even though every research is unique and every day is varied, I’m a seasoned Senior Research Associate, and my duty is to be right alongside the research participants in the journey, from the day of admission to their dosing and till the time they get discharged.

However, the most important task of a clinical research nurse involves determining the consent of suitable volunteers who consent to proceed with the study.

I have to ensure that the volunteer understands what the research seeks to accomplish and the protocols associated with it.

After educating the volunteers, I have to check her/his eligibility through OVIS and double-check it through routine screenings like blood and urine tests.

A usual day starts with a doctor assigning me my duty as per the study slots.

I go to my designated location, mind the volunteers, and check their vitals.

I hope and work to minimize the risk of adverse events during the research, but the risk is always there.

Identifying adverse events at the earliest possible time requires disciplined training and an in-depth understanding, thereby minimizing risk to research participants.

With the nature of conducting novel research, the risk of adverse events is always there, and the way we counteract it is by having ICU wards with doctors and nurses on standby so that we can treat any complication with haste.

Volunteer Safety is of the utmost importance to me and to Veeda, and we take all the necessary measures, in terms of personnel skills and our infrastructure, to ensure the same.

Besides taking care of research participants, documenting and recording information during clinical trials is the most important responsibility that a research nurse has.

And we at Veeda ensure the Quality and reproducibility of data by taking a meticulous approach and following the highest level of integrity.

I am extremely passionate about my job as I feel I am a part of something that is larger than us & larger than my role.

I wanted to be a part of it, as I get to be a part of the research that aims to test an experimental practice on willing volunteers and see it become a part of standard practice, therefore, saving many lives in the future.

A Day in the Life of a CRA

Hi, I am Gangichatti Laxman Kumar & I work as a Clinical Research Associate with Veeda, and this is how a day in my life looks like

Although I’m based out of Hyderabad, I might be visiting a site that’s in a completely different part of the country by the time you read it.

This blog is supposed to walk you through a typical day in the life of a CRA.

A Clinical Research Associate plays a crucial role within the pharmaceutical business.

A CRA is responsible for pre-study qualification visits, reviewing the study progress, checking the quality & accuracy of data collection, ensuring compliance of patients with trial visits, and ensuring good clinical practices are maintained throughout the trial.

After successfully completing Pharma-D, I started working as a Safety Associate to the regulatory bodies; after that, I switched to clinical research operations and started working as a CRA in Oncology, Neurology, Endocrinology, Cardiology, and General Medicine.

I have also worked in the department of BA/BE trials, where I experienced a multi-functional team, and finally moved to Veeda Clinical Research, where I got the opportunity to work in BA/BE studies as well as Late Phase Trials in the field of Oncology.

Being a CRA, I have to spend a significant amount of time traveling to and from all the research sites that I have been assigned, which are spread throughout the country, and I visit 4 to 5 sites in a day.

The very fact that I have to be constantly on the move, which happens to be a part of my job, adds a travel aspect to the mix that always remains fresh.

I believe that Social interaction plays an important role in learning, and through this role, I have the opportunity to interact with a wide range of people, from site coordinators to doctors to project managers, which has proven to be quite effective in my cognitive development.

My standard operating day comprises of monitoring and supervising data files as a part of the source data verification process to ensure that the site is entering data accurately and in a timely manner.

The safety of a patient is of the utmost importance at Veeda, and I, along with my staff, regularly assess patient notes to ensure the safe undertaking of procedures as per the protocol.

Every role comes with its own set of challenges, and the role of a CRA is no different. Veeda offers workplace flexibility, which helps me deal with challenges calmly & efficiently.

Being a CRA, I practice a fast-paced lifestyle, but for me, the sense of accomplishment I get from tackling all those challenges is what makes me choose this line of profession every time.

Parameters to Consider During Preparation of Master Protocols for Oncology Drugs and Biologics

In our last blog on Master protocols, we discussed the definition of master protocol, the types, and the advantages of using Master Protocol in clinical trials.

In today’s article, we would like to present to you the parameters that are kept in consideration while designing a master protocol for oncology drugs and biologics.

During the preparation of master protocols, different parameters are kept in consideration, such as:

  • Specific Design Considerations
  • Biomarker Development Considerations
  • Statistical Considerations
  • Safety Considerations
  • Regulatory Considerations

Specific Design Considerations in Master Protocols

1. Use of a Single Common Control Arm

The FDA recommends using a single control arm with the current System Organ Class (SOC) when developing a master protocol that assesses multiple drugs in a single disease.

The SOC for the target population can be revised during the trial if a new drug is approved or if scientific evidence emerges that renders it unethical to randomize patients based on the previous SOC.

In such a situation, the FDA recommends that the sponsor suspend patient enrollment until the protocol, the SAP, and the protocol-informed consent document are modified to include the new SOC as the control.

2. Novel Combination of Two or More Investigational Drugs

When writing a master protocol involving two or more investigational drugs as a combination product, the sponsor should summarize the following.

  • Safety of the combinational product
  • Pharmacology of the combinational product
  • Preliminary efficacy data for each investigational drug
  • Rationale for the use of the drugs as a combination product
  • Evidence of any synergistic effect (if any) of the two or more investigational drugs when given in combination.

The FDA strongly recommends that sponsors ensure the identification of the Recommended Phase II Dose (RP2D) for each drug with antitumor activity in all cases.

3. Studies With Drugs Targeting Multiple Biomarkers

The FDA highly encourages early discussion of biomarker research strategies when a sponsor plans to use one or more biomarkers to guide patient selection for trials.

A defined plan for the allocation of eligible patients should be present.

Patient selection studies must be analytically checked with well-defined parameters for master protocols involving drugs that target multiple biomarkers.

4. Adding and Stopping Treatment Arms

Before beginning the clincial trial, the sponsor should make sure that the master protocol and its corresponding SAP identify conditions that would contribute to adaptations, such as introducing a new experimental arm or arms to the study, re-estimating the sample size based on the interim analysis results, or discontinuing the experimental arm on the rules of futility.

5. Independent Data Monitoring Committee (IDMC)

The master protocol should provide details of the IDMC involved in monitoring efficacy results and details of the Independent Safety Assessment Committee (ISAC) involved in monitoring safety results.

However, the IDMC can perform both the functions of safety and efficacy.

For marketing an oncology drug, if the basis of the marketing application involves one or more sub-studies, the FDA recommends the inclusion of an independent radiologic review committee to perform blinded tumor-based assessments.

Biomarker Development Considerations

Master protocols assessing biomarker-defined populations should explain the rationale behind the use of that particular biomarker.

The sponsor should employ in vitro diagnostic (IVD) tests that are analytically validated, establish procedures for sample acquisition, handling, and the testing and analysis plans as early as possible.

The sponsor may need to submit the IVD’s analytical validation data to the FDA (CDRH or CBER) to determine whether the clinical results will be interpretable.

Statistical Considerations

If a sponsor introduces randomization into the design of an umbrella trial, the FDA recommends using a standard control arm whenever possible.

Bayesian statistical methods or other methods for dropping an arm, modifying sample size, or implementing other adaptive strategies can be used in the preparation of master protocols.

The SAP should include details on the implementation of Bayesian or other methods as described in the FDA guidance for industry, Adaptive Design Clinical Trials for Drugs and Biologics, and the guidance on Enrichment Strategies for Clinical Trials to Support Approval of Human Drugs and Biological Products.

Statistical considerations for master protocols can be strategized in four different ways:

  1. Nonrandomized, Activity-Estimating Design
  2. Randomized Designs
  3. Master Protocols Employing Adaptive/Bayesian Design
  4. Master Protocols With Biomarker-Defined Subgroups

Safety Considerations

The sponsor should implement a structured team of ISAC or an IDMC to assess the safety as well as the efficacy of all master protocols.

The constitution of this committee and the definition of its responsibilities should be well-defined in the IND.

A sponsor should not begin a clinical trial until the master protocol has been reviewed and approved by an IRB or IEC.

The FDA encourages the use of a central IRB to promote the IRB analysis of master protocols.

The sponsor is required to conduct a safety review of master protocols more frequently than annually and provide the investigator with the details.

If the master protocol contains proposals to include pediatric patients in the study, the FDA advises that the IRB include a pediatric oncology expert in its team who has expertise with the regulatory criteria for the enrollment of pediatric patients in clinical investigations, including parental approval and consent.

The informed consent document should be submitted to the Institutional Review Board (IRB) for review.

Additional Regulatory Considerations

Each master protocol should be submitted as a new IND to the FDA.

This is done to avoid miscommunication, owing to the sophistication of master protocols that may hamper patient safety.

If the sponsor is conducting a clinical trial on more than one indication for oncology drugs or biologics, the IND should then be forwarded to the Office of Hematology and Oncology Products at the Center for Drug Evaluation and Research (CDER) or the Center for Biologics Evaluation and Research (CBER) for approval.

REFERENCE

Master Protocols: Efficient Clinical Trial Design Strategies to Expedite Development of Oncology Drugs and Biologics, Guidance for Industry, Draft Guidance. U.S. Department of Health and Human Services, Food and Drug Administration, September 2018.

Will Brexit Have Any Impact on CROs?

The United Kingdom comprises England, Scotland, Wales, and Northern Ireland. It is an island nation in northwestern Europe.

The exit of the United Kingdom from the European Union to become a “third country” on January 31, 2020, is termed as Brexit.

The withdrawal agreement, which provided a transition period of one year, came to an end on December 31, 2020.

Thus, the Medicines and Healthcare Products Regulatory Agency (MHRA) has been the UK’s independent authority for medicines and medical devices since 1 January 2021.

Brexit will have both direct and indirect effects on the future of UK and EU clinical trials.

The impact of Brexit on pharmaceutical companies will be seen at the levels of regulatory alignment with respect to the forthcoming implementation of the EU Clinical Trial Regulation (EU CTR).

As the best universities for research in the study of clinical and pre-clinical medicine are present in the UK with strong regulatory and IP safety structures, the United Kingdom has become a major global centre for the pharmaceutical industry.

In addition, most generic pharmaceutical companies are registered with a UK address.

The departure from the EU would thus lead to hectic structural shifts, with a huge amount of time and investment on both sides.

Impact of Brexit on Outsourcing of Clinical Trials

Till now, many pharmaceutical companies based out of Europe were outsourcing their projects to contract research organizations (CROs) and contract manufacturing organizations (CMOs) based in the UK.

Post-Brexit, these scenarios may change.

As of now, the European Commission has given its decision that the UK authorities will have partial access to Article 57 and will also have partial access to the EudraVigilance database.

Because of Brexit, CROs and CMOs located in the United Kingdom are no longer members of the EU, and this will have a dramatic impact on the European portion of the clinical trials for the delivery of investigational medicinal products (IMPs).

The effect of clinical trials on the supply chain post-Brexit will totally disrupt the new drug development process due to major negative financial and economic effects.

Brexit can influence the clinical trial and drug discovery scenario that may involve access to drugs and Investigational Medicinal Products (IMPs), results, financing, and the workforce of clinical trials.

For BE studies carried out in the EU, the reference product can be made to a RefMP (UK Reference product) that has been granted in the Union in accordance with Articles 8(3), 10a, 10b, or 10c of Directive 2001/83/EC.

It is important to understand for the sponsor and the CRO that bioequivalence studies conducted with a medicinal product sourced in the UK can be used by EMA if the new MA using those BE studies has been granted before January 31, 2020.

Conclusion

United Kingdom is the 2nd destination of Indian Pharmaceutical exports after the USA. Some CROs have an internal Brexit Task Force comprised of talented individuals who very well know their roles and responsibilities.

CROs are preparing themselves to engage and capitalize on the new regulatory process in the UK and EU so as to avoid costly delays and disruptions of clinical trials.

However, many questions still remain unanswered.

One of the biggest issues refers to complaints regarding the shipping of materials from the UK to the EU for clinical trials.

Will the volunteers involved be at any risk? Or will international boundaries lead to delays in clinical trials and difficulty in site management?

Or will there be any imposition of tariffs that could lead to disinterest among pharmaceutical sponsors in the UK in carrying out clinical research?

Thus, it will be interesting to see what is in store for the CROs post-BREXIT.

However, because the UK and the EU account for less than 15-18 percent of total Indian pharmaceutical revenues, BREXIT is expected to have little impact on Indian pharmaceutical firms.

References

  1. The Landscape for CROs post-Brexit: An Update. Accessed at https://dwlanguages.com/2018/02/22/cros-post-brexit/
  2. Brexit Solutions, Clinigen Clinical Supplies, and Management. Accessed at https://www.clinigencsm.com/brexit-solutions
  3. Questions and answers to Stakeholders on the implementation of the Protocol on Ireland/Northern Ireland, 11 December 2020. European Medicine Agency (EMA/520875/2020)
  4. Future of clinical trials after Brexit. Cancer Research UK, School of International Futures (SOIF).

The Role of ADME in Phase 1 Clinical Trials

The drug development process for pharmaceuticals and biologics is strictly regulated across the globe by different regulatory authorities.

The process of drug development comprises the following stages:

  • Stage 1: Target and lead identification, in vitro testing of tissues, plasma, etc., for bench testing of the product.
  • Stage 2: Non-clinical testing in live animals (in vivo testing).
  • Stage 3: Filing of IND (Investigational New Drug) to get approval to test on humans. If approved, the clinical trial begins with Phase I clinical trials, which are also known as first-in-human studies.
  • Stage 4: Filing of NDA (New Drug Application) after successful Phase II trial completion. If approved, the clinical trial will begin for Phase III.
  • Stage 5: Submission of the document to request approval to market the product after a successful Phase III clinical trial.

Phase I Clinical Trials

Phase I studies are designed to investigate the safety and tolerability, i.e., identifying the Maximum Tolerable Dose (MTD), as well as the pharmacokinetics and pharmacodynamics of an investigational drug in humans.

The Right Drug to the Right Patient with the Right Dose at the Right Time is the ultimate goal or objective of Phase 1 Clinical Trials.

To achieve the objective of Phase I studies, scientists carry out studies in the following sections:-

Clinical Pharmacology of the Drug

  • It involves studies such as First-in-Human, SAD and MAD PK studies, Healthy vs. Patient Population, ADME (Mass Balance), Specific population, Drug Interaction, Population PK, Biomarkers, Pharmacogenomics, and other specialized safety studies.

Exposure-response (PK/PD) of the drug

  • It involves dose selection and optimization, efficacy vs. safety, and clinical trial simulation.

Biopharmaceutics of the Drug

  • It involves BA/BE and Food Effect studies

In vitro studies carried out with the drug

  • It involves protein binding, blood-to-plasma partitioning, in vitro drug metabolism, transport, and drug interactions.

Bio-analytical methods

For Biologics, scientists carry out immunogenicity and comparability studies.

This article focuses on the ADME studies involved in Phase 1 Clinical Trials.

What is Pharmacokinetics?

Pharmacokinetics is the study of the action of the human body on medicines.

Absorption, Distribution, Metabolism, and Excretion are the major steps involved when a drug enters the human body.

The physicochemical properties of the drug, the administration route, and intrinsic and extrinsic factors of the subject, such as diseases, organ dysfunction, concomitant medications, and food, are factors that affect the pharmacokinetic (PK) profile of an investigational drug.

Efficacy, Toxicity, Cmax, and Tmax are some of the important terms that we generally come across in PK studies.

ADME study is also known as a mass balance study.

ADME studies are important because they help to determine other clinical investigations that might need to be conducted in support of regulatory approval for a new drug.

The ADME is determined by attaching a radioactive isotope (radiolabel), such as carbon-14 (14C) or tritium (3H), to an investigational new drug and following the radiolabel in human subjects.

Human ADME studies are carried out by the sponsor to obtain valuable information about the investigational new drug, which includes:

  • Determining the routes of elimination and clearance mechanisms of the drug.
  • Identifying metabolites and determining the relative exposure of parent drug and metabolites.
  • Confirming that the human metabolite profile is covered by the metabolite profile in animals from toxicology studies.

What Is the Type of Study Design Carried Out in ADME Studies?

ADME studies are typically single-dose studies with healthy males (4-6 in number) at the intended route of administration.

What are the Primary and Secondary Outcome Measures Considered in an ADME Study?

The primary outcome measures of ADME studies in Phase 1 trials include:

  • 1) PK Parameters

Maximum observed concentration (Cmax), time to reach maximum observed concentration (Tmax), area under the concentration-time curve from hour 0 to the last measurable concentration (AUC0-t), area under the concentration-time curve extrapolated to infinity (AUC0-inf), apparent terminal elimination rate constant apparent terminal elimination half-life (t1/2), apparent clearance, and apparent volume of distribution.

  • 2) Urine and Feces PK Parameters

Amount excreted in urine over the sampling interval, renal clearance (CLR), and the percent excreted in the urine, amount excreted in feces over the sampling interval, and the percent excreted in feces

  • 3) Metabolites

Metabolites of [14C]-DRUG MOLECULE and their PK parameters will be identified and calculated as deemed appropriate, based on plasma and urine concentration levels.

The secondary outcome measures involved in Phase 1 Clinical Trials include:

  • Signs, symptoms, incidence, and severity of adverse events (AE).
  • Abnormalities in clinical laboratory assessments, vital signs, electrocardiograms (ECGs), and physical examinations.

How Are ADME Studies Conducted in Phase 1 Trials?

Mass Balance or ADME studies are carried out with healthy male volunteers by administering them a single dose of the investigational drug labeled with Carbon-14.

The cumulative radiolabeled dosage used in these experiments is approximately 50-100 μCi.

It is based on the predictions of real tissue exposures from tissue distribution studies performed during preclinical trials involving animals.

The volunteers are then kept in the clinical pharmacology unit (CPU) after administration until the radioactivity linked to the radiolabeled drug is quantitatively retrieved in the excreta (thresholds prescribed in the study protocol, normally in the range of 95% total and < 1 Bq/mL in the blood).

Blood samples collected during the study are analyzed for the PK properties of the parent medication.

The samples collected from this analysis are used in the circulation and excreted metabolite profiling.

Conclusion

The human mass balance study is an essential study of the drug development process.

ADME is also being carried out in the preclinical stage, but the safety and efficacy of the investigational drug can only be validated after determining the absorption, distribution, metabolism, and excretion (ADME) properties of the investigational drug on healthy human volunteers.

It can be rightly said that the human ADME (hADME) study provides a correlation between clinical observations and preclinical safety studies.

The key objective of the hADME study is to quantify, characterize, and identify drug metabolites present in the systemic circulation.

References

  1. Clinical Pharmacology 1: Phase 1 Studies and Early Drug Development, US FDA.
  2. What is a Human Mass Balance Study? Accessed at https://www.nuventra.com/resources/blog/what-is-human-mass-balance-study/
  3. Why, When, and How to Conduct 14C Human Studies. Accessed at https://www.sgs.pt/~/media/Global/Documents/Technical%20Documents/SGS-Clinical-14C-ADME-Clinical-Trials-EN-09.pdf

Current Outlook of Biosimillar Development

Veeda, through its V-Konnect series, interacted with Dr. Susobhan Das and discussed “Current outlook of Biosimilar Development.”

About the V- Konnect

V-Konnect interview series is a program to get in touch with specialized industry experts to know their views on current relevant subject matters.

About Dr Susobhan Das – Founder & CEO at Amthera Life Sciences

Dr. Das is the Founder and CEO of Amthera Life Sciences Pvt. Ltd., a preclinical-stage biosimilar drug development company based in Bangalore.

Dr. Das has extensive techno-commercial experience in early-stage Biologics Development.

He has 20 years of experience in advanced biotechnology research and biopharmaceutical development.

He has served as a member of the USP Biologics and Biotechnology Expert Panel and also worked as a Director at the United States Pharmacopeia, India site.

Dr. Das has also worked at a senior management level at Intas Pharmaceuticals, developing biosimilars for global markets.

Dr. Das has worked as a member of the Expert Committee on Biologicals and rDNA Products: Indian Pharmacopeia Commission (IPC); Govt. of India.

He has authored research papers that are published in peer-reviewed National and International journals

Transcript.

1. What are the key international developments with respect to EU and USFDA biosimilar requirements?

A: One key development towards biosimilar acceptance has been the issuance of guidance on “interchangeability” by the US-FDA in May this year.

This will pave the way for the substitution of one product for the other without a prescriber’s involvement, as is the case for generic small-molecule pharmaceuticals.

This, I believe, is a significant action and will promote competition in the biologic market in the US.

Another development is the issuance of a revised guidance by the FDA titled “Development of Therapeutic Protein Biosimilars: Comparative Analytical Assessment and Other Quality Considerations,” also in May this year.

This is the revised version of an earlier guidance titled “Quality Considerations in Demonstrating Biosimilarity of a Therapeutic Protein Product to a Reference Product,” published on April 30, 2015.

FDA says this revision is to reflect on agency’s recommendations on the design and evaluation of comparative analytical studies intended to support a demonstration that a proposed therapeutic protein product is biosimilar to a reference product and in anticipation that this will provide additional clarity and flexibility for product developers on analytical approaches to evaluating product structure and function.

For Europe, although the approval rate of Biosimilars is much higher than in the US, uptake of biosimilars is somewhat country-specific, with the large EU5 countries still not having interchangeability options.

However, payers have been significantly employing various tools, which may lead to higher biosimilar uptake.

For example, the introduction of prescribing targets, i.e., prescribing biosimilars to a predetermined percentage of patients.

The NHS of the UK introduced a biosimilar adoption framework with the idea that switching patients to a biosimilar may be inserted into clinical practice with incentive offerings for staff to offset switching costs.

This year in May, the NHS has published a document titled “What is a biosimilar medicine” for clinical and nonclinical stakeholders about the role of biosimilars in the healthcare system.

The document explains, among many other aspects, the overall savings from Biosimilars as well as suggests that a prescriber can switch from a reference to a biosimilar product.

However, switching at the pharmacy level is still not permitted without the consent of the prescriber as of now.

2. What are the main attributes for higher market approvals of Biosimilars in Europe compared to the US?

A: The first biosimilar, Zarxio, was approved in the United States only in 2015, whereas Omnitrope, another biosimilar, was approved by the European Medicines Agency (EMA) way back in 2006.

Since then, the EMA has approved more than 40 biosimilars as of 2019.

Essentially, this shows that EMA is the pioneering agency to advance biosimilars approval and uptake for the world.

To understand this, one may refer to the concept paper on the development of a guideline on the comparability of biotechnology-derived products published in 1998, which led to the introduction of a directive in EU legislation with the idea of “similar biological medicinal product” in 2001.

Therefore, a definition and a legal framework for market authorization for Biosimilars were first introduced in the world by the EU and are monitored and updated on an ongoing basis, which is key for a larger market approval rate of biosimilars in the EU.

By now, the EU has already gained experience of over a decade of Biosimilar use and has established the fact that biosimilars have similar efficacy and safety concerns to those of the reference products and can save a significant portion of healthcare costs.

Only three official biosimilars are in the market in the US, although around 15 are approved, and their uptake has been slower than anticipated.

For example, less than 15% for filgrastim biosimilar and 3% for the infliximab biosimilar hold as market share.

This is partly due to the lack of pricing incentives from biosimilars, as well as more attractive contract offers from the innovator product.

A host of other reasons for this slow approvals and uptake could be considerations on overall quality, safety, and clinical efficacy of the biosimilar, plus manufacturer reliability (supply without disruptions), reimbursement rates set by insurance companies or commercial payers, and support services for health care professionals and patients.

In other words, assurance on the efficacy and safety from the providers, as well as less out-of-pocket expenses, is key to most US patients.

Currently, this has yet to happen in the US, although progress has been made to achieve these goals.

On the contrary, a range of different policies to generate pricing pressure, drive adoption, and ultimately yield cost-savings for their healthcare systems have been implemented in the EU countries, which has somewhat led to a higher uptake rate for the biosimilars.

3. What is the scenario of prescribers’ acceptance of biosimilars over the innovator biological products?

A: At the beginning of the biosimilar era, the differences between lots in quality characteristics were cited to be reason enough for great concerns on efficacy and safety of the product.

From this, we have come to a stage where regulatory agencies have formalized acceptable changes of quality characteristics in the “innovator products” with no impact on efficacy and safety.

We also have more than a decade of real-world experiences of biosimilar use with comparable efficacy and safety concerns in the EU.

Moreover, we now have the outcome of the NOR-SWITCH trial, which demonstrated that “switching from infliximab originator to CT-P13 [a biosimilar] was not inferior to continued treatment with infliximab originator”.

All of these experiences, I believe, have led to higher prescribers’ acceptance of biosimilars over the innovator product, given there are incentives attached all through the stakeholders chain (for example, for the provider, prescriber, payer, and insurer).

The EU is clearly way ahead in implementing policies with the above considerations and will reap huge benefits in healthcare cost savings.

Although slow, the US has finally initiated action that may eventually allow biosimilars to be interchangeable with the innovator product.

First, to this idea was the finalization of the guidelines on interchangeability this year in May.

4. What is your opinion on Indian biosimilar industry, whether it attained its potential or this is just the beginning of the journey?

A: Indian biosimilar industry has now been very firmly established with defined regulatory path and a number of large and medium manufacturers with more than 70 biosimilars approved.

India is also the first country to approve a biosimilar monoclonal antibody to Rituximab in 2007, and interestingly, without having a published guideline, which first appeared in the year 2012 and in a revised form in 2016.

This approval has tremendously helped the patients to have access to the product with almost half the cost of the innovator product.

Interestingly, another mAb, Trastuzumab, indicated for HER2-positive breast cancer, is now available at almost 65% less than the innovator price, due to the launch of an Indian biosimilar.

Moreover, 3 companies from India have biosimilar products registered in the US, the EU, and Japan.

This shows the maturation of the Indian biosimilar industry as a global player.

Although these facts are very positive, India still has huge gaps in filling up the affordability factor with its very low per capita income.

On the contrary, India has a very high number of incidences and disease burden in most therapeutic segments, such as Cancer, Diabetes, Infections, Arthritis, Blood factor disorders, etc.

Therefore, affordable and quality biosimilars are a big opportunity for India.

However, what is critically needed is a policy framework somewhat similar to that being followed in the EU, which incentivizes all the stakeholders involved with biosimilar use, including the insurance sector.

Unfortunately, medicine costs in India are largely an out-of-pocket expense, and this needs to change very rapidly.

Given that these policies are implemented, the Indian biosimilar industry has tremendous potential to impact healthcare in a significant way.

5. Where does China stand with biosimilar approvals and the regulatory requirements?

A: This year, in February, Chinese regulators approved their first biosimilar.

A biosimilar Rituximab indicated for non-Hodgkin Lymphoma.

Although biotherapeutics development in China continue to grow exponentially over the past decade, no biosimilar drug however was approved until 2019.

This is primarily because of the lack of a national regulatory guidance, which was first published in February 2015.

This guidance document followed the same principles and requirements consistent with those formalized by the FDA and EMA.

Some other changes also happened simultaneously to foster pharmaceutical approvals and market authorizations, such as the China Food and Drug Administration (CFDA), which is now the National Medical Product Administration (NMPA), which falls under the State Administration for Market Regulation (SAMR).

The Centre for Drug Evaluation (CDE), which reviews applications under NMPA, remains unchanged in function.

China currently has more than 200 biosimilars under clinical development.

Interestingly, two key recent developments in policy setting by NMPA can be seen either as a barrier to biosimilar growth or as bringing serious competition: One is the listing of foreign-made drugs for urgent unmet medical needs, which can be approved for registration without any clinical trials being conducted in China.

Forty-eight such drugs have been listed for public review, out of which 11 are biologic drugs.

The second one is reduced or no import cost of new cancer drugs or drugs for hard-to-treat cancer.

Another very interesting development is the Market Authorization Holder (MAH) program implemented by the Chinese regulatory agency as a pilot program, which allows holders of an NMPA biologics approval to have the option to manufacture the drugs on their own or use any contract manufacturer.

This policy has given a significant boost to the CMO industry inside China and will surely foster growth in the Chinese Biosimilar industry along with new drug development.

6. How switching and interchangeability affect biosimilars access and its market size?

A: EMA and the EU commission define 3 terms related to biosimilar switching: interchangeability, switching, and automatic substitution.

Interchangeability is a general term that includes both switching, when the prescriber decides to use one over another, and substitution, when this exchange happens at the pharmacy level without the consultation of the prescriber.

In the US, though, FDA-designated interchangeability may refer to automatic substitution at the pharmacy.

Europe has been at the forefront in terms of interchangeability and currently allows physician-guided transitions of biosimilars, restricting pharmacy-level substitution, and this is without any separate or additional
regulatory guideline or drug development criteria.

As a result, we see a very high uptake of Biosimilars in some select EU countries.

Therefore, we may envisage that interchangeability or substitution will surely bring competition as well as uptake and cost savings.

Indeed, a follow-on biologic to Lantus, like Basaglar, has gained a market share of around 30 percent, and the Neupogen market share is down by 20 percent from the competition of Zarxio, a biosimilar.

Disclaimer:

The opinions expressed in this publication are those of the Interviewee and are not intended to malign any ethic group, club, organization, company, individual, or anything.

Examples of analysis performed within this publication are only examples. They should not be utilized in real-world analytic products as they are based only on the personal views of the Interviewee.

They do not purport to reflect the opinions or views of the VEEDA CRO or its management.

Veeda CRO does not guarantee the accuracy or reliability of the information provided herein.

How to Capture ICSRs for COVID Treatment

An Individual Case Study Report (ICSR) is a source of data in pharmacovigilance that contains information on the adverse events caused by medications.

It is reported by an individual or an individual’s physician.

Reports from member countries of the WHO Network are the primary target of ICSRs.

The Uppsala Monitoring Centre (UMC), on behalf of the WHO, manages and produces a worldwide individual case safety report database called the VigiBase.

Medical coding aims to translate information on adverse effects into terminology that can be defined and analyzed quickly, as the terminology used for a similar event may vary from region to region.

As a part of medical coding, a generic terminology from a medical coding dictionary, such as MedDRA (the most widely used medical coding dictionary), is used for an adverse event.

UMC has updated MedDRA 23.0 to capture the ICSRs for COVID-19 treatment, and the current MedDRA version in use is 23.1.

It should be noted that there are insufficient safety details about the multiple therapeutic options for COVID-19 infection.

It is important to exchange information on suspected adverse effects from all of the drugs that are used to treat COVID-19, as well as how the virus and the medications used to treat it affect patients with co-morbidities that are already on various medicines for managing conditions like hypertension, diabetes, etc.

Given the global scale of the pandemic, all attempts should be made to reduce delays in reporting events related to COVID-19 so that countries can benefit as early as possible from each other’s experience.

Data points other than demographic details (sex and age of a patient) that are particularly useful for analyzing and identifying COVID-19-related cases include:

  • Medical history of the patient, inclusive of the concurrent medications
  • The therapeutic reaction of the drug
  • Laboratory test results
  • If there is death, then the reason behind death
  • Patient narrative, diagnostic reports, and comments from the healthcare provider

EMA has recently released complete guidance on the processing and submission of ICSRs in the context of the global COVID-19 pandemic.

The detailed guidance document refers to the updated MedDRA version 23.0 for getting the terms related to COVID-19, and also notifies of the release of a COVID-19 SMQ with MedDRA version 23.1.

It calls upon organisations to comply with their legal obligations to disclose reported adverse drug reactions in compliance with the provisions of Articles 107 and 107a of Directive 2001/83/EC.

It also requests the organizations to comply with the guidelines laid down in GVP Module VI, ICH E2B Guidelines, and the current version of MedDRA term selection.

The important points from the document regarding capturing ICSRs for COVID treatment include:

  • Complete information that includes the medical and administrative data for a valid ICSR should be submitted in a standardized manner in the relevant ICH-E2B data elements and in the narrative section for serious adverse event cases.
  • No report should be documented for the misuse of non-medicinal products that may contain substances that are also found in medicinal products.
  • The guidance stated to discuss the reports of drugs having off-label use with no associated suspected adverse reactions in the Periodic Safety Update Report or in the product Risk Management Plan. These reports should not be submitted to EudraVigilance as ICSRs.
  • If a pharmaceutical product is used to prevent or cure COVID-19 infection after getting approval and no possible adverse effect is recorded for lack of therapeutic effectiveness, then it should be sent to EudraVigilance as an ICSR within 15 days. The reason is that COVID-19 is a potentially life-threatening illness.
  • If any medication has a valid Adverse Drug Reaction (ADR) and demonstrates a lack of clinical efficacy for the treatment of COVID-19, an ICSR should be requested regardless of whether or not the application of the drug as off-label.
  • ICSRs should be considered as spontaneous reports. If ICSRs are of named patient programs having an active collection of adverse events, then they will be considered as solicited reports.
  • Given the substantial rise in the number of publications related to COVID-19, the marketing authorization holders should abstain from creating duplicate ICSRs in the EudraVigilance. Those AE reports should be submitted by the Medical Literature Monitoring Service.
  • For every single identifiable patient, one case should be generated when respecting the exclusion requirements given in GVP module VI.C.2.2.3.2.
  • Specific COVID-19 terms have been included in MedDRA version 23.1. Stakeholders should ensure that when coding ICSRs in compliance with the MedDRA, they choose the correct specific COVID-19-related word.
  • If the COVID-19 condition is found to aggravate, then usually the ‘Reaction (MedDRA)’ field should be populated with either the MedDRA LLT “COVID-19 aggravated” (LLT Code 10084657) or MedDRA LLT “COVID-19 pneumonia aggravated” (LLT Code 10084658) term.
  • If a suspected adverse reaction occurs in the off-label use environment, the guidance provided in GVP Module VI, chapter VI.C.6.2.3.3 should be followed for coding AE in the ICSR.
  • The medicinal drugs that are used in the treatment of confirmed or suspected COVID-19 infection should be populated with the most precise COVID-19-related MedDRA LLT (Low-level term).
  • If any approved medication is used as a prophylaxis against COVID-19 infection, the indication “COVID-19 prophylaxis” (LLT code 10084458) should be filled as MedDRA LLT.
  • If the medicine is used as immunization against COVID-19 infection, it should be filled in MedDRA under the PT as “COVID-19 immunization”.
  • If the medication is used as a cure for COVID-19 infection, the indication under the PT ‘COVID-19 treatment’ should be filled with the most appropriate MedDRA LLT unless a more accurate code word is available.
  • If a patient has reported a COVID-19 infection, the patient’s medical history data should be filled with the most reliable MedDRA LLT COVID-19 terms.
  • The most accurate MedDRA LLT codes, such as “Exposure to SARS-CoV-2” or “Occupational exposure to SARS-CoV-2,” should be entered for ICSRs where the alleged medicinal agent was not used to treat COVID-19 infection and where it is specifically stated that the patient has documented exposure to COVID-19 without contracting an infection.
  • The code for the name of the test should be populated under the most accurate MedDRA LLT, as applicable. Code like PT’s ‘Coronavirus test,’ ‘SARS-CoV-2 test,’ or ‘SARS-CoV-2 antibody test’ can be used.

The updated MedDRA Version 23.1 contains 50 new COVID-19-related LLTs/PTs. Similarly, a revised guideline on post-marketing adverse case reporting for prescription drugs and nutritional supplements during COVID-19 has been released by the FDA.

Performance should be maintained as far as possible, but to ensure business stability, the FDA agrees that consistency in adverse event reporting responsibilities would be required.

The post-marketing notice on the Mandatory Reporting Requirement of COVID-19 from Health Canada also aligns with the views of the FDA.

The MHRA has also included a new section on PV in its guidance on regulatory flexibility during COVID-19.

REFERENCES

Three Ways to Reduce Cost and Complexity in Clinical Trials

Medicine research and clinical trials are crucial to the success and growth of the healthcare industry.

However, it is also the segment that faces varied economic challenges and fluctuations.

Furthermore, the looming expiry of their products’ patents keeps the industry constantly on its toes and working on its operational efficiency to survive and grow.

Clinical Trials – The Cost Factor!

Clinical trials are one of the largest cost drivers in the healthcare industry.

These trials are sponsored by healthcare and/ or biotech companies.

According to an article published in the clinical trials arena in 2018, the average cost of transitioning from Phase 1 to Phase 3 is over $79.1 million, with a range of $52.9 million for a single Phase 3.

This cost may increase at any time due to various factors, significantly impacting the industry’s performance.

Hence, it is imperative to work on cost-control strategies for clinical trials.

Factors to Be Considered

  • Stretching Timeline

Delays affect clinical trial budgets to a great extent and can be financially damaging too.

One of the most common reasons for delays in clinical trials is patient recruitment and retention, which is quite a complicated and tough aspect of the trial.

A research claims, “69% of patients final pre-screening, 58% decline consent, and 8% drop out after the enrolment.”

Researchers are adopting a patient-centric approach, wherein patients’ point of view is considered.

The approach would aid in patient recruitment and retention and control the delays in the trial. It also emphasizes the importance of site selection.

  • Logistics Decisions

Most of the clinical trials in phases 3 or 4 are conducted on a large scale at a global level. And hence, logistics cost comes into the picture.

More often than not, product shipment decisions are based more on previous experiences and less on the feasibility of the site.

It is best to take a pragmatic approach to it and analyze if it would be feasible to ship the product to the clinical site directly or make sense to have a local depot there.

Prior studies may be factored in, although they may have less or zero relevance to a new trial.

Instead, a study must be conducted on the demand and supply for the site, and the logistics and operational costs must be evaluated before deciding.

  • Interactive Response Technology (IRT)

Automating the processes through IRT can bring down the costs significantly.

It reduces manual oversights and the risks of stock outages and aids in supply management.

IRT systems can be programmed to monitor depot inventories and batch expiries and keep supply managers updated about it through alerts.

IRTs can be custom-built to provide real-time feed on varied aspects of operations in clinical trials, including stocks, supply chain, shipment, etc.

This small investment can optimize operations greatly and aid in cost control.

It also simplifies the entire complexity of the tedious processes.

Cost control and increasing operational efficiencies are the keys to the profitability of any clinical trial.

And there are several opportunities to pursue this goal.

A tactical approach, if successfully executed, would result in saving millions of dollars and enhancing the value of the drug in the investigation.

How to Select a CRO for BA/ BE Studies?

A Contract Research Organization (CRO) plays a vital role as a service provider to the pharmaceutical industry.

The market size of the global contract research organization (CRO) services was estimated at USD 38,396.4 million in 2018. By the end of 2026, it is expected to hit USD 90,926.3 million.

It should be noted that in terms of the number of generic drugs, 20% of global exports are from India.

This makes India the biggest global supplier of generic medicines.

It is very much obvious that to get marketing approval for generic drugs on foreign soil, manufacturers from India have to clear all the regulatory parameters.

Thus, BA/BE studies are of great importance, and conducting them requires due planning and experience.

Generic companies have the R&D for product development, manufacturing, and quality testing.

Many of the bigger pharmaceutical firms have their own clinical and bioanalytical units.

They are capable of carrying out Phase 1 and BA/BE studies.

However, because of the desire to produce more compounds in shorter time periods, there comes a point when the internal resources become saturated.

Often, several smaller firms, virtual companies, and generic companies do not have the privilege of performing BA/BE trials with their own dedicated clinical unit or full in-house capability.

They may not have the clinical and bio-analytical capability.

Thus, the role of CRO or outsourcing of BA/BE studies comes into the picture.

They reduce the cost of BA/BE study, help pharmaceutical companies to file ANDA applications, and bring new medicines to market quickly.

The typical services outsourced for BA/ BE studies from a pharmaceutical company to a CRO may include Bioanalytical Analysis, Bioanalytical Site Selection and Qualification, Clinical Study Design, Clinical Protocol Development, Clinical Site Selection and Qualification, Clinical Conduct, Clinical Monitoring, Data Management, Pharmacokinetic Analyses, Statistical Analyses, Pharmacokinetic Report Writing, Integrated ICH Report Writing, Project Management, and FDA/Regulatory Consultation.

How to Select a CRO?

The first step before outsourcing a study to a CRO is to develop a list of potential CROs that are involved in conducting BA/BE studies.

CROs that have good experience in conducting BA/BE studies and can meet the sponsor’s timeline should be given first preference.

The list should include both CROs that provide all services and those that provide only clinical or analytical services.

CROs that have a proven record of carrying out BA/BE studies with appropriate clinical conduct, laboratory analysis, data management, biostatistics, pharmacokinetics, and medical writing should be given priority.

They should comply with Good Clinical Practices (GCP), Good Laboratory Practices (GLP), and other applicable regulatory practices and guidelines.

How to Assess the Qualification of a CRO?

The sponsor company should assess a CRO on different parameters before finalizing to outsource the project.

The parameters include Clinical Capabilities, Bioanalytical Capabilities, Pharmacokinetic capabilities, and quality deliverables on time.

The sponsor should obtain copies of past FDA inspection reports (483s and Establishment Inspection Reports [EIRs]) through the Freedom of Information (FOI).

The client should also request any FDA warning letters that have been issued against the CRO, if any.

The ability to recruit volunteers for both small and large sample studies is a major assessment criterion for the qualification of any CRO.

The CRO should be able to recruit the entire study population at a single center, preferably as a single group.

The client should ensure that the Bioanalytical team is well-experienced in analyzing the analyte or metabolite of the drug, as appropriate.

The client should also verify that the facility adheres to cGLPs and has a clean inspection history from regulatory bodies.

The Bioanalytical team of the CRO should be able to provide a written validation report.

The CRO should have validated pharmacokinetic and statistical programs in place and should be compliant with 21 CFR Part 11 (especially concerning change control).

The CRO should also provide performance metrics used for monitoring the timelines and financial metrics.

The client should request ‘‘references’’ that include those companies that outsourced studies and, in return, had successful ANDA or NDA approvals.

After evaluating the credentials and performance metrics of each CRO, the sponsor should physically visit the site and audit the clinical, bioanalytical, and pharmacokinetic capabilities of the CRO.

The audit should include the evaluation of the:

  • Procedure for the CRO to handle an unexpected and serious adverse event (AE) investigation.
  • Training records for the clinical team
  • CRO’s capability to synchronize plasma and urine deliveries to different bioanalytical facilities
  • CRO’s ability to coordinate functional handoffs
  • CRO’s clinical project management capabilities
  • Validation of the data collection system
  • SOPs, CRF, and database correction, change control
  • Deliverables like CRFs (CRO or sponsor format), transport procedures to the bioanalytical unit, and content of the written clinical report

The client should also asses the capability of the laboratory project management with regard to their coordination with the clinic, pharmacokineticist, and the sponsor during the study.

Finally, to support the BA/BE study, the CRO should provide written documentation of the final analytical report that should contain supplementary project-specific validation data.

Thus, in a nutshell, it can be said that factors like the number of years in the business, qualified team of scientific, medical, and statistical experts, the ability of CRO to recruit volunteers, a sufficient number of beds for in-housing, calibrated laboratory equipment with suitable SOPs, location of the CRO, duration of getting IEC/IRB approval, employee training on SOPs, adherence to GCP and GLP, correct volunteer database, appropriate ambulatory service, clean kitchen facilities with maintained hygiene, recreation rooms for volunteers, working QAU system, facility management, and accurately designed scientific organization charts assess the qualification of a CRO to conduct BA/BE studies.

Conclusion

A generic manufacturer outsources a BA/BE study so that their product can be proved bioequivalent to that of a Reference Listed Drug (RLD).

The key elements for the success of the BA/BE study between the client and the CRO are transparent Communication at all levels, Sensitivity to the project’s requirements, timelines, and flexibility to recognize and adjust to unexpected events throughout the project timeline.

Work culture compatibility between a sponsor and CRO is also a substantial merit, as it leads to a more aligned relationship in the future.

REFERENCE

  1. Outsourcing Bioavailability and Bioequivalence Studies to Contract Research Organizations, Patrick K. Noonan. Generic Drug Product Development Solid Oral Dosage Forms Chapter 13, Pg. No. 299-321.

Healthy Volunteers Contribute To Moving Science Forward

When it comes to developing nations, there is a greater preference among the populace for generic pharmaceutical drugs as opposed to branded ones.

In India, generic drugs comprise 71% of the pharmaceutical market.

The reason for this is not hard to guess – a large proportion of the population having a low income level means the market is bound to be highly price sensitive.

Generic Drugs & Healthy Human Volunteers

Generic drugs may not have to go through the full gamut of clinical trials from Phase 1 to Phase 3, but they do have to pass the Bio-Availability and Bio-Equivalence (BA/BE) tests in order to earn the marketing license.

Healthy volunteers have an important role to play in enabling the BA/BE testing of such drugs.

Through BA/BE testing, a pharmaceutical company can determine if the molecule that they have developed has a similar response to the branded drug that it seeks to compete with.

Another reason BA/BE testing is important is to identify if there is a possibility of any side effects occurring as a result of being exposed to the generic drug molecule.

How Healthy Volunteers Contribute to BA/Be Testing of Generic Drugs

Because the drug is only being tested for bioavailability and bioequivalence with a previously known drug, the testing can be performed on healthy volunteers and need not necessarily involve patient volunteers.

Pharmaceutical companies would find it easier to recruit healthy volunteers as the number of patient volunteers would be comparatively smaller, and not all of them would be willing to subject themselves to a clinical test.

Thus, healthy volunteers play an important role in enabling the market introduction of generic drugs, which have a key role to play in making healthcare affordable in India and other developing countries.

Reviewing the Role of Healthy Volunteers in Testing of Investigational Drugs

In addition to this, First-In-Human (FIH) Phase 1 clinical studies for investigational drugs are also preferably performed on healthy volunteers.

The key goal that is sought to be achieved through healthy volunteer studies is to determine the pharmacokinetics and pharmacodynamics of a novel drug that is sought to be introduced, as well as to determine the right level of dosage and its safety and tolerability.

Typically, this involves a total of 20-80 healthy volunteers divided into groups of 3-6 each, who are administered escalating doses of the investigational drug.

Through these studies, a pharmaceutical company attempts to identify the bodily mechanisms involved in absorption, metabolism, and excretion of the drug, its pharmacokinetic profile, and the safety and tolerability of the drug at different dosage levels.

By conducting trials on healthy volunteers, a pharmaceutical company gets to understand the body’s response to a drug as well as its safety profile in the absence of any pre-existing pathological conditions influencing the response.

Thus, healthy volunteers play a key role in the journey of pharmaceutical drugs, both branded and generic, from the laboratory to the market.

Not only do pharmaceutical companies benefit by being able to reduce the time taken between the drug research and commercialization, but the fact that the drug can be introduced early also means it can be sold at lower prices, thus benefiting the patients who would depend on the drug for treatment.