1 00:00:13,246 --> 00:00:14,914 >> Stacey Arnold: In this third part of the series, 2 00:00:14,981 --> 00:00:17,183 I'll describe the process for submitting results 3 00:00:17,250 --> 00:00:19,352 information to ClinicalTrials.gov. 4 00:00:20,353 --> 00:00:23,089 Topics for this session include an overview of results 5 00:00:23,156 --> 00:00:24,791 reporting to ClinicalTrials.gov 6 00:00:24,858 --> 00:00:27,560 via the protocol registration and results system, 7 00:00:27,627 --> 00:00:30,864 or PRS, including the objectives of reporting 8 00:00:30,930 --> 00:00:33,032 and the components of results submissions. 9 00:00:33,566 --> 00:00:37,103 We'll also review key points to consider when reporting results. 10 00:00:38,838 --> 00:00:40,774 The ClinicalTrials.gov Results Database 11 00:00:40,840 --> 00:00:43,009 was designed to satisfy legal requirements 12 00:00:43,076 --> 00:00:45,779 for the sharing of clinical trial results information. 13 00:00:46,546 --> 00:00:48,448 The database aims to promote objective, 14 00:00:48,515 --> 00:00:49,749 standardized reporting 15 00:00:49,816 --> 00:00:52,552 and to facilitate good reporting practices, 16 00:00:52,619 --> 00:00:55,488 including publishing and regulatory guidelines. 17 00:00:55,555 --> 00:00:58,425 The database provides structured tabular data entry 18 00:00:58,491 --> 00:00:59,893 to ensure complete reporting 19 00:00:59,959 --> 00:01:01,928 and consistent display of data elements 20 00:01:02,429 --> 00:01:04,264 and to facilitate the quality assurance 21 00:01:04,330 --> 00:01:07,333 review of the information submitted to ClinicalTrials.gov. 22 00:01:08,101 --> 00:01:11,004 This consistent structure supports detailed searches 23 00:01:11,070 --> 00:01:13,039 of the ClinicalTrials.gov database. 24 00:01:14,974 --> 00:01:17,477 As with registration, results are manually entered 25 00:01:17,544 --> 00:01:20,280 or uploaded into the PRS database 26 00:01:20,346 --> 00:01:23,049 for eventual posting to ClinicalTrials.gov. 27 00:01:23,950 --> 00:01:26,119 Results can be submitted once data collection 28 00:01:26,186 --> 00:01:29,522 has been completed for at least one primary outcome measure 29 00:01:29,589 --> 00:01:31,591 and for records that have been previously 30 00:01:31,658 --> 00:01:33,860 registered on ClinicalTrials.gov. 31 00:01:34,994 --> 00:01:37,096 Results are posted to ClinicalTrials.gov 32 00:01:37,163 --> 00:01:39,399 once they have undergone a review process 33 00:01:39,466 --> 00:01:42,168 like the one performed for registration information, 34 00:01:42,235 --> 00:01:44,304 meaning they must pass an automated system 35 00:01:44,370 --> 00:01:45,905 validation process, 36 00:01:45,972 --> 00:01:48,975 and quality assurance review by ClinicalTrials.gov staff. 37 00:01:50,844 --> 00:01:53,246 Results submissions included scientific information 38 00:01:53,313 --> 00:01:56,716 provided in four modules, including participant flow, 39 00:01:56,783 --> 00:02:00,186 baseline and demographic characteristics, 40 00:02:00,253 --> 00:02:03,857 outcome measures and statistical analyses and adverse events. 41 00:02:04,524 --> 00:02:07,760 An additional module, limitations, and caveats, 42 00:02:07,827 --> 00:02:09,662 provides a free text field where data submitters 43 00:02:09,729 --> 00:02:11,631 can provide information about considerations 44 00:02:11,698 --> 00:02:13,433 for interpreting the reported data. 45 00:02:14,000 --> 00:02:16,836 There are also two modules for administrative information 46 00:02:16,903 --> 00:02:19,339 including contact information for the point of contact 47 00:02:19,405 --> 00:02:20,907 for the study results, 48 00:02:20,974 --> 00:02:22,342 and a description of any agreements 49 00:02:22,408 --> 00:02:23,877 between the principal investigator 50 00:02:23,943 --> 00:02:25,078 and the study sponsor, 51 00:02:25,144 --> 00:02:27,881 including ones that restrict the PI from discussing 52 00:02:27,947 --> 00:02:29,682 or publishing study results. 53 00:02:31,584 --> 00:02:33,586 The participant flow module includes a table 54 00:02:33,653 --> 00:02:35,955 that resembles the consort flow diagram 55 00:02:36,022 --> 00:02:37,924 that often serves as the first figure 56 00:02:37,991 --> 00:02:39,792 in a clinical trial publication. 57 00:02:40,493 --> 00:02:42,829 It tracks the progress of participants through the trial 58 00:02:42,896 --> 00:02:46,032 according to the arms or groups to which they've been assigned. 59 00:02:46,633 --> 00:02:49,335 An arm represents a unique experience, for example, 60 00:02:49,402 --> 00:02:51,838 receipt of a single intervention or the sequence 61 00:02:51,905 --> 00:02:54,641 and interventions for the duration of the trial. 62 00:02:54,707 --> 00:02:57,377 Studies specific milestones, multiple periods, 63 00:02:57,443 --> 00:03:00,146 and reasons for participant dropout can all be listed. 64 00:03:00,747 --> 00:03:03,283 An example of how a consort flow diagram 65 00:03:03,349 --> 00:03:06,986 is translated into a participant flow table is shown to the left. 66 00:03:10,490 --> 00:03:11,658 The baseline characteristics 67 00:03:11,724 --> 00:03:14,127 module provides demographic and baseline data 68 00:03:14,193 --> 00:03:16,930 for the entire population of the trial 69 00:03:16,996 --> 00:03:19,132 as well as each charm or comparison group. 70 00:03:19,933 --> 00:03:22,368 Age, sex, race, ethnicity, 71 00:03:22,435 --> 00:03:24,337 and any measures assessed at baseline 72 00:03:24,404 --> 00:03:26,472 that are used in the analysis of the primary 73 00:03:26,539 --> 00:03:29,309 outcome measures are required to be included. 74 00:03:29,976 --> 00:03:33,246 Examples of each type of measure are shown to the left. 75 00:03:37,183 --> 00:03:39,452 The outcome measures and statistical analysis 76 00:03:39,519 --> 00:03:42,789 module presents data by arm or comparison group 77 00:03:42,855 --> 00:03:45,425 and accommodates categorical, continuous, 78 00:03:45,491 --> 00:03:47,293 and time to event data. 79 00:03:47,360 --> 00:03:50,897 Examples of outcome measure and statistical analysis tables 80 00:03:50,964 --> 00:03:52,565 are shown to the left. 81 00:03:55,735 --> 00:03:58,338 Three types of outcome measures are reported in this module 82 00:03:58,404 --> 00:04:00,773 including primary outcome measures, 83 00:04:00,840 --> 00:04:04,077 which represent the analyses of greatest importance in the study 84 00:04:04,143 --> 00:04:05,645 and typically include the assessment 85 00:04:05,712 --> 00:04:07,413 used in the power calculation, 86 00:04:08,114 --> 00:04:10,450 secondary outcome measures which are of lesser importance 87 00:04:10,516 --> 00:04:12,652 than the primary outcomes but are of interest 88 00:04:12,719 --> 00:04:15,221 in evaluating the effects of the interventions, 89 00:04:15,288 --> 00:04:17,156 and other pre specified outcome measures 90 00:04:17,223 --> 00:04:21,127 which are exploratory in nature. A well planned outcome measure 91 00:04:21,194 --> 00:04:23,396 specifies four levels of analysis 92 00:04:23,997 --> 00:04:26,666 that identifies a domain for the analysis in this example, 93 00:04:26,733 --> 00:04:29,669 anxiety, defines a specific measurement tool 94 00:04:29,736 --> 00:04:30,937 to explore the domain, 95 00:04:31,004 --> 00:04:33,139 like the Hamilton anxiety rating scale, 96 00:04:33,773 --> 00:04:35,942 indicates a specific metric for determining 97 00:04:36,009 --> 00:04:39,579 an effective interventions such as change from baseline 98 00:04:40,146 --> 00:04:43,916 and identifies a method for aggregating collected data, 99 00:04:43,983 --> 00:04:45,785 like report of the proportion of participants 100 00:04:45,852 --> 00:04:48,388 with a greater than or equal to 50 percent decrease 101 00:04:48,454 --> 00:04:50,189 in the measured scale score. 102 00:04:52,725 --> 00:04:55,828 The adverse events module lists all collected events, 103 00:04:55,895 --> 00:04:58,698 whether anticipated or unanticipated, 104 00:04:58,765 --> 00:05:02,602 that result in death, are serious, or are non-serious 105 00:05:02,669 --> 00:05:04,137 and occurring above a frequency 106 00:05:04,203 --> 00:05:06,406 threshold of less than or equal to 5 percent 107 00:05:06,472 --> 00:05:08,341 in any study arm or comparison group. 108 00:05:09,208 --> 00:05:11,577 Examples of all three adverse events tables 109 00:05:11,644 --> 00:05:13,246 are shown to the left. 110 00:05:16,516 --> 00:05:19,352 An additional section, the study documents section, 111 00:05:19,419 --> 00:05:22,588 is required to be included at the time of results submission. 112 00:05:22,655 --> 00:05:24,724 For studies with the primary completion date on 113 00:05:24,791 --> 00:05:27,994 or after January 18, 2017, 114 00:05:28,795 --> 00:05:33,032 a full protocol and accompanying statistical analysis plan 115 00:05:33,099 --> 00:05:36,536 are required to be submitted and informed consent forms 116 00:05:36,602 --> 00:05:38,204 must also be posted for trials 117 00:05:38,271 --> 00:05:40,740 that are subject to the Revised Common Rule. 118 00:05:42,809 --> 00:05:45,278 The statistical analysis plan can be included 119 00:05:45,344 --> 00:05:47,714 as part of a single document with the protocol 120 00:05:48,314 --> 00:05:50,216 or as a separate document. 121 00:05:50,283 --> 00:05:52,752 These documents must represent all amendments 122 00:05:52,819 --> 00:05:55,555 approved by a human subject's review board 123 00:05:55,621 --> 00:05:58,057 that apply to all study locations, 124 00:05:58,124 --> 00:06:00,093 they must be accompanied by a cover page 125 00:06:00,159 --> 00:06:03,229 that indicates the official title for the study, 126 00:06:03,296 --> 00:06:05,732 the NCT number assigned by ClinicalTrials.gov 127 00:06:05,798 --> 00:06:07,667 at the time of trial registration, 128 00:06:07,734 --> 00:06:10,036 and the date of the document version. 129 00:06:10,103 --> 00:06:12,071 Data submitters can redact this information 130 00:06:12,138 --> 00:06:14,774 including personally identifiable information, 131 00:06:14,841 --> 00:06:16,008 and trade secrets 132 00:06:16,075 --> 00:06:18,678 or other confidential commercial information 133 00:06:18,745 --> 00:06:20,713 unless the information is otherwise required 134 00:06:20,780 --> 00:06:22,048 to be submitted. 135 00:06:22,115 --> 00:06:26,285 The uploaded documents must be in the archival PDF/A format 136 00:06:26,352 --> 00:06:28,321 and will be made public on ClinicalTrials.gov, 137 00:06:28,387 --> 00:06:30,723 so they are also required to be in English. 138 00:06:33,259 --> 00:06:35,328 Inclusion of the informed consent form 139 00:06:35,394 --> 00:06:37,296 on ClinicalTrials.gov is optional. 140 00:06:37,930 --> 00:06:40,933 However, ClinicalTrials.gov is one of two federal websites 141 00:06:41,000 --> 00:06:43,336 that satisfy the requirement of the Revised Common 142 00:06:43,402 --> 00:06:45,505 Rule that clinical trials conducted 143 00:06:45,571 --> 00:06:46,873 or supported by a Common 144 00:06:46,939 --> 00:06:49,342 Rule department or agency be posted 145 00:06:49,408 --> 00:06:51,644 on a publicly available federal website 146 00:06:51,711 --> 00:06:53,346 within a specific timeframe. 147 00:06:54,046 --> 00:06:58,417 The compliance date for this provision was January 21, 2019, 148 00:06:58,951 --> 00:07:01,154 and Regulations.gov is the second site 149 00:07:01,220 --> 00:07:02,822 that satisfies the requirements. 150 00:07:05,224 --> 00:07:06,626 There are three main points to consider 151 00:07:06,692 --> 00:07:09,028 when reporting results to ClinicalTrials.gov. 152 00:07:09,095 --> 00:07:10,329 These include the manner 153 00:07:10,396 --> 00:07:13,166 in which the data will be prepared for submission, 154 00:07:13,232 --> 00:07:16,469 the considerations needed to satisfy review criteria, 155 00:07:16,536 --> 00:07:18,237 and the relationship of reporting results 156 00:07:18,304 --> 00:07:19,872 to ClinicalTrials.gov 157 00:07:19,939 --> 00:07:23,075 to publishing results in scientific journals. 158 00:07:25,845 --> 00:07:27,313 Summarizing results for submission 159 00:07:27,380 --> 00:07:29,515 of ClinicalTrials.gov is similar in complexity 160 00:07:29,582 --> 00:07:32,251 to preparing results for journal publication. 161 00:07:32,318 --> 00:07:33,953 The process requires an understanding 162 00:07:34,020 --> 00:07:37,023 of the study design and analytic plan, 163 00:07:37,089 --> 00:07:38,925 a basic understanding of the principles 164 00:07:38,991 --> 00:07:41,394 of clinical trial conduct and analysis, 165 00:07:41,961 --> 00:07:44,096 and access to the necessary data. 166 00:07:44,163 --> 00:07:46,432 Ideally, results should be prepared for submission 167 00:07:46,499 --> 00:07:49,235 by the study's principal investigator or statistician. 168 00:07:50,069 --> 00:07:52,705 The submitted information must be accurate and precise, 169 00:07:52,772 --> 00:07:54,607 as well as understandable and informative 170 00:07:54,674 --> 00:07:57,210 for someone who is a reader of the medical literature, 171 00:07:57,276 --> 00:07:59,312 but not an expert in the field. 172 00:07:59,378 --> 00:08:01,147 It's recommended that someone who is not familiar 173 00:08:01,214 --> 00:08:03,382 with the study review the information for clarity 174 00:08:03,449 --> 00:08:04,817 and comprehension 175 00:08:04,884 --> 00:08:07,153 prior to submission to ClinicalTrials.gov. 176 00:08:09,322 --> 00:08:11,324 It is important to note that meeting the requirements 177 00:08:11,390 --> 00:08:13,192 for reporting to ClinicalTrials.gov 178 00:08:13,259 --> 00:08:15,328 does not necessitate a change 179 00:08:15,394 --> 00:08:17,864 in study design or study procedures. 180 00:08:17,930 --> 00:08:19,999 The reporting results should reflect what was planned 181 00:08:20,066 --> 00:08:21,467 and collected as part of the study 182 00:08:21,534 --> 00:08:24,303 as designed to meet the research objectives. 183 00:08:24,904 --> 00:08:27,240 Results are intended for readers of the medical literature 184 00:08:27,306 --> 00:08:28,474 and not the lay public. 185 00:08:28,541 --> 00:08:30,176 This is different from information provided 186 00:08:30,243 --> 00:08:31,377 during registration, 187 00:08:31,444 --> 00:08:34,213 which should be understandable to a lay audience 188 00:08:34,280 --> 00:08:36,682 to facilitate recruitment of study participants. 189 00:08:37,283 --> 00:08:40,019 Results provided and data tables should be informative 190 00:08:40,086 --> 00:08:41,888 with minimal narrative text. 191 00:08:42,455 --> 00:08:45,691 Conclusions and discussion of the data are not permitted. 192 00:08:45,758 --> 00:08:48,160 The database is intended for report of just the facts 193 00:08:48,227 --> 00:08:51,964 that is just the summary level data and results submission 194 00:08:52,031 --> 00:08:53,966 is not required for all registered trials 195 00:08:54,033 --> 00:08:56,335 only those that are subject to the final rule, 196 00:08:56,402 --> 00:08:59,205 NIH policy, or other funding policies. 197 00:09:01,274 --> 00:09:04,010 The ClinicalTrials.gov quality assurance team reviews records 198 00:09:04,076 --> 00:09:07,113 for apparent validity, meaningful entries, logic, 199 00:09:07,179 --> 00:09:10,249 and internal consistency and will return a record 200 00:09:10,316 --> 00:09:13,519 with comments requiring the resolution of major problems 201 00:09:13,586 --> 00:09:15,621 when the following types of issues arise. 202 00:09:16,155 --> 00:09:17,723 When there's a lack of apparent validity, 203 00:09:17,790 --> 00:09:18,925 such as an outcome measure 204 00:09:18,991 --> 00:09:22,161 that reports a mean of 263 hours of sleep per day, 205 00:09:22,995 --> 00:09:24,697 when a description of an analysis 206 00:09:24,764 --> 00:09:26,332 is too big to be meaningful. 207 00:09:26,399 --> 00:09:27,867 For example, when an outcome measure 208 00:09:27,934 --> 00:09:30,336 reports the results of a scaled assessment 209 00:09:30,403 --> 00:09:33,339 without sufficient information to interpret the result, 210 00:09:33,406 --> 00:09:37,109 when data are inconsistent with the description of the analysis, 211 00:09:37,176 --> 00:09:38,377 for example, when an outcome measure 212 00:09:38,444 --> 00:09:39,879 reports account of participants 213 00:09:39,946 --> 00:09:43,215 rather than a median and full range or a time to event. 214 00:09:44,283 --> 00:09:46,519 When information throughout a record is inconsistent, 215 00:09:46,585 --> 00:09:47,787 for example, 216 00:09:47,853 --> 00:09:50,389 when a study designated as observational indicates 217 00:09:50,456 --> 00:09:53,192 that randomization was used to assign participants 218 00:09:53,259 --> 00:09:54,694 to interventions, 219 00:09:54,760 --> 00:09:56,595 or when a trial design is unclear. 220 00:09:57,129 --> 00:09:59,231 For example, when participants suddenly appear 221 00:09:59,298 --> 00:10:00,666 in an outcome measure analysis 222 00:10:00,733 --> 00:10:02,435 who were not included in the participant 223 00:10:02,501 --> 00:10:05,438 flow or baseline characteristics modules. 224 00:10:08,074 --> 00:10:11,143 With ClinicalTrials.gov in peer reviewed journal publications 225 00:10:11,210 --> 00:10:14,313 seek to ensure accurate and informative results reporting. 226 00:10:14,380 --> 00:10:16,615 However, they differ in important ways. 227 00:10:16,682 --> 00:10:17,917 ClinicalTrials.gov results 228 00:10:17,984 --> 00:10:19,885 reporting does not reject submissions. 229 00:10:20,453 --> 00:10:23,055 While peer reviewed journals can refuse to publish research 230 00:10:23,122 --> 00:10:25,825 that isn't deemed high quality or interest to readers. 231 00:10:26,425 --> 00:10:28,227 ClinicalTrials.gov permits the disclosure 232 00:10:28,294 --> 00:10:30,529 of all outcome measures that were assessed, 233 00:10:30,596 --> 00:10:32,231 while journals might limit the focus 234 00:10:32,298 --> 00:10:34,734 to the report of critical aspects of a study, 235 00:10:34,800 --> 00:10:36,802 thereby excluding some outcome measures. 236 00:10:37,436 --> 00:10:40,973 And ClinicalTrials.gov does not permit extensive narrative text. 237 00:10:41,040 --> 00:10:43,809 It is intended for tabular summary level data only. 238 00:10:44,377 --> 00:10:46,846 In contrast, journal articles rely upon narrative 239 00:10:46,912 --> 00:10:48,848 text and conclusive language 240 00:10:48,914 --> 00:10:51,017 to provide context for reported results 241 00:10:51,083 --> 00:10:53,886 and to allow for interpretation of comparative analyses. 242 00:10:54,820 --> 00:10:56,022 In summary, the 243 00:10:56,088 --> 00:10:58,090 ClinicalTrials.gov Results Database 244 00:10:58,157 --> 00:11:00,693 was designed to fulfill legal requirements, 245 00:11:00,760 --> 00:11:02,762 facilitate structured data entry, 246 00:11:02,828 --> 00:11:05,865 and support detailed searches of results information. 247 00:11:05,931 --> 00:11:08,267 Results are reported in four scientific modules 248 00:11:08,334 --> 00:11:10,703 that reflect the flow of participants through a study, 249 00:11:10,770 --> 00:11:12,538 their baseline characteristics, 250 00:11:12,605 --> 00:11:14,206 the results of outcome measure analyses 251 00:11:14,273 --> 00:11:15,641 in which they participate, 252 00:11:15,708 --> 00:11:17,777 and any serious adverse events frequent, 253 00:11:17,843 --> 00:11:20,279 non-serious adverse events or deaths 254 00:11:20,346 --> 00:11:22,515 that occur over the course of the study. 255 00:11:22,581 --> 00:11:24,683 There are also three types of supporting documentation 256 00:11:24,750 --> 00:11:27,887 that can or should be appended, including the study protocol, 257 00:11:27,953 --> 00:11:31,490 the statistical analysis plan, and the informed consent form. 258 00:11:32,358 --> 00:11:34,326 Results should be prepared for submission 259 00:11:34,393 --> 00:11:37,496 by someone who understands the study design and analytic plan. 260 00:11:38,064 --> 00:11:40,466 Results submissions to ClinicalTrials.gov 261 00:11:40,533 --> 00:11:42,935 serve to supplement journal publication 262 00:11:43,002 --> 00:11:46,172 by allowing a board of all analyses and studies. 263 00:11:48,307 --> 00:11:50,342 Now I'll ask a couple of questions 264 00:11:50,409 --> 00:11:52,378 to review the material that we covered. 265 00:11:53,145 --> 00:11:54,613 True or False? 266 00:11:54,680 --> 00:11:56,582 Results reporting is required for all trials 267 00:11:56,649 --> 00:11:59,051 that have been registered on ClinicalTrials.gov. 268 00:12:01,420 --> 00:12:04,256 This is false -- results submission is not required 269 00:12:04,323 --> 00:12:07,259 for registered studies that are not subject to the final rule, 270 00:12:07,326 --> 00:12:10,196 NIH policy, or other funding policies. 271 00:12:12,431 --> 00:12:13,999 True or False? 272 00:12:14,066 --> 00:12:16,669 When reporting results on ClinicalTrials.gov researchers 273 00:12:16,735 --> 00:12:18,904 can describe conclusions drawn from analyses 274 00:12:18,971 --> 00:12:21,307 of all pre specified outcome measures, 275 00:12:21,373 --> 00:12:24,410 even ones that aren't reported in journal publications. 276 00:12:26,812 --> 00:12:28,614 This is false -- ClinicalTrials.gov 277 00:12:28,681 --> 00:12:32,651 does not permit study records to include conclusive language 278 00:12:32,718 --> 00:12:34,453 or discussion of trial results. 279 00:12:37,123 --> 00:12:39,091 I hope you've learned about the types of information 280 00:12:39,158 --> 00:12:42,495 included in results submissions to ClinicalTrials.gov 281 00:12:42,561 --> 00:12:45,498 and how these submissions differ from journal publications. 282 00:12:46,031 --> 00:12:47,633 Thank you for your attention.