Clinical Trial Activation Has Slowed to Critical Point: 'All
Systems Go' on Reform
Inefficiencies in the NCI-funded cancer clinical trials endeavor
prompted the NCI Clinical Trials and Translational Research
Advisory Committee (CTAC) to establish the Operational Efficiency
Working Group (OEWG). This body was charged with identifying
barriers to speed and efficiency in protocol development and
approval-and devising ways to eliminate them.
NCI approved the first phase of OEWG's work in March, and it
went into effect this January. The 14 recommendations (see sidebar,
OEWG Recommendations for Trial Activation on page 8) contain
enforceable timelines for protocol development and implementation,
including a "drop dead" date, at which time it will be
terminated.


Draconian?
Not really, said James H. Doroshow, MD, Director,
NCI Division of Cancer Therapy Evaluation Program (CTEP) and Chair
of the 63-member working group. "The report was unanimously
endorsed, and everyone agreed on the timelines."
How did inefficiencies in the clinical trial system evolve?
Gabriel Hortobagyi, MD, Professor of Medicine and
Chair, Department of Breast Medical Oncology, MD Anderson
Cancer Center, and Co-Chair of OEWG, said there are several major
reasons.
First are the overwhelming regulations. "Thirty years ago, it
took less than a month to get a trial going, from an investigator's
idea to accrual of the first patient, and that included writing the
protocol, IRB submission and approval, and calling a pharmaceutical
company for sponsorship. Now all that takes a year or more-not
including all the bureaucratic rigmarole of reporting adverse
events, modifying the proposal, and filling out more forms."
And that's only when a single institution is doing the study.
When it's a multisite affair, such as with a cooperative group, the
time, expense, bureaucratic intervention, and aggravation are
multiplied exponentially.
Dr. Doroshow agrees. "The minutiae of bureaucracy eat up so much
time and so many resources that it has become impossible to
control. When I first came to work at NCI in 1975, a protocol was 5
or 10 pages long. A consent form was a page or so. Now each file is
inches thick," he said.
"The boilerplate is excessive, consent forms are so long and
involved that a lawyer can barely understand them, let alone a
patient," he continued. "Everything has more steps, involves more
people, takes more time, and costs more money. There are too many
rules and regulations."
Second is the health-care economy in general. There are many
well-known reasons why everything costs more each year, and
clinical trials are no exception.
Despite challenges, the federally funded clincal trials system
has led to countless breakthroughs that have transformed cancer
care. Removing bureaucratic impediments to trial activation will
unleash the potential of the system to move quickly to investigate
the latest ideas for new treatment options, Lawrence
Wickerham, MD, Associate Chairman, National Surgical
Adjuvant Breast and Bowel Project, Associate Professor of Human
Oncology, Drexel University College of Medicine, Pittsburgh, and
OEWG member, told The ASCO Post. "We at NSABP design trials that
not only can meet accrual goals but can answer the scientific
questions as well. We've had considerable success, and so have many
other institutions and cooperative groups."
Time to Trial Activation and Accrual
Before improvements were made to the
system, some trials took so long to get started that investigators
lost interest before the first patient was recruited. Cooperative
group phase III trials have a current median time to
activation of 830 days-more than 2 years. It is 550 days for
phase II trials and 200 days for investigator-initiated cancer
center trials (see Fig. 1).
Many trials accrue only a small percentage of the required
subjects, and some accrue none. In fact, the longer the process
takes, the less likely full accrual will be reached. A recent study
sponsored by CTEP found that only 18.5% of all trials achieved
their minimum accrual goals, and 54.2% of 2,685 trials at 14 NCI
comprehensive cancer centers did not accrue any patients at all.
Only 26.6% accrued more than two patients.
The situation is not all that dire, however, said Dr. Wickerham.
"Of 10 NSABP breast cancer trials activated between 2000 and 2007,
only 1 was stopped because of inadequate accrual, and only 1 of 4
colorectal studies failed to meet its goal. Of the more than 34,000
patients in these trials, only 0.5% entered a study that was closed
due to low accrual. We try to avoid enrolling any patient in a
trial that will not be completed," he said.
Other trial groups have equally positive numbers; nevertheless,
the clinical trial community must develop better ways to choose
trials, get them going with minimal delay, accrue patients-and stop
them when it is pointless to continue.
The Remedies
In addition to OEWG's 14 initiatives, the
committee established targets for trial activation: 300 days for
phase III, 210 days for phase II, and 90 days for
investigator-initiated trials. Protocols that have been in the
review pipeline for more than 24 months (for phase III) or
18 months (for phase II) will be terminated, retroactive to
January 2011.
Cancer centers that conduct NCI-funded grants can improve internal
management to increase efficiency (see sidebar, Recommendations to
Increase Efficiency at NCI-funded Cancer Centers), but some are
reluctant to participate in multisite trials because collaboration
in such efforts is not recognized as a legitimate academic
activity, nor is it seen as an important service. As a remedy, OEWG
recommended the following measures:
- Including trial leadership, as well as accrual of patients in
trials led by others, as a criterion for academic tenure and
promotion
- Encouraging deans and department chairs to honor trial
participation
- Enhancing training and mentorship for junior investigators as
incentives to remain in academic medicine and clinical research
(NCI will create new training programs to further this goal)
OEWG also recommended that CTEP and cooperative groups work with
FDA, industry, and NCI to define standards about registration
studies, establish consistency in protocol development, and resolve
issues of trial objectives and design.
Collaborative Efforts
The OEWG initiatives will be "taken seriously by everyone
involved," said Dr. Wickerham, "and I'm sure that people will put
forth their best effort to make them work."
Yes, everyone agrees that clinical trials need to be faster and
more efficient, said Dr. Hortobagyi. And if it were up to only
those conducting them, it wouldn't be such a problem. But the
system is enormous, unwieldy, and fractured.
There are too many government agencies, private industry
members, politicians, and advocacy groups for it to work even
reasonably smoothly. "It takes 800 steps to perform one trial, so
we must change the systemic problems."
It's Starting to Work
Between April 1 and December 1,
2010, CTEP received 13 phase III proposals, 45 unsolicited
phase I, I/II, or II proposals from cooperative groups, and a
number of intramural ones. Of those approved, all are on
schedule.
"People respond well to targets," said Dr. Doroshow. "This new
system will get clinical trials moving again, increase
transparency, and improve accrual."
NCI has instituted initiatives to help achieve OEWG goals. Two
are especially helpful. During the course of getting a trial up and
running, innumerable questions and problems arise. They have
traditionally been resolved by sending e-mails, twiddling thumbs
while they languish in in-boxes, waiting for replies, and then
asking someone else the same or related questions. This takes
weeks. A much better way is to conduct a conference call and hash
things out in a matter of minutes. "These calls save enormous
amounts of time and frustration," said Dr. Doroshow.
The other initiative is establishment of a website to track
timelines. Steve Friedman, MHSA, Chief, Clinical Trials Operations
and Informatics Branch, explained that the website provides access
to NCI employees and investigators who need to follow a protocol's
progress. All steps are listed in a timeline (how much time each
took, how much time is left, etc), which can be compared to those
of other protocols.
"It works like the FedEx tracking system: You know where your
package is, when it's on the truck, and when the driver is going to
ring your doorbell," he said. ■