IJParticleon Data Management
IJParticleon Data Management
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Educational Forum
ABSTRACT
Clinical Data Management (CDM) is a critical phase in clinical research, which leads to
generation of high‑quality, reliable, and statistically sound data from clinical trials. This
helps to produce a drastic reduction in time from drug development to marketing. Team
members of CDM are actively involved in all stages of clinical trial right from inception
Global Medical Affairs, Dr. Reddy’s to completion. They should have adequate process knowledge that helps maintain the
Laboratories Ltd., Ameerpet, quality standards of CDM processes. Various procedures in CDM including Case Report
Hyderabad, India Form (CRF) designing, CRF annotation, database designing, data‑entry, data validation,
discrepancy management, medical coding, data extraction, and database locking are
Received: 07-03-2011 assessed for quality at regular intervals during a trial. In the present scenario, there is an
Revised: 08-11-2011
increased demand to improve the CDM standards to meet the regulatory requirements
Accepted: 01-01-2012
and stay ahead of the competition by means of faster commercialization of product. With
the implementation of regulatory compliant data management tools, CDM team can meet
Correspondence to:
these demands. Additionally, it is becoming mandatory for companies to submit the data
Dr. Binny Krishnankutty,
electronically. CDM professionals should meet appropriate expectations and set standards
E‑mail: [email protected]
for data quality and also have a drive to adapt to the rapidly changing technology. This
article highlights the processes involved and provides the reader an overview of the tools
and standards adopted as well as the roles and responsibilities in CDM.
KEY WORDS: Clinical data interchange standards consortium, clinical data management
systems, data management, e‑CRF, good clinical data management practices, validation
arbitrarily ‘acceptable level of variation’ that would not affect the 11‑compliant systems. Most of the CDM systems available are
conclusion of the study on statistical analysis. The data should like this and pharmaceutical companies as well as contract
also meet the applicable regulatory requirements specified for research organizations ensure this compliance.
data quality. Society for Clinical Data Management (SCDM) publishes the
Tools for CDM Good Clinical Data Management Practices (GCDMP) guidelines,
Many software tools are available for data management, and a document providing the standards of good practice within
these are called Clinical Data Management Systems (CDMS). In CDM. GCDMP was initially published in September 2000 and has
multicentric trials, a CDMS has become essential to handle the undergone several revisions thereafter. The July 2009 version
huge amount of data. Most of the CDMS used in pharmaceutical is the currently followed GCDMP document. GCDMP provides
companies are commercial, but a few open source tools are guidance on the accepted practices in CDM that are consistent
available as well. Commonly used CDM tools are ORACLE with regulatory practices. Addressed in 20 chapters, it covers
CLINICAL, CLINTRIAL, MACRO, RAVE, and eClinical Suite. In the CDM process by highlighting the minimum standards and
terms of functionality, these software tools are more or less best practices.
similar and there is no significant advantage of one system Clinical Data Interchange Standards Consortium (CDISC),
over the other. These software tools are expensive and need a multidisciplinary non‑profit organization, has developed
sophisticated Information Technology infrastructure to function. standards to support acquisition, exchange, submission, and
Additionally, some multinational pharmaceutical giants use archival of clinical research data and metadata. Metadata is the
custom‑made CDMS tools to suit their operational needs and data of the data entered. This includes data about the individual
procedures. Among the open source tools, the most prominent who made the entry or a change in the clinical data, the date and
ones are OpenClinica, openCDMS, TrialDB, and PhOSCo. These time of entry/change and details of the changes that have been
CDM software are available free of cost and are as good as made. Among the standards, two important ones are the Study
their commercial counterparts in terms of functionality. These Data Tabulation Model Implementation Guide for Human Clinical
open source software can be downloaded from their respective Trials (SDTMIG) and the Clinical Data Acquisition Standards
websites. Harmonization (CDASH) standards, available free of cost from
In regulatory submission studies, maintaining an audit trail the CDISC website (www.cdisc.org). The SDTMIG standard[4]
of data management activities is of paramount importance. describes the details of model and standard terminologies for
These CDM tools ensure the audit trail and help in the the data and serves as a guide to the organization. CDASH v
management of discrepancies. According to the roles and 1.1[5] defines the basic standards for the collection of data in a
responsibilities (explained later), multiple user IDs can be clinical trial and enlists the basic data information needed from
created with access limitation to data entry, medical coding, a clinical, regulatory, and scientific perspective.
database designing, or quality check. This ensures that each The CDM Process
user can access only the respective functionalities allotted to The CDM process, like a clinical trial, begins with the end in
that user ID and cannot make any other change in the database. mind. This means that the whole process is designed keeping
For responsibilities where changes are permitted to be made the deliverable in view. As a clinical trial is designed to answer
in the data, the software will record the change made, the the research question, the CDM process is designed to deliver
user ID that made the change and the time and date of change, an error‑free, valid, and statistically sound database. To meet
for audit purposes (audit trail). During a regulatory audit, the this objective, the CDM process starts early, even before the
auditors can verify the discrepancy management process; the finalization of the study protocol.
changes made and can confirm that no unauthorized or false Review and finalization of study documents
changes were made. The protocol is reviewed from a database designing
Regulations, Guidelines, and Standards in CDM perspective, for clarity and consistency. During this review, the
Akin to other areas in clinical research, CDM has guidelines CDM personnel will identify the data items to be collected and
and standards that must be followed. Since the pharmaceutical the frequency of collection with respect to the visit schedule.
industry relies on the electronically captured data for the A Case Report Form (CRF) is designed by the CDM team, as this
evaluation of medicines, there is a need to follow good practices is the first step in translating the protocol‑specific activities into
in CDM and maintain standards in electronic data capture. data being generated. The data fields should be clearly defined
These electronic records have to comply with a Code of Federal and be consistent throughout. The type of data to be entered
Regulations (CFR), 21 CFR Part 11. This regulation is applicable should be evident from the CRF. For example, if weight has to
to records in electronic format that are created, modified, be captured in two decimal places, the data entry field should
maintained, archived, retrieved, or transmitted. This demands have two data boxes placed after the decimal as shown in
the use of validated systems to ensure accuracy, reliability, and Figure 1. Similarly, the units in which measurements have to be
consistency of data with the use of secure, computer‑generated, made should also be mentioned next to the data field. The CRF
time‑stamped audit trails to independently record the date and should be concise, self‑explanatory, and user‑friendly (unless
time of operator entries and actions that create, modify, or you are the one entering data into the CRF). Along with the
delete electronic records.[3] Adequate procedures and controls CRF, the filling instructions (called CRF Completion Guidelines)
should be put in place to ensure the integrity, authenticity, and should also be provided to study investigators for error‑free
confidentiality of data. If data have to be submitted to regulatory data acquisition. CRF annotation is done wherein the variable
authorities, it should be entered and processed in 21 CFR part is named according to the SDTMIG or the conventions followed
internally. Annotations are coded terms used in CDM tools to CRF tracking
indicate the variables in the study. An example of an annotated The entries made in the CRF will be monitored by the Clinical
CRF is provided in Figure 1. In questions with discrete value Research Associate (CRA) for completeness and filled up CRFs
options (like the variable gender having values male and female are retrieved and handed over to the CDM team. The CDM team
as responses), all possible options will be coded appropriately. will track the retrieved CRFs and maintain their record. CRFs
Based on these, a Data Management Plan (DMP) is are tracked for missing pages and illegible data manually to
developed. DMP document is a road map to handle the data assure that the data are not lost. In case of missing or illegible
under foreseeable circumstances and describes the CDM data, a clarification is obtained from the investigator and the
activities to be followed in the trial. A list of CDM activities is issue is resolved.
provided in Table 1. The DMP describes the database design, data Data entry
entry and data tracking guidelines, quality control measures, Data entry takes place according to the guidelines prepared
SAE reconciliation guidelines, discrepancy management, data along with the DMP. This is applicable only in the case of
transfer/extraction, and database locking guidelines. Along with paper CRF retrieved from the sites. Usually, double data entry
the DMP, a Data Validation Plan (DVP) containing all edit‑checks is performed wherein the data is entered by two operators
to be performed and the calculations for derived variables are separately.[8] The second pass entry (entry made by the second
also prepared. The edit check programs in the DVP help in person) helps in verification and reconciliation by identifying
cleaning up the data by identifying the discrepancies. the transcription errors and discrepancies caused by illegible
Database designing data. Moreover, double data entry helps in getting a cleaner
database compared to a single data entry. Earlier studies have
Databases are the clinical software applications, which
shown that double data entry ensures better consistency with
are built to facilitate the CDM tasks to carry out multiple
paper CRF as denoted by a lesser error rate.[9]
studies.[6] Generally, these tools have built‑in compliance
with regulatory requirements and are easy to use. “System Data validation
validation” is conducted to ensure data security, during which Data validation is the process of testing the validity of data
system specifications,[7] user requirements, and regulatory in accordance with the protocol specifications. Edit check
compliance are evaluated before implementation. Study details programs are written to identify the discrepancies in the
like objectives, intervals, visits, investigators, sites, and patients entered data, which are embedded in the database, to ensure
are defined in the database and CRF layouts are designed for data validity. These programs are written according to the logic
data entry. These entry screens are tested with dummy data condition mentioned in the DVP. These edit check programs
before moving them to the real data capture. are initially tested with dummy data containing discrepancies.
Discrepancy is defined as a data point that fails to pass a
Data collection validation check. Discrepancy may be due to inconsistent data,
Data collection is done using the CRF that may exist in the missing data, range checks, and deviations from the protocol.
form of a paper or an electronic version. The traditional method In e‑CRF based studies, data validation process will be run
is to employ paper CRFs to collect the data responses, which frequently for identifying discrepancies. These discrepancies
are translated to the database by means of data entry done will be resolved by investigators after logging into the system.
in‑house. These paper CRFs are filled up by the investigator Ongoing quality control of data processing is undertaken at
according to the completion guidelines. In the e‑CRF‑based regular intervals during the course of CDM. For example, if
CDM, the investigator or a designee will be logging into the the inclusion criteria specify that the age of the patient should
CDM system and entering the data directly at the site. In be between 18 and 65 years (both inclusive), an edit program
e‑CRF method, chances of errors are less, and the resolution will be written for two conditions viz. age <18 and >65. If for
of discrepancies happens faster. Since pharmaceutical any patient, the condition becomes TRUE, a discrepancy will
companies try to reduce the time taken for drug development be generated. These discrepancies will be highlighted in the
processes by enhancing the speed of processes involved, many system and Data Clarification Forms (DCFs) can be generated.
pharmaceutical companies are opting for e‑CRF options (also DCFs are documents containing queries pertaining to the
called remote data entry). discrepancies identified.
• Data Manager by means of the systems and processes being implemented and
• Database Programmer/Designer the standards being followed. The biggest challenge from the
• Medical Coder regulatory perspective would be the standardization of data
• Clinical Data Coordinator management process across organizations, and development
• Quality Control Associate of regulations to define the procedures to be followed and the
• Data Entry Associate data standards. From the industry perspective, the biggest
The data manager is responsible for supervising the entire hurdle would be the planning and implementation of data
CDM process. The data manager prepares the DMP, approves management systems in a changing operational environment
the CDM procedures and all internal documents related where the rapid pace of technology development outdates the
to CDM activities. Controlling and allocating the database existing infrastructure. In spite of these, CDM is evolving to
access to team members is also the responsibility of the data become a standard‑based clinical research entity, by striking a
manager. The database programmer/designer performs the balance between the expectations from and constraints in the
CRF annotation, creates the study database, and programs the existing systems, driven by technological developments and
edit checks for data validation. He/she is also responsible for business demands.
designing of data entry screens in the database and validating
the edit checks with dummy data. The medical coder will do References
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and systems, thereby leading to encouraging results on speed Cite this article as: Krishnankutty B, Bellary S, Naveen Kumar BR,
and quality of data being generated. At the same time, CDM Moodahadu LS. Data management in clinical research: An overview. Indian
J Pharmacol 2012;44:168-72.
professionals should ensure the standards for improving data
Source of Support: Nil. Conflict of Interest: None declared.
quality.[11] CDM, being a speciality in itself, should be evaluated