Stata is a powerful statistical analysis software that offers some advantages for clinical trial and medtech use cases compared to the more widely used SAS software. Stata provides an intuitive and user-friendly interface that facilitates efficient data management, data processing and statistical analysis. Its agile and concise syntax allows for reproducible and transparent analyses, enhancing the overall research process with more readily accessible insights.
Distinct from R, which incorporates S based coding, both Stata and SAS have used C based programming languages since 1985. All three packages can parse full Python within their environment for advanced machine learning capabilities, in addition to those available natively. In Stata’s case this is achieved through the pystata python package. Despite a common C based language, there are tangible differences between Stata and SAS syntax. Stata generally needs less lines of code on average compared to SAS to perform the same function and thus tends to be more concise. Stata also offers more flexibility to how you code as well as more informative error statements which makes debugging a quick and easy process, even for beginners.
When it comes to simulations and more advanced modelling our experience had been that the Basic Edition of Stata (BE) is faster and uses less memory to perform the same task compared to Base SAS. Stata BE certainly has more inbuilt capabilities than you would ever need for the design and analysis of advanced clinical trials and sophisticated statistical modelling of all types. There is also the additional benefit of thousands of user-built packages, such as the popular WinBugs, that can be instantly installed as add-ons at no extra cost. Often these packages are designed to make existing Stata functions even more customisable for immense flexibility and programming efficiency. Both Stata and SAS represent stability and reliability and have enjoyed widespread industry adoption. SAS has been more widely adopted by big pharma and Stata more-so with public health and economic modelling.
It has been nearly a decade since the Biostatistics Collaboration of Australia (BCA) which determines Biostatistics education nationwide has transitioned from teaching SAS and R as part of their Masters of Biostatistics programs to teaching Stata and R. This transition initially was made in anticipation of an industry-wide shift from SAS to Stata. Whether their predictions were accurate or not, the case for Stata use in clinical trials remains strong.
Stata is almost certainly a superior option for bootstrapped life science start-ups and SMEs. Stata licencing fees are in the low hundreds of pounds with the ability to quickly purchase over the Stata website, while SAS licencing fees span the tens to hundreds of thousands and often involve a drawn-out process just to obtain a precise quote.
Working with a CRO that is willing to use Stata means that you can easily re-run any syntax provided from the study analysis to verify or adapt it later. Of course, open-source software such as R is also available, however Stata has the advantage of a reduced learning curve being both user-friendly and sufficiently sophisticated.
Stata for clinical trials
Industry Adoption:
Stata has gained significant popularity and widespread adoption in the field of clinical research. It is commonly used by researchers, statisticians, and healthcare professionals for the statistical analysis of clinical data.
2. Regulatory Compliance and CDISC standardisation:
Stata provides features and capabilities that support regulatory compliance requirements in clinical trials. While it may not have the same explicit recognition from CDISC as SAS, Stata does lend itself well to CDISC compliance and offers tools for documentation, data tracking, and audit trails to ensure transparency and reproducibility in analyses.
3. Comprehensive Statistical Procedures:
A key advantage of Stata is its extensive suite of built-in statistical functions and commands specifically designed for clinical trial data analysis. Stata offers a wide range of methods for handling missing data, performing power calculations, and of course a wide range of methods for analysing clinical trial data; from survival analysis methods, generalized linear models, mixed-effects models, causal inference, and Bayesian simulation for adaptive designs. Preparatory tasks for clinical trials such as meta-analysis, sample size calculation and randomisation schedules are arguably easier to achieve in Stata than SAS. These built-in functionalities empower researchers to conduct various analyses within a single software environment.
4. Efficient Data Management:
Stata excels in delivering agile data management capabilities, enabling efficient data handling, cleaning, and manipulation. Its intuitive data manipulation commands allow researchers to perform complex transformations, merge datasets, handle missing data, and generate derived variables seamlessly.
Perhaps the greatest technical advantage of Stata over SAS in the context of clinical research is usability and greater freedom to keep open and refer to multiple data sets with multiple separate analyses at the same time. While SAS can keep many data sets in memory for a single project, Stata can keep many data sets in siloed memory for simultaneous use in different windows to enable viewing or working on many different projects at the same time. This approach can make workflow easier because no data step is required to identify which data set you are referring to, instead the appropriate sections of any data sets can be merged with the active project as needed and due to siloing, which works similarly to tabs in a browser, you do not get the log, data or output of one project mixed up with another. This is arguably an advantage for biostatisticians and researchers alike who typically do need to compare unrelated data sets or the statistical results from separate studies side-by-side.
5. Interactive and Reproducible Analysis:
Stata provides an interactive programming environment that allows users to perform data analysis in a step-by-step manner. The built-in “do-file” functionality facilitates reproducibility by capturing all commands and results, ensuring transparency and auditability of the analysis process. The results and log window for each data set prints out the respective syntax required item by item. This syntax can easily be pasted into the do-file or the command line to edit or repeat the command with ease. SAS on the other hand tends to separate the results from the syntax used to derive it.
6. Graphics and Visualization:
While not traditionally known for this, Stata actually offers a wide range of powerful and customizable graphical capabilities. Researchers can generate high-quality publication standard plots and charts of any description needed to visualise clinical trial results Common examples include survival curves, forest plots, spaghetti and diagnostic plots. Stata also has built-in options to perform all necessary assumption and model checking for statical model development.
These visualisations facilitate the exploration and presentation of complex data patterns, as well as the presentation, and communication of findings. There are many user-created customisation add-ons for data visualisation that rival what is possible in R customisation.
The one area of Stata that users may find limiting is that it is only possible to display one graph at a time per active data set. This means that you do need to copy graphs as they are produced and save them into a document to compare multiple graphs side by side.
7. Active User Community and Support:
Like SAS, Stata has a vibrant user community comprising researchers, statisticians, and experts who actively contribute to discussions, share knowledge, and provide support. StataCorp, the company behind Stata, offers comprehensive documentation, online resources, and user forums, ensuring users have access to valuable support and assistance when needed. Often the resources available for Stata are more direct and more easily searchable than what is available for SAS when it comes to solving customisation quandaries. This is of course bolstered by the availability of myriad instant package add-ons.
Stata’s active and supportive user community is a notable advantage. Researchers can access extensive documentation, online forums, and user-contributed packages, which promote knowledge sharing and facilitate problem-solving. Additionally, Stata’s reputable technical support ensures prompt assistance for any software-related queries or challenges.
While SAS and Stata have their respective strengths, Stata’s increasing industry adoption, statistical capabilities, data management features, reproducibility, visualisation add-ons, and support community make it a compelling choice for clinical trial data analysis.
As it stands, SAS remains the most widely used software in big-pharma for clinical trial data analysis. Stata however offers distinct advantages in terms of user-friendliness, tailored statistical functionalities, advanced graphics, and a supportive user community. Consider adopting Stata to streamline your clinical trial analyses and unlock its vast potential for gaining insights from research outcomes. An in-depth overview of Stata 18 can be found here. A summary of it’s features for biostatisticians can be found here.
P values are so ubiquitous in clinical research that it’s easy to take for granted that they are being understood and interpreted correctly. After-all, one might say, they are just simple proportions and it’s not brain surgery. At times, however, its’ the simplest of things that are easiest to overlook. In fact, the definitions and interpretations of p values are sufficiently subtle that even a minute pivot from an exact definition can lead to interpretations that are wildly misleading.
In the case of clinical trials, p values have a momentous impact on decision making in terms of whether or not to pursue and invest further into the development and marketing of a given therapeutic. In the context of clinical practice p values drive treatment decisions for patients as they essentially comprise the foundational evidence upon which these treatment decisions are made. This is perhaps as it should be, as long as the definition of p values and their interpretations are sound.
A counter-point to this is the bias towards publishing only studies with a statistically significant p value, as well as the fact that many studies are not sufficiently reproducible or reproduced. This leaves clinicians with an impression that evidence for a given treatment is stronger than the full picture would suggest. This however is a publishing issue rather than an issue of significance tests themselves. This article focusses on interpretation issues only.
As p values apply to the interpretation of both parametric and non-parametric tests in much the same way, this article will focus on parametric examples.
Interpreting p values in superiority/difference study designs
This refers to studies where we are seeking to find a difference between two treatment groups or between a single group measured at two time points. In this case the null hypothesis is that there is no difference between the two treatment groups or no effect of the treatment, as the case may be.
According to the significance testing framework all p values are calculated based upon an assumption that the null hypothesis is true. If a study yields a p value of 0.05, this means that we would expect to see a difference between the two groups at least as extreme as the observed effect 5% of the time; if the study were to be repeated. In other words, if there is no true difference between the two treatment groups and we ran the experiment 20 times on 20 independent samples from the same population, we would expect to see a result this extreme once out of the 20 times.
This of course is not a very helpful way of looking at things if our goal is to make a statement about treatment effectiveness. The inverse likely makes more intuitive sense: if were were to run this study 20 times on distinct patient samples from the same population, 19 out of 20 times we would not expect a result this extreme if there was no true effect. Based on the rarity of the observed effect, we conclude that likelihood of the null hypothesis being the optimal explanation of the data is sufficiently low that we can reject it. Thus our alternative research hypothesis, that there is a difference between the two treatments, is likely to be true. As the p value does not tell us whether the difference is a positive or negative direction, care should of course be taken to confirm which of the treatments holds the advantage.
P values in non-inferiority or equivalence studies.
In non-inferiority and equivalence studies a non-statistically significant p value can be a welcome result, as can a very low p value where the differences were not clinically significant, or where the new treatment is shown to be superior to the standard treatment. By only requiring the treatment not to be inferior, more power is retained and a smaller sample size can be used.
The interpretation of the p value is much the same as for superiority studies, however the implications are different. In these types of studies it is ideal for the confidence intervals for the individual treatment effects to be narrow as this provides certainty that the estimates obtained are accurate in the absence of a statistically significant difference between the two estimates.
While alternatives to p values exist, such as Bayesian statistics, these statistics have limitations of their own and are subject to the same propensity for misuse and misinterpretation as frequentist statistics are. Thus it remains important to take caution in interpreting all statistical results.
What p values do not tell you
A p value of 0.05 is not the same as saying that there is only a 5% chance that the treatment wont work. Whether or not the treatment works in the individual is another probability entirely. It is also not the same as saying there is a 5% chance of the null hypothesis being true. The p value is a statistic that is based on the assumption that the null hypothesis is true and on that basis gives the likelihood of the observed result.
Nor does the p value represent the chance of making a type 1 error. As each repetition of the same experiment produces a different p value, it does not make sense to characterise the p value as the chance of incorrectly rejecting the null hypothesis ie making a type one error. Instead, an alpha cut-off point of 0.05 should be seen as indicating a result rare enough under the null hypothesis that we are now willing to reject the null as the most likely explanation given the data. Under a type-one error alpha of 0.05 this decision is expected to be wrong 5% of the time, regardless of the p value achieved in the statistical test. The relationship between the critical alpha and statistical power is illustrated below.
Another misconception is that a small p value provides strong support for a given research hypothesis. In reality a small p value does not necessarily translate to a big effect, nor a clinically meaningful one. The p value indicates a statistically significant result, however it says nothing about the magnitude of the effect or whether this result is clinically meaningful in the context of the study. A p value of 0.00001 may appear to be a very satisfactory result, however if the difference observed between the two groups is very small then this is not always the case. All it would be saying is that “we are really really sure that there is only minimal difference between the two treatments”, which in a superiority design may not be as desired.
Minimally important difference (MID)
This is where the importance of pre-defining a minimally important difference (MID) becomes evident. The MID, or clinically meaningful difference. should be defined and quantified in the design stage before the study is to be undertaken. In the case of clinical studies this should generally be done in consultation with the clinician or disease expert concerned.
The MID may take different forms depending on whether a study is a superiority design, versus an equivalence or non-inferiority design. In the case of a superiority design or where the goal of the study is to detect a difference, the MID is the threshold of minimum difference at which we would be willing to consider the new treatment worth pursuing over the standard treatment or control being used as the comparator. In the case of a non-inferiority design the MID would be the minimum lower threshold at which we would still consider the new treatment as equally effective or useful as the standard treatment. Equivalence design on the other hand may sometimes rely on an interval around the standard treatment effect.
When interpreting results of clinical studies it is of primary importance to keep a clinically meaningful difference in mind, rather than defaulting to the p value in isolation. In cases where the p value is statistically significant, it is important to ask whether the difference between comparison groups is also as large as the MID or larger.
Confidence Intervals
All statistical tests that involve p values can produce a corresponding confidence interval for the estimates. Unlike p values, confidence intervals do not rely on an assumption of the null hypothesis but rather on the assumption that the sample approximates the population of interest. A common estimate in clinical trials where confidence intervals become important is the treatment effect. Very often this translates to the difference in means of a surrogate endpoint between two groups, however confidence intervals are also important to consider for individual group means/ treatment effects, which are an estimate of the population means of the endpoint in these distinct groups/treatment categories.
Confidence interval for the mean
A 95% confidence interval of the estimate of the mean indicates that, if this study were to be repeated, the mean value is expected to fall within this interval 95% of the time. While this estimate is based on the real mean of the study sample our interest remains in making inferences about the wider population who might later be subject to this treatment. Thus inferentially the observed mean and it’s confidence interval are both considered an estimate of the population values.
In a nutshell the confidence interval indicates how sure we can be of the accuracy of the estimate. A narrower interval indicates greater confidence and a wider interval less. The p value of the estimate indicates how certain we can be of this result, ie the interval itself.
Confidence interval for the mean difference, treatment effects or difference in treatment effects
The mean difference in treatment effect between two groups is an important estimate in any comparison study, from superiority to non-inferiority clinical trial designs. Treatment response is mainly ascertained from repeated measures of surrogate endpoint data on the individual level. One form of mean difference is repeated measures data from the same individuals at different time points, these individuals’ differences could then be compared between two independent treatment groups. In the context of clinical trials, confidence intervals of the mean difference can relate to an individual’s treatment effect or to group differences in treatment effects.
A 95% Confidence interval of the mean difference in treatment effect indicates that 95 per cent of the time, if this study were to be repeated, the true difference in treatment effect between the groups is expected to fall within this interval. A confidence interval containing zero indicates that a statistically significant difference between the two groups has not been found. Namely, if part of the time the true population value representing the difference is expected to fall above zero on the number line and part of the time to fall below zero, indicating a difference in the opposite direction, we cannot be sure whether one group is higher or lower than the other.
Much ho-hum has been made of p values in recent years but they are here to stay. While alternatives to p values exist, such as Bayesian methods, these statistics have limitations of their own and are subject to the same propensity for misuse and misinterpretation as frequentist statistics are. Thus it remains important to take caution in interpreting all statistical results.
Sources and further reading:
Gao, P-Values – A chronic conundrum, BMC Medical Research Methodology (2020), 20:167 https://doi.org/10.1186/s12874-020-01051-6
The Royal College of Ophthalmologists, The clinician’s guide to p values, confidence intervals, and magnitude of effects, Eye (2022) 36:341–342; https://doi.org/10.1038/s41433-021-01863-w
As a medical researcher or a small enterprise in the life sciences industry, you are likely to encounter many experts using statistical and computational techniques to study biological, clinical and other health data. These experts can come from a variety of fields such as biostatistics, bioinformatics, biometrics, clinical data science and epidemiology. Although these fields do overlap in certain ways they differ in purpose, focus, and application. All four areas listed above focus on analysing and interpreting either biological, clinical data or public health data but they typically do so in different ways and with different goals in mind. Understanding these differences can help you choose the most appropriate specialists for your research project and get the most out of their expertise. This article will begin with a brief description of these disciplines for the sake of disambiguation, then focus on biostatistics and bioinformatics, with a particular overview of the roles of biostatisticians and bioinformatics scientists in clinical trials.
Biostatisticians
Biostatisticians use advanced biostatistical methods to design and analyse pre-clinical experiments, clinical trials, and observational studies predominantly in the medical and health sciences. They can also work in ecological or biological fields which will not be the focus of this article. Biostatisticians tend to work on varied data sets, including a combination of medical, public health and genetic data in the context of clinical studies. Biostatisticians are involved in every stage of a research project, from planning and designing the study, to collecting and analysing the data, to interpreting and communicating the results. They may also be involved in developing new statistical methods and software tools. In the UK the term “medical statistician” has been in common use over the past 40 years to describe a biostatistician, particularly one working in clinical trials, but it is becoming less used due to the global nature of the life sciences industry.
Bioinformaticians
Bioinformaticians use computational and statistical techniques to analyse and interpret large datasets in the life sciences. They often work with multi-omics data such as genomics, proteomics transcriptomics data and use tools such as large databases, algorithms, and specialised software programs to analyse and make sense of sequencing and other data. Bioinformaticians develop analysis pipelines and fine-tune methods and tools for analysing biological data to fit the evolving needs of researchers.
Clinical data scientists
Data scientists use statistical and computational modelling methods to make predictions and extract insights from a wide range of data. Often, data is real-world big data of which it might not be practical to analyse using other methods. In a clinical development context data sources could include medical records, epidemiological or public health data, prior clinical study data, or IOT and IOB sensor data. Data scientists may combine data from multiple sources and types. Using analysis pipelines, machine learning techniques, neural networks, and decision tree analysis this data can be made sense of. The better the quality of the input data the more precise and accurate any predictive algorithms can be.
Statistical programmers
Statistical programmers help statisticians to efficiently clean and prepare data sets and mock TFLs in preparation for analysis. They set up SDTM and ADaM data structures in preparation for clinical studies. Quality control of data and advanced macros for database management are also key skills.
Biometricians
Biometricians use statistical methods to analyse data related to the characteristics of living organisms. They may work on topics such as growth patterns, reproductive success, or the genetic basis of traits. Biometricians may also be involved in developing new statistical methods for analysing data in these areas. Some use the terms biostatistician and biometrician interchangeably however for the purpose of this article they remain distinct.
Epidemiologists
Epidemiologists study the distribution and determinants of diseases in populations. Using descriptive, analytical, or experimental techniques, such as cohort or case-control studies, they identify risk factors for diseases, evaluate the effectiveness of public health interventions, as well as track or model the spread of infectious diseases. Epidemiologists use data from laboratory testing, field studies, and publicly available health data. They can be involved in developing new public health policies and interventions to prevent or control the spread of diseases.
Clinical trials and the role of data experts
Clinical trials involve testing new treatments, interventions, or diagnostic tests in humans. These studies are an important step in the process of developing new medical therapies and understanding the effectiveness and safety of existing treatments.
Biostatisticians are crucial to the proper design and analysis of clinical trials. So that optimal study design can take place, they may first have to conduct extensive meta-analysis of previous clinical studies and RWE generation based on available real-world data sets or R&D results. They may also be responsible for managing the data and ensuring its quality, as well as interpreting and communicating the results of the trial. From developing the statistical analysis plan and contributing to the study protocol, to final analysis and reporting, biostatisticians have a role to play across the project time-line.
During a clinical trial, statistical programmers may prepare data sets to CDISC standards and pre-specified study requirements, maintain the database, as well as develop and implement standard SAS code and algorithms used to describe and analyse the study data.
Bioinformaticians may be involved in the design and analysis stages of clinical trials, particularly if the trial design involves the use of large data sets such as sequencing data for multi-omics analysis. They may be responsible for managing and analysing this data, as well as developing software tools and algorithms to support the analysis.
Data scientists may be involved in designing and analysing clinical trials at the planning stage, as well as in developing new tools and methods. The knowledge gleaned from data science models can be used to improve decision-making across various contexts, including life sciences R&D and clinical trials. Some applications include optimising the patient populations used in clinical trials; feasibility analysis using simulation of site performance, region, recruitment and other variables, to evaluate the impacts of different scenarios on project cost and timeline.
Biometricians and epidemiologists may also contribute to clinical trials, particularly if the trial is focused on a specific population or on understanding the factors that influence the incidence or severity of a disease. They may contribute to the design of the study, collecting and analysing the data, or interpreting the results.
Overall, the role of these experts in clinical trials is to use their varied expertise in statistical analysis, data management, and research design to help understand the safety and effectiveness of new treatments and interventions.
The role of biostatistician in clinical trials
Biostatisticians may be responsible for developing the study protocol, determining the sample size, producing the randomisation schedule, and selecting the appropriate statistical methods for analysing the data. They may also be responsible for managing the data and ensuring its quality, as well as interpreting and communicating the results of the trial.
SDTM data preparation
The Study Data Tabulation Model (SDTM) is a data standard that is used to structure and organize clinical study data in a standardized way. Depending on how a CRO is structured, either biostatisticians, statistical programmers, or both will be involved in mapping the data collected in a clinical trial to the SDTM data set, which involves defining the structure and format of the data and ensuring that it is consistent with the standard. This helps to ensure that the data is organised in a way that is universally interpretable. This process involves working with the research team to ensure the appropriate variables and categories are defined before reviewing and verifying the data to ensure that it is accurate, complete and in line with industry standards. Typically the SDTM data set will be established early at the protocol phase and populated later once trial data is accumulated.
Creating and analysing the ADaM dataset
In clinical trials, the Analysis Data Model (ADaM) is a data set model used to structure and organize clinical trial data in a standardized way for the purpose of statistical analysis. ADaM data sets are used to store the data that will be analysed as part of the clinical trial, and are typically created from the Study Data Tabulation Model (SDTM) data sets, which contain the raw data collected during the trial. This helps to ensure the reliability and integrity of the data, and makes it easier to analyse and interpret the results of the trial.
Biostatisticians and statistical programmers are responsible for developing ADaM data sets from the SDTM data, which involves selecting the relevant variables and organizing them in a way that is appropriate for the particular statistical analyses that will be conducted. While statistical programmers may create derived variables, produce summary statistics, TFLs, and organise the data into appropriate datasets and domains, biostatisticians are responsible for conducting detailed statistical analyses of the data and interpreting the results. This may include tasks such as testing hypotheses, identifying patterns and trends in the data, and developing statistical models to understand the relationships between the data and the research questions the trial seeks to answer.
The role of biostatisticians, specifically, in developing ADaM data sets from SDTM data is to use their expertise in statistical analysis and research design to guide statistical programmers in ensuring that the data is organised, structured, and formatted in a way that is appropriate for the analyses that will be conducted, and to help understand and interpret the results of the trial.
A Biostatistician’s role in study design & planning
Biostatisticians play a critical role in the design, analysis, and interpretation of clinical trials. The role of the biostatistician in a clinical trial is to use their expertise in statistical analysis and research design to help ensure that the trial is conducted in a scientifically rigorous and unbiased way, and to help understand and interpret the results of the trial. Here is a general overview of the tasks that a biostatistician might be involved in during the different stages of a clinical trial:
Clinical trial design: Biostatisticians may be involved in designing the clinical trial, including determining the study objectives, selecting the appropriate study population, and developing the study protocol. They are responsible for determining the sample size and selecting the appropriate statistical methods for analysing the data. Often in order to carry out these tasks, preparatory analysis will be necessary in the form of detailed meta-analysis or systematic review.
Sample size calculation: Biostatisticians are responsible for determining the required sample size for the clinical trial. This is an important step, as the sample size needs to be large enough to detect a statistically significant difference between the treatment and control groups, but not so large that the trial becomes unnecessarily expensive or time-consuming. Biostatisticians use statistical algorithms to determine the sample size based on the expected effect size, the desired level of precision, and the expected variability of the data. This information is informed by expert opinion and simulation of the data from previous comparable studies.
Randomisation schedules: Biostatisticians develop the randomisation schedule for the clinical trial, which is a plan for assigning subjects to the treatment and control groups in a random and unbiased way. This helps to ensure that the treatment and control groups are similar in terms of their characteristics, which helps to reduce bias or control for confounding factors that might affect the results of the trial.
Protocol development: Biostatisticians are involved in developing the statistical and methodological sections of the clinical trial protocol, which is a detailed plan that outlines the objectives, methods, and procedures of the study. In addition to outlining key research questions and operational procedures the protocol should include information on the study population, the interventions being tested, the outcome measures, and the data collection and analysis methods.
Data analysis: Biostatisticians are responsible for analysing the data from the clinical trial, including conducting interim analyses and making any necessary adjustments to the protocol. They play a crucial role in interpreting the results of the analysis and communicating the findings to the research team and other stakeholders.
Final analysis and reporting: Biostatisticians are responsible for conducting the final analysis of the data and preparing the final report of the clinical trial. This includes summarising the results, discussing the implications of the findings, and making recommendations for future research.
The role of bioinformatician in biomarker-guided clinical studies.
Biomarkers are biological characteristics that can be measured and used to predict the likelihood of a particular outcome, such as the response to a particular treatment. Biomarker-guided clinical trials use biomarkers as a key aspect of the study design and analysis. In biomarker-guided clinical trials where the biomarker is based on genomic sequence data, bioinformaticians may play a particularly important role in managing and analysing the data. Genomic and other omics data is often large and complex, and requires specialised software tools and algorithms to analyse and interpret. Bioinformaticians develop and implement these tools and algorithms, as well as for managing and analysing the data to identify patterns and relationships relevant to the trial. Bioinformaticians use their expertise in computational biology to to help understand the relationship between multi-omics data and the outcome of the trial, and to identify potential biomarkers that can be used to guide treatment decisions.
Processing sequencing data is a key skill of bioinformaticians that involves several steps, which may vary depending on the specific goals of the analysis and the type of data being processed. Here is a general overview of the steps that a bioinformatician might take to process sequencing data:
Data pre-processing: Cleaning and formatting the data so that it is ready for analysis. This may include filtering out low-quality data, correcting errors, and standardizing the format of the data.
Mapping: Aligning the sequenced reads to a reference genome or transcriptome in order to determine their genomic location. This can be done using specialized software tools such as Bowtie or BWA.
Quality control: Checking the quality of the data and the alignment, and identifying and correcting any problems that may have occurred during the sequencing or mapping process. This may involve identifying and removing duplicate reads, or identifying and correcting errors in the data.
Data analysis: Using statistical and computational techniques to identify patterns and relationships in the data such as identifying genetic variants, analysing gene expression levels, or identifying pathways or networks that are relevant to the study.
Data visualization: Creating graphs, plots, and other visualizations to help understand and communicate the results of the analysis.
Once omics data has been analysed, the insights obtained can be used for tailoring therapeutic products to patient populations in a personalised medicine approach.
A changing role of data experts in life sciences R&D and clinical research
Due to the need for better therapies and health solutions, researchers are currently defining diseases at more granular levels using multi-omics insights from DNA sequencing data which allows differentiation between patients in the biomolecular presentation of their disease, demographic factors, and their response to treatment. As more and more of the resulting therapies reach the market the health care industry will need to catch up in order to provide these new treatment options to patients.
Even after a product receives regulatory approval, payers can opt not to reimburse patients, so financial benefit should be demonstrated in advance where possible. Patient reported outcomes and other health outcomes are becoming important sources of data to consider in evidence generation. Evidence provided to payers should aim to demonstrate financial as well as clinical benefit of the product.
In this context, regulators are becoming aware of the need for innovation in developing new ways of collecting treatment efficacy and other data used to assess novel products for regulatory approval. The value of observational studies and real-world-data sources as a supplement clinical trial data is being acknowledged as a legitimate and sometimes necessary part of the product approval process. Large scale digitisation now makes it easier to collect patient-centric data directly from clinical trial participants and users via devices and apps. Establishing clear evidence expectations from regulatory agencies then Collaborating with external stakeholders, data product experts, and service-providers to help build new evidence-building approaches.
Expert data governance and quality control is crucial to the success of any new methods to be implemented analytically. Data from different sources, such as IOT sensor data, electronic health records, sequencing data for multi-omics analysis, and other large data sets, has to be combined cautiously and with robust expert standards in place.
From biostatistics, bioinformatics, data science, CAS, and epidemiology for public heath or post-market modelling; a bespoke team of integrated data and analytics specialists is now as important to a product development project as the product itself to gaining competitiveness and therefore success in the marketplace. Such a team should be applying a combination of established data collection methodologies eg. clinical trials and systematic review, and innovative methods such as machine learning models that draw upon a variety of real world data sources to find a balance between advancing important innovation and mitigating risk.
The following article investigates several systematic reviews into sex and gender representation in individual clinical trial patient populations. In these studies sex ratios are assessed and evaluated by various factors such as clinical trial phase, disease type under investigation and disease burden in the population. Sex differences in the reporting of safety and efficacy outcomes are also investigated. In many cases safety and efficacy outcomes are pooled, rather than reported individually for each sex, which can be problematic when findings are generalised to the wider population. In order to get the dosage right for different body compositions and avoid unforeseen outcomes in off label use or when a novel therapeutic first reaches the market, it is important to report sex differences in clinical trials. Due to the unique nuances of disease types and clinical trial phases it is important to realise that a 50-50 ratio of male to female is not always the ideal or even appropriate in every clinical study design. Having the right sex balance in your clinical trial population will improve the efficiency and cost-effectiveness of your study. Based upon the collective findings a set of principles are put forth to guide the researcher in determining the appropriate sex ratio for their clinical trial design.
Sex difference by clinical trial phase
variation in sex enrolment ratios for clinical trial phases
females less likely to participate in early phases, due to increased risk of adverse events
under-representation of women in phase III when looking at disease prevalence
It has been argued that female representation in clinical trials is lacking, despite recent efforts to mitigate the gap. US data from 2000-2020 suggests that trial phase has the greatest variation in enrolment when compared to other factors, with median female enrolment being 42.9%, 44.8%, 51.7%, and 51.1% for phases I, I/II to II, II/III to III, and IV4. This shows that median female enrolment gradually increases as trials progress, with the difference in female enrolment between the final phases II/III to III and IV being <1%. Additional US data on FDA approved drugs including trials from as early as 1993 report that female participation in clinical trials is 22%, 48%, and 49% for trial phases I, II, and III respectively2. While the numbers for participating sexes are almost equal in phases II and III, women make up only approximately one fifth of phase I trial populations in this dataset2. The difference in reported participation for phase I trials between the datasets could be due to an increase in female participation in more recent years. The aim of a phase I trial is to evaluate safety and dosage, so it comes as no surprise that women, especially those of childbearing age, are often excluded due to potential risks posed to foetal development.
In theory, women can be included to a greater extent as trial phases progress and the potential risk of severe adverse events decreases. By the time a trial reaches phase III, it should ideally reflect the real-world disease population as much as possible. European data for phase III trials from 2011-2015 report 41% of participants being female1, which is slightly lower than female enrolment in US based trials. 26% of FDA approved drugs have a >20% difference between the proportion of women in phase II & III clinical trials and the prevalence of women in the US with the disease2, and only one of these drugs shows an over-representation of women.
Reporting of safety and efficacy by sex difference
Both safety and efficacy results tend to differ by sex.
Reporting these differences is inconsistent and often absent
Higher rates of adverse events in women are possibly caused by less involvement or non stratification in dose finding and safety studies.
There is a need to enforce analysis and reporting of sex differences in safety and efficacy data
Sex differences in response to treatment regarding both efficacy and safety have been widely reported. Gender subgroup analyses regarding efficacy can reveal whether a drug is more or less effective in one sex than the other. Gender subgroup analyses for efficacy are available for 71% of FDA approved drugs, and of these 11% were found to be more efficacious in men and 7% in women2. Alternatively, only 2 of 22 European Medicines Agency approved drugs examined were found to have efficacy differences between the sexes1. Nonetheless, it is important to study the efficacy of a new drug on all potential population subgroups that may end up taking that drug.
The safety of a treatment also differs between the sexes, with women having a slightly higher percentage (p<0.001) of reported adverse events (AE) than men for both treatment and placebo groups in clinical trials1. Gender subgroup analyses regarding safety can offer insights into the potential risks that women are subjected to during treatment. Despite this, gender specific safety analyses are available for only 45% of FDA approved drugs, with 53% of these reporting more side effects in women2. On average, women are at a 34% increased risk of severe toxicity for each cancer treatment domain, with the greatest increased risk being for immunotherapy (66%). Moreover, the risk of AE is greater in women across all AE types, including patient-reported symptomatic (female 33.3%, male 27.9%), haematologic (female 45.2%, male 39.1%) and objective non-haematologic (female 30.9%, male 29.0%)3. These findings highlight the importance of gender specific safety analyses and the fact that more gender subgroup safety reporting is needed. More reporting will increase our understanding of sex-related AE and could potentially allow for sex-specific interventions in the future.
Sex differences by disease type and burden
Several disease categories have recently been associated with lower female enrolment
Men are under-represented as often as women when comparing enrolment to disease burden proportions
There is a need for trial participants to be recruited on a case-by-case basis, depending on the disease.
Sex differences by disease type
When broken down by disease type, the sex ratio of clinical trial participation shows a more nuanced picture. Several disease categories have recently been associated with lower female enrolment, compared to other factors including trial phase, funding, blinding, etc4. Women comprised the smallest proportions of participants in US-based trials between 2000-2020 for cardiology (41.4%), sex-non-specific nephrology and genitourinary (41.7%), and haematology (41.7%) clinical trials4. Despite women being
proportionately represented in European phase III clinical studies between 2011-2015 for depression, epilepsy, thrombosis, and diabetes, they were significantly under-represented for hepatitis C, HIV, schizophrenia, hypercholesterolaemia, and heart failure and were not found to be overrepresented in trials for any of the disease categories examined1. This shows that the gap in gender representation exists even in later clinical trial phases when surveying disease prevalence, albeit to a lesser extent. Examining disease burden shows that the gap is even bigger than anticipated and includes the under-representation of both sexes.
Sex Differences by Disease Burden
It is not until the burden of disease is considered that men are shown to be under-represented as often as women. Including burden of disease can depict proportionality relative to the variety of disease manifestations between men and women. It can be measured as disability-adjusted life years (DALYs), which represent the number of healthy years of life lost due to the disease. Despite the sexes each making up approximately half of clinical trial participants overall in US-based trials between 2000-2020, all disease categories showed an under-representation of either women or men relative to disease burden, except for infectious disease and dermatologic clinical trials4. Women were under-represented in 7 of 17 disease categories, with the greatest under-representation being in oncology trials, where the difference between the number of female trial participants and corresponding DALYs is 3.6%. Men were under-represented compared with their disease burden in 8 of 17 disease categories, with the greatest difference being 11.3% for musculoskeletal disease and trauma trials.4 Men were found to be under-represented to a similar extent to women, suggesting that the under-representation of either sex could be by coincidence. Alternatively, male under-representation could potentially be due to the assumption of female under-representation leading to overcorrection in the opposite direction. It should be noted that these findings would benefit from statistical validation, although they illustrate the need for clinical trial participants to be recruited on a case-by-case basis, depending on the disease.
Takeaways to improve your patient sample in clinical trial recruiting:
Know the disease burden/DALYs of your demographics for that disease.
Try to balance the ratio of disease burden to the appropriate demographics for your disease
Aim to recruit patients based on these proportions
Stratify clinical trial data by the relevant demographics in your analysis. For example: toxicity, efficacy, adverse events etc should always be analyses separately for male and female to come up wit the respective estimates.
Efficacy /toxicity etc should always be reported separately for male and female. reporting difference by ethnicity is also important as many diseases differentially affect certain ethnicity and the corresponding therapeutics can show differing degrees of efficacy and adverse events.
The end goal of these is that medication can be more personalised and any treatment given is more likely to help and less likely to harm the individual patient.
Conclusions
There is room for improvement in the proportional representation of both sexes in clinical trials and knowing a disease demographic is vital to planning a representative trial. Assuming the under-representation is on the side of female rather than male may lead to incorrect conclusions and actions to redress the balance. Taking demographic differences in disease burden into account when recruiting trial participants is needed. Trial populations that more accurately depict the real-world populations will allow a therapeutic to be tailored to the patient.
Efficacy and safety findings highlight the need for clinical study data to be stratified by sex, so that respective estimates can be determined. This enables more accurate, sex/age appropriate dosing that will maximise treatment efficacy and patient safety, as well as minimise the chance of adverse events. This also reduces the risks associated with later off label use of drugs and may avoid modern day tragedies resembling the thalidomide tragedy. Moreover, efficacy and adverse events should always be reported separately for men and women, as the evidence shows their distinct differences in response to therapeutics.
1. Dekker M, de Vries S, Versantvoort C, Drost-van Velze E, Bhatt M, van Meer P et al. Sex Proportionality in Pre-clinical and Clinical Trials: An Evaluation of 22 Marketing Authorization Application Dossiers Submitted to the European Medicines Agency. Frontiers in Medicine. 2021;8.
2. Labots G, Jones A, de Visser S, Rissmann R, Burggraaf J. Gender differences in clinical registration trials: is there a real problem?. British Journal of Clinical Pharmacology. 2018;84(4):700-707.
3. Unger J, Vaidya R, Albain K, LeBlanc M, Minasian L, Gotay C et al. Sex Differences in Risk of Severe Adverse Events in Patients Receiving Immunotherapy, Targeted Therapy, or Chemotherapy in Cancer Clinical Trials. Journal of Clinical Oncology. 2022;40(13):1474-1486.
4. Steinberg J, Turner B, Weeks B, Magnani C, Wong B, Rodriguez F et al. Analysis of Female Enrollment and Participant Sex by Burden of Disease in US Clinical Trials Between 2000 and 2020. JAMA Network Open. 2021;4(6):e2113749.
Data sources for cost analysis of drug development R&D and clinical trials
Cost estimates for pre-clinical and clinical development across the pharmaceutical industry differ based on several factors. One of these is the source of data used by each costing study to inform these estimates. Several studies use private data, which can include confidential surveys filled out by pharmaceutical firms/clinical trial units and random samples from private databases3,9,10,14,15,16. Other studies have based their cost estimates upon publicly available data, such as data from the FDA/national drug regulatory agencies, published peer-reviewed studies, and other online public databases1,2,12,13,17.
Some have questioned the validity of using private surveys from large multinational pharmaceutical companies to inform cost estimates, saying that survey data may be artificially inflated by pharmaceutical companies to justify high therapeutic prices 18,19,20. Another concern is that per trial spending by larger pharmaceutical companies and multinational firms would far exceed the spending of start-ups and smaller firms, meaning cost estimates made based on data from these larger companies would not be representative of smaller firms.
Failure rate of R&D and clinical trial pipelines
Many estimates include the cost of failures, which is especially the case for cost estimates “per approved drug”. As many compounds enter the clinical trial pipeline, the cost to develop one approved drug/compound includes cost of failures by considering the clinical trial success rate and cost of failed compounds. For example, if 100 compounds enter phase I trials, and 2 compounds are approved, the clinical cost per approved drug would include the amount spent on 50 compounds.
The rate of success used can massively impact cost estimates, where a low success rate or high failure rate will lead to much higher costs per approved drug. The overall probability of clinical success may vary by year and has been estimated at a range of values including 7.9%21, 11.83%10, and 13.8%22. There are concerns that some studies suggesting lower success rates have relied on small samples from industry curated databases and are thereby vulnerable to selection bias12,22.
Success rates per phase transition also affects overall costs. When more ultimately unsuccessful compounds enter late clinical trial stages, the higher the costs are per approved compound. In addition, success rates are also dependent on therapeutic area and patient stratification by biomarkers, among other factors. For example, one study estimated the lowest success rate at 1.6% for oncological trials without biomarker use compared with a peak success rate of 85.7% for cardiovascular trials utilising biomarkers22. While aggregate success rates can be used to estimate costs, using specific success rates will be more accurate to estimate the cost of a specific upcoming trial, which could help with budgeting and funding decisions.
Out-of-pocket costs vs capitalised costs & interest rates
Cost estimates also differ due to reporting of out-of-pocket and capitalised costs. An out-of-pocket cost refers to the amount of money spent or expensed on the R&D of a therapeutic. This can include all aspects of setting up therapeutic development, from initial funding in drug discovery/device design, to staff and site costs during clinical trials, and regulatory approval expenses.
The capitalised cost of a new therapeutic refers to the addition of out-of-pocket costs to a yearly interest rate applied to the financial investments funding the development of a new drug. This interest rate, referred to as the discount rate, is determined by (and is typically greater than) the cost of capital for the relevant industry.
Discount rates for the pharmaceutical industry vary between sources and can dramatically alter estimates for capitalised cost, where a higher discount rate will increase capitalised cost. Most studies place the private cost of capital for the pharmaceutical industry to be 8% or higher23,24, while the cost of capital for government is lower at around 3% to 7% for developed countries23,25. Other sources have suggested rates from as high as 13% to as low as zero13,23,26, where the zero cost of capital has been justified by the idea that pharmaceutical firms have no choice but to invest in R&D. However, the mathematical model used in many estimations for the cost of industry capital, the CAPM model, tends to give more conservative estimates23. This would mean the 10.5% discount rate widely used in capitalised cost estimates may in fact result in underestimation.
While there is not a consensus on what discount rate to use, capitalised costs do represent the risks undertaken by research firms and investors. A good approach may be to present both out-of-pocket and capitalised estimated costs, in addition to rates used, justification for the rate used, and the estimates using alternative rates in a sensitivity analysis26.
Costs variation over time
The increase in therapeutic development costs
Generally, there has been a significant increase in the estimated costs to develop a new therapeutic over time26. One study reported an exponential increase of capitalised costs from the 1970s to the mid-2010s, where the total capitalised costs rose annually 8.5% above general inflation from 1990 to 201310. Recent data has suggested that average development costs reached a peak in 2019 and had decreased the following two years9. This recent decrease in costs was associated with slightly reduced cycle times and an increased proportion of infectious disease research, likely in response to the rapid response needed for COVID-19.
Recent cost estimates
Costs can range with more than 100-fold differences for phase III/pivotal trials alone1. One of the more widely cited studies on drug costs used confidential survey data from ten multinational pharmaceutical firms and a random sample from a database of publicly available data10. In 2013, this study estimated the total pre-approval cost at $2.6 billion USD per approved new compound. This was a capitalised cost, and the addition of post-approval R&D costs increased this estimate to $2.87 billion (2013 USD). The out-of-pocket cost per approved new compound was reported at $1.395 billion, of which $965 million were clinical costs and the remaining $430 million were pre-clinical.
Another estimate reported the average cost to develop an asset at $1.296 billion in 20139. Furthermore, it reported that this cost had increased until 2019 at $2.431 billion and had since decreased to $2.376 billion in 2020 and $2.006 billion in 2021. While comparable to the previous out-of-pocket estimate for 2013, this study does not state whether their estimates are out-of-pocket or capitalised, making it difficult to meaningfully compare these estimates.
Figure 1: Recent cost estimates for drug development per approved new compound. “Clinical only” costs include only the costs of phase 0-III clinical trials, while “full” costs include pre-clinical costs. The colour of each bubble indicates the study, while bubble size indicated relative cost. A dashed border indicated the study used private data for their estimations, while a solid border indicates the study utilised publicly available data. Figure represents studies 9, 10, 12, 13 and 17 from the reference list in this report.
Publicly available data of 63 FDA-approved new biologics from 2009-2018 was used to estimate the capitalised (at 10.5%) R&D investment to bring a new drug to market at median of $985.3 million and a mean of $1.3359 billion (inflation adjusted to 2018 USD)12. These data were mostly accessible from smaller firms, smaller trials, first-in-class drugs, and further specific areas. The variation in estimated cost was, through sensitivity analysis, mostly explained by success/failure rates, preclinical expenditures, and cost of capital.
Publicly available data of 10 companies with no other drugs on the market in 2017 was used to estimate out-of-pocket costs for the development of a single cancer drug. This was reported at a median of $648 million and a mean of $719.8 million13. Capitalised costs were also reported using a 7% discount rate, with a median of $754.4 million and mean of $969.4 million. By focusing on data from companies without other drugs on the market, these estimates may better represent the development costs per new molecular entity (NME) for start-ups as the cost of failure of other drugs in the pipeline were included while any costs related to supporting existing on-market drugs were systematically impossible to include.
One study estimated the clinical costs per approved non-orphan drug at $291 million (out-of-pocket) and $412 million (capitalised 10.5%)17. The capitalised cost estimate increased to $489 million when only considering non-orphan NMEs. The difference between these estimates for clinical costs and the previously mentioned estimates for total development costs puts into perspective the amount
spent on pre-clinical trials and early drug development, with one studynoting their pre-clinical estimates comprised 32% of out-of-pocket and 42% of capitalised costs10.
Things to consider about cost estimates
The issue with these estimates is that there are so many differing factors affecting each study. This complicates cost-based pricing discussions, especially when R&D cost estimates can differ orders of magnitude apart. The methodologies used to calculate out-of-pocket costs differ between studies9,17, and the use of differing data sources (public data vs confidential surveys) seem to impact these estimates considerably.
There is also an issue with the transparency of data and methods from various sources in cost estimates. Some of this is a result of using confidential data, where some analyses are not available for public scrutiny8. This study in particular raised questions as estimates were stated without any information about the methodology or data used in the calculation of estimates. The use of confidential surveys of larger companies has also been criticised as the confidential data voluntarily submitted would have been submitted anonymously without independent verification12.
Due to the limited amount of comprehensive and published cost data17, many estimates have no option but to rely on using a limited data set and making some assumptions to arrive at a reasonable estimate. This includes a lack of transparent available data for randomised control trials, where one study reported that only 18% of FDA-approved drugs had publicly available cost data18. Therefore, there is a need for transparent and replicable data in this field to allow for more plausible cost estimates to be made, which in turn could be used to support budget planning and help trial sustainability18,26.
Despite the issues between studies, the findings within each study can be used to gather an idea of trends, cost drivers, and costs specific to company/drug types. For example, studies suggest an increasing overall cost of drug development from 1970 to peak in 201910, with a subsequent decrease in 2020 and 20219.
Data evaluating the costs associated with developing novel therapeutics within the pharmaceutical industry can be used to identify trends over time and can inform more accurate budgeting for future research projects. However, the cost to develop a drug therapeutic is difficult to accurately evaluate, resulting in varying estimates ranging from hundreds of millions to billions of US dollars between studies. The high cost of drug development is not purely because of clinical trial expenses. Drug discovery, pre-clinical trials, and commercialisation also need to be factored into estimates of drug development costs.
There are limitations in trying to accurately assess these costs. The sheer number of factors that affect estimated and real costs means that studies often take a more specific approach. For example, costs will differ between large multinational companies with multiple candidates in their pipeline and start-ups/SMEs developing their first pharmaceutical. Due to the amount and quality of available data, many studies work mostly with data from larger multinational pharmaceutical companies with multiple molecules in the pipeline. When taken out of context, the “$2.6 billion USD cost for getting a single drug to market” can seem daunting for SMEs. It is very important to clarify what scale these cost estimates represent, but cost data from large pharma companies are still relevant for SMEs as they can used to infer costs for different scales of therapeutic development.
This mini-report includes what drives clinical trial costs, methods to reduce these costs, and then explores what can be learned from varying cost estimates.
What drives clinical trial costs?
There is an ongoing effort to streamline the clinical trial process to be more cost and time efficient. Several studies report on cost drivers of clinical trials, which should be considered when designing and budgeting a trial. Some of these drivers are described below:
Study size
Trial costs rise exponentially with an increasing study size, which some studies have found to be the single largest driver in trial costs1,2,3. There are several reasons for varying sample sizes between trials. For example, study size increases with trial phase progression as phases require different study sizes based on the number of patients needed to establish the safety and/or effectiveness of a treatment. Failure to recruit sufficient patients can result in trial delays which also increases costs4.
Trial site visits
A large study size is also correlated with a larger overall number of patient visits during a trial, which is associated with a significant increase in total trial costs2,3. Trial clinic visits are necessary for patient screening, treatment and treatment assessment but include significant costs for staff, site hosting, equipment, treatment, and in some cases reimbursement for patient travel costs. The number of trial site visits per patient varies between trials where more visits may indicate longer and/or more intense treatment sessions. One estimate for the number of trial visits per person was a median of 11 in a phase III trial, with $2 million added to estimated trial costs for every +1 to the median2.
Number & location of clinical trial sites
A higher number of clinical trial study sites has been associated with significant increase in total trial cost3. This is a result of increased site costs, as well as associated staffing and equipment costs. These will vary with the size of each site, where larger trials with more patients often use more sites or larger sites.
Due to the lower cost and shorter timelines of overseas clinical research5,6, there has been a shift to the globalisation of trials, with only 43% of study sites in US FDA-approved pivotal trials being in North America7. In fact, 71% of these trials had sites in lower cost regions where median regional costs were 49%-97% of site costs in North America. Most patients in these trials were either in North America (39.7%), Western Europe (21%), or Central Europe (20.4%).
Median cost per regional site as a percentage of North American median cost for comparison.
However, trials can face increased difficulties in managing and coordinating multiple sites across different regions, with concerns of adherence to the ethical and scientific regulations of the trial centre’s region5,6. Some studies have reported that multiregional trials are associated with a significant increase in total trial costs, especially those with sites in emerging markets3. It is unclear if this reported increase is a result of lower site efficiency, multiregional management costs, or outsourcing being more common among larger trials.
Clinical Trial duration
Longer trial duration has been associated with a significant increase in total trial costs3,4, where many studies have estimated the clinical period between 6-8 years8,9,10,11,12,13. Longer trials are sometimes necessary, such as in evaluating the safety and efficacy of long-term drug use in the management of chronic and degenerative disease. Otherwise, delays to starting up a trial contribute to longer trials, where delays can consume budget and diminish the relevance of research4. Such delays may occur as a result of site complications or poor patient accrual.
Another aspect to consider is that the longer it takes to get a therapeutic to market (as impacted by longer trials), the longer the wait is before a return of investment is seen by both the research organisation and investors. The period from development to on-market, often referred to as cycle time, can drive costs per therapeutic as interest based on the industry’s cost of capital can be applied to investments.
Therapeutic area under investigation
The cost to develop a therapeutic is also dependent on the therapeutic area, where some areas such as oncology and cardiovascular treatments are more cost intensive compared with others1,2,5,6,12,14. This is in part due to variation in treatment intensity, from low intensity treatments such as skin creams to high intensity treatments such as multiple infusions of high-cost anti-cancer drugs2. An estimate for the highest mean cost for pivotal trials per therapeutic area was $157.2M in cardiovascular trials compared to $45.4M in oncology, and a lowest of $20.8M in endocrine, metabolic, and respiratory disease trials1. This was compared to an overall median of $19M. Clinical
trial costs per therapeutic area also varied by clinical trial phase. For example, trials in pain and anaesthesia have been found to have the lowest average cost of a phase I study while having the highest average cost of a phase III study6.
It is important to note that some therapeutic areas will have far lower per patient costs when compared to others and are not always indicative of total trial costs. For example, infectious disease trials generally have larger sample sizes which will lead to relatively low per patient costs, whereas trials for rare disease treatment are often limited to smaller sample sizes with relatively high per patient costs. Despite this, trials for rare disease are estimated to have significantly lower drug to market costs.
Drug type being evaluated
As mentioned in the therapeutic areas section above, treatments may vary in intensity from skin creams to multiple rounds of treatment with several anti-cancer drugs. This can drive total trial costs due to additional manufacturing and the need for specially trained staff to administer treatments.
In the case of vaccine development, phase III/pivotal trials for vaccine efficacy can be very difficult to run unless there are ongoing epidemics for the targeted infectious disease. Therefore, some cost estimates of vaccine development include from the pre-clinical stages to the end of phase IIa, with the average cost for one approved vaccine estimated at $319-469 million USD in 201815.
Study design & trial control type used
Phase III trial costs vary based on the type of control group used in the trial1. Uncontrolled trials were the least expensive with an estimated mean of $13.5 million per trial. Placebo controlled trials had an estimated mean of $28.8 million, and trials with active drug comparators had an estimated mean cost of $48.9 million. This dramatic increase in costs is in part due to manufacturing and staffing to administer a placebo or active drug. In addition, drug-controlled trials require more patients compared to placebo-controlled, which also requires more patients than uncontrolled trials2.
Reducing therapeutic development costs
Development costs can be reduced through several approaches. Many articles recommend improvements to operational efficiency and accrual, as well as deploying standardised trial management metrics4. This could include streamlining trial administration, hiring experienced trial staff, and ensuring ample patient recruitment to reduce delays in starting and carrying out a study.
Another way to reduce development costs can take place in the thorough planning of clinical trial design by a biostatistician, whether in-house or external. Statistics consulting throughout a trial can help to determine suitable early stopping conditions and the most appropriate sample size. Sample size calculation is particularly important as underestimation undermines experimental results, whereas overestimation leads to unnecessary costs. Statisticians can also be useful during the pre-clinical stage to audit R&D data to select the best available candidates, ensure accurate R&D data analysis, and avoid pursuing unsuccessful compounds.
Other ways to reduce development costs include the use of personalised medicine, clinical trial digitisation, and the integration of AI. Clinical trial digitisation would lead to the streamlining of clinical trial administration and would also allow for the integration of artificial intelligence into clinical trials. There have been many promising applications for AI in clinical trials, including the use of electronic health records to enhance the enrolment and monitoring of patients, and the potential use of AI in trial diagnostics. More information about this topic can be found in our blog “Emerging use-cases for AI in clinical trials”.
Cost breakdown in more detail: How is a clinical trial budget spent?
Clinical trial costs can be broken down and divided into several categories, such as staff and non-staff costs. In a sample of phase III studies, personnel costs were found to be the single largest component of trial costs, consisting of 37% of the total, whereas outsourcing costs made up 22%, grants and contracting costs at 21%, and other expenses at 21%3.
From a CRO’s perspective, there are many factors that are considered in the cost of a pivotal trial quotation, including regulatory affairs, site costs, management costs, the cost of statistics and medical writing, and pass-through costs27. Another analysis of clinical trial cost factors determined clinical procedure costs made up 15-22% of the total budget, with administrative staff costs at 11-29%, site monitoring costs at 9-14%, site retention costs at 9-16%, and central laboratory costs at 4-12%5,6. In a study of multinational trials, 66% of total estimated trial costs were spent on regional tasks, of which 53.3% was used in trial sites and the remainder on other management7.
Therapeutic areas and shifting trends
Therapeutic area had previously been mentioned as a cost driver of trials due to differences in sample sizes and/or treatment intensity. It is however worth mentioning that, in 2013, the largest number of US industry-sponsored clinical trials were in oncology (2,560/6,199 active clinical trials with 215,176/1,148,340 patients enrolled)4,14. More recently, there has been a shift to infectious disease trials, in part due to the needed COVID-19 trials9.
Clinical trial phases
Due to the expanding sample size as a trial progresses, average costs per phase increase from phase I through III. Median costs per phase were estimated in 2016 at $3.4 million for phase I, $8.6 million for phase II, and $21.4 million for phase III3. Estimations of costs per patient were similarly most expensive in phase III at $42,000, followed by phase II at $40,000 and phase I at $38,50014. The combination of an increasing sample size and increasing per patient costs per phase leads to the drastic increase in phase costs with trial progression.
In addition, studies may have multiple phase III trials, meaning the median estimated cost of phase III trials per approved drug is higher than per trial costs ($48 million and $19 million respectively)2. Multiple phase III trials can be used to better support marketing approval or can be used for therapeutics which seek approval for combination/adjuvant therapy.
There are fewer cost data analyses available on phase 0 and phase IV on clinical trials. Others report that average Phase IV costs are equivalent to Phase III but much more variable5,6.
Orphan drugs
Drugs developed for the treatment of rare diseases are often referred to as orphan drugs. Orphan drugs have been estimated to have lower clinical costs per approved drug, where capitalised costs per non-orphan and orphan drugs were $412 million and $291 million respectively17. This is in part due to the limit to sample size imposed upon orphan drug trials by the rarity of the target disease and the higher success rate for each compound. However, orphan drug trials are often longer when compared to non-orphan drug trials, with an average study duration of 1417 days and 774 days respectively.
NMEs
New molecular entities (NMEs) are drugs which do not contain any previously approved active molecules. Both clinical and total costs of NMEs are estimated to be higher when compared to next in class drugs13,17. NMEs are thought to be more expensive to develop due to the increased amount of pre-clinical research to determine the activity of a new molecule and the increased intensity of clinical research to prove safety/efficacy and reach approval.
Conclusion & take-aways
There is no one answer to the cost of drug or device development, as it varies considerably by several cost drivers including study size, therapeutic area, and trial duration. Estimates of total drug development costs per approved new compound have ranged from $754 million12 to $2.6 billion10 USD over the past 10 years. These estimates do not only differ based on the data used, but also due to methodological differences between studies. The limited availability of comprehensive cost data for approved drugs also means that many studies rely on limited data sets and must make assumptions to arrive at a reasonable estimate.
There are still multiple practical ways that can be used to reduce study costs, including expert trial design planning by statisticians, implementation of biomarker-guided trials to reduce the risk of failure, AI integration and digitisation of trials, improving operational efficiency, improving accrual, and introducing standardised trial management metrics.
References
Moore T, Zhang H, Anderson G, Alexander G. Estimated Costs of Pivotal Trials for Novel Therapeutic Agents Approved by the US Food and Drug Administration, 2015-2016. JAMA Internal Medicine. 2018;178(11):1451-1457.
.1 Moore T, Zhang H, Anderson G, Alexander G. Estimated Costs of Pivotal Trials for Novel Therapeutic Agents Approved by the US Food and Drug Administration, 2015-2016. JAMA Internal Medicine. 2018;178(11):1451-1457.
2. Moore T, Heyward J, Anderson G, Alexander G. Variation in the estimated costs of pivotal clinical benefit trials supporting the US approval of new therapeutic agents, 2015–2017: a cross-sectional study. BMJ Open. 2020;10(6):e038863.
3. Martin L, Hutchens M, Hawkins C, Radnov A. How much do clinical trials cost?. Nature Reviews Drug Discovery. 2017;16(6):381-382.
4. Bentley C, Cressman S, van der Hoek K, Arts K, Dancey J, Peacock S. Conducting clinical trials—costs, impacts, and the value of clinical trials networks: A scoping review. Clinical Trials. 2019;16(2):183-193.
6. Sertkaya A, Wong H, Jessup A, Beleche T. Key cost drivers of pharmaceutical clinical trials in the United States. Clinical Trials. 2016;13(2):117-126.
7. Qiao Y, Alexander G, Moore T. Globalization of clinical trials: Variation in estimated regional costs of pivotal trials, 2015–2016. Clinical Trials. 2019;16(3):329-333.
10. DiMasi J, Grabowski H, Hansen R. Innovation in the pharmaceutical industry: New estimates of R&D costs. Journal of Health Economics. 2016;47:20-33.
11. Farid S, Baron M, Stamatis C, Nie W, Coffman J. Benchmarking biopharmaceutical process development and manufacturing cost contributions to R&D. mAbs. 2020;12(1):e1754999.
12. Wouters O, McKee M, Luyten J. Estimated Research and Development Investment Needed to Bring a New Medicine to Market, 2009-2018. JAMA. 2020;323(9):844-853.
13. Prasad V, Mailankody S. Research and Development Spending to Bring a Single Cancer Drug to Market and Revenues After Approval. JAMA Internal Medicine. 2017;177(11):1569-1575.
15. Gouglas D, Thanh Le T, Henderson K, Kaloudis A, Danielsen T, Hammersland N et al. Estimating the cost of vaccine development against epidemic infectious diseases: a cost minimisation study. The Lancet Global Health. 2018;6(12):e1386-e1396. 16. Hind D, Reeves B, Bathers S, Bray C, Corkhill A, Hayward C et al. Comparative costs and activity from a sample of UK clinical trials units. Trials. 2017;18(1).
17.Jayasundara K, Hollis A, Krahn M, Mamdani M, Hoch J, Grootendorst P. Estimating the clinical cost of drug development for orphan versus non-orphan drugs. Orphanet Journal of Rare Diseases. 2019;14(1).
19. Speich B, von Niederhäusern B, Schur N, Hemkens L, Fürst T, Bhatnagar N et al. Systematic review on costs and resource use of randomized clinical trials shows a lack of transparent and comprehensive data. Journal of Clinical Epidemiology. 2018;96:1-11.
20. Light D, Warburton R. Demythologizing the high costs of pharmaceutical research. BioSocieties. 2011;6(1):34-50.
21. Adams C, Brantner V. Estimating The Cost Of New Drug Development: Is It Really $802 Million?. Health Affairs. 2006;25(2):420-428.
23. Wong C, Siah K, Lo A. Estimation of clinical trial success rates and related parameters. Biostatistics. 2019;20(2):273-286. 24. Chit A, Chit A, Papadimitropoulos M, Krahn M, Parker J, Grootendorst P. The Opportunity Cost of Capital: Development of New Pharmaceuticals. INQUIRY: The Journal of Health Care Organization, Provision, and Financing. 2015;52:1-5. 25. Harrington, S.E. Cost of Capital for Pharmaceutical, Biotechnology, and Medical Device Firms. In Danzon, P.M. & Nicholson, S. (Eds.), The Oxford Handbook of the Economics of the Biopharmaceutical Industry, (pp. 75-99). New York: Oxford University Press. 2012. 26. Zhuang J, Liang Z, Lin T, De Guzman F. Theory and Practice in the Choice of Social Discount Rate for Cost-Benefit Analysis: A Survey [Internet]. Manila, Philippines: Asian Development Bank; 2007. Available from: https://www.adb.org/sites/default/files/publication/28360/wp094.pdf 27. Rennane S, Baker L, Mulcahy A. Estimating the Cost of Industry Investment in Drug Research and Development: A Review of Methods and Results. INQUIRY: The Journal of Health Care Organization, Provision, and Financing. 2021;58:1-11. 28. Ledesma P. How Much Does a Clinical Trial Cost? [Internet]. Sofpromed. 2020 [cited 26 June 2022]. Available from: https://www.sofpromed.com/how-much-does-a-clinical-trial-cost
Overview of medical device categorisations and classifications for regulatory purposes in the United Kingdom
Summary of medical devices categorisations based on type, usage and risk potential during use as specified in the MDR and IVDR.
The class of medical device and its purpose determines the criteria required to meet regulatory approval. All medical devices in the UK must have a UKCA or CE marking depending on the legislation the device has been certified under.
Explanation of risk classifications for general medical devices and active implantable devices
Explanation of risk classifications for in vitro diagnostics
In the UK and EU medical devices are regulated under the Medical Devices Regulation (MDR) or In Vitro Diagnostics Regulation (IVDR) depending upon which category they fall under. In the UK it is the Medicines and Healthcare Products Regulatory Agency (MHRA) that is responsible for new product approval and market surveillance activities related to medical devices and other therapeutics, such as pharmaceuticals, intended for use in patients within the UK. The equivalent regulatory agency in the EU is the European Regulatory Agency (EMA). The MHRA also manages the Early Access to Medicines Scheme (EAMS) to enable patients access to pre-market therapeutics that are yet to receive regulatory approval where their medical needs are currently unmet by existing options. To qualify for EAMS a medicine must be designated as a Promising Innovative Medicine (PIM) based on early clinical data.
Having a thorough understanding of the classification and class of your medical device is vital for it to undergo the appropriate assessment route and be approved and ready for market. While the scope of medical devices is incredibly broad, for regulatory purposes they tend to be classified based on device type, duration of use and level of risk. Which risk class a device falls into will be determined in a large part by device type and duration of use, as both of these factors influence the level of risk to the patient. All medical devices in the UK must be designated a category and a risk classification in order to undertake the regulatory approval process.
Category (type) of Medical Device
The MHRA categorises medical devices into the following 5 categories:
Non-invasive – Devices which do not enter the body
Invasive – Devices which in whole or part are inserted into the body’s orifices (including the external eyeball surface) or through the surface or the body such as the skin.
Surgically invasive – Devices used or inserted surgically that penetrate the body through the surface of the body, such as through the skin.
Active – Devices requiring an external source of power, including stand-alone software.
Implantable – Devices intended to be totally or partially introduced into the human body (including to replace an epithelial surface or the surface of the eye) by surgical intervention and to remain in place for a period of time.
Duration of use category
Medical devices are then further categorised based upon their intended duration of use under normal circumstances.
Transient – intended for less than 60 minutes of continuous use.
Short term – intended for between 60 minutes to 30 days of continuous use.
Long term – intended for more than 30 days continuous use.
Further to these use, duration and risk categories the HPRA designates 3 additional categories for the purposes of UKCA Mark and conformity assessment. These categories for the are:
General medical devices – most medical devices fall into this category.
Active implantable devices – devices powered by implants or partial implants intended to remain in the human body after a procedure.
In vitro diagnostics medical devices (IVDs) – equipment or system used in vitro to examine specimens from the human body.
UKCA mark and conformity assessment and subsequent labelling is a crucial procedure for a device to enter the UK market for use by patients. It should be noted that the UKCA mark is not recognised in the EU or Northern Ireland, who instead recognise the CE mark. Great Britain will not recognise the CE mark after 30 June 2023, thus it will be important to have both the UKCA and CE mark for widespread distribution of a medical device. These incompatibilities seem to have arisen largely as a result of Brexit.
Risk classification categories for general medical devices and active implantable devices
In The UK and EU there are 4 official risk-related classes for medical devices. These classes apply to both general medical devices and active implantable devices. As noted previously, the class a device falls into is largely informed by the category and the intended duration of use for the device.
Class I , which includes the subclasses Class Is (sterile no measuring function), Class Im (measuring function), and Class Ir (devices to be reprocessed or reused). Low risk of illness/injury resulting from use. Only self-assessment required to meet regulatory approval.
Class IIa Low to medium risk of illness/injury resulting from use. Notified Body approval required.
Class IIb Medium to high risk of illness/injury resulting from use. Notified Body approval required.
Class III high potential risk of illness/injury resulting from use. Notified Body approval required.
More details on these classes can be found below.
In Vitro Diagnostic Medical Devices (IVDs)
The IVDR categorise IVDs in to the following categories for the purpose of obtaining regulatory approval in Great Britain. IVDs do not harm patients directly in the same way that other medical devices can and are thus subject to different risk assessment.
General IVD medical devices
IVDs for self-testing – intended to be using by an individual at home.
IVDs stated in Part IV of the UK MDR 2002, Annex II List B
IVDs stated in Part IV of the UK MDR 2002, Annex II List A
A more detailed explanation of these categories can be found towards the end of this article.
The EU and Northern Ireland has moved away from this list style of classification and has recently implemented the following risk classes. There are 4 IVDR risk classes outlined in Annex VIII. It seems likely that Great Britain may follow this in future.
Risk Classes for IVDs
Class A – Laboratory devices, instruments and receptacles.
Class B – All devices not covered in the other classes.
Class C – High risk devices presenting a lower direct risk to the patient population. Includes diagnostic devices where failure to accurately diagnose could be life-threatening. Covers companion diagnostics, genetic screening and some self-testing.
Class D – Devices that pose a high direct risk to the patient population, and in some cases the wider population, relating to life threatening conditions, transmissible agents in blood, biological materials for transplantation in to the human body and other similar materials.
Risk categories for general medical devices and active implantable medical devices in detail
Class I devices
These are generally regarded as low risk devices and pose little risk of illness and injury. Such devices have minimal contact with patients and the lowest impact on patient health outcomes. To self-certify your product, you must confirm that it is a class I device1,3. This may involve carrying out clinical evaluations, notifying the Medicines and Healthcare products Regulatory Agency (MHRA) of proposals to perform clinical investigations, preparing technical documentation and drawing up a declaration of conformity1. In cases where the device includes sterile products or measuring functions, approval from a UK Approved Body may still be necessary3. Devices in this category include thermometers, stethoscopes, bandages and surgical masks.
Class IIa & IIb devices
Class IIa devices are generally regarded as medium risk devices and pose moderate risk of illness and injury. Both class IIa and IIb devices must be declared as such by applying to a UK Approved Body and performing a conformity assessment3, 4. For class IIa and IIb devices, there are several assessments. These include examining and testing the product or a homogenous batch of products, auditing the production quality assurance system, auditing the final inspection and testing or auditing the full quality assurance system3. include dental fillings, surgical clamps and tracheotomy tubes4 Class IIb devices include lung ventilators and bone fixation plates4.
Class III devices
These are considered high risk devices and pose substantial risk of illness and injury. Devices in this category are essential for sustaining human life and Due to the high-risk associated with class III devices, they are subject to the strictest regulations. In addition to the class IIa and IIb assessments, class III devices require a design dossier examination3. include pacemakers, ventilators, drug-coated stents and spinal disc cages.
Risk Categories for In Vitro Diagnostics in detail
These include but are not limited to reagents, instruments, software and systems intended for in vitro examination of specimens such as tissue donations and blood4. Most IVDs do not require intervention from a UK Approved Body5. However, for IVDs that are considered essential to health, involvement of a UK Approved Body is necessary5. The specific conformity assessment procedure depends on the category of IVD concerned5.
General IVDs
These are considered a low risk to patients and include clinical chemistry analysers, specimen receptacles and prepared selective culture media4. For general IVDs, involvement from a UK Approved Body is not required5. Instead, relevant provisions in the UK MDR 2002 must be met and self-declared prior to adding a UKCA mark to the device5,6.
IVDs for self-testing
These represent a low-to-medium risk to patients and include pregnancy self-testing, urine test strips and cholesterol self-testing4. In addition to conforming to requirements for general IVDs, applications for IVDs involved in self-testing must be sent to a UK Approved Body5. This enables examination of the design of the device, such as how suitable it is for non-professional users5.
IVDs stated in Part IV of the UK MDR 2002, Annex II List B
These represent medium-to-high risk to patients and include blood glucose self-testing, PSA screening and HLA typing4. Applications for devices in this category must be sent to a UK Approved Body5. This can enable auditing of technical documentation and the quality management system6.
IVDs stated in Part IV of the UK MDR 2002, Annex II List A.
These represent the highest risk to patients and include Hepatitis B blood-donor screening, ABO blood grouping and HIV blood diagnostic tests4. Due to the high risk associated with IVDs in this category, applications for devices in this category must be sent to a UK Approved Body5. By doing so, an audit of the quality management system can be performed as well as a design dossier review6. In addition, the UK Approved Body must verify each product or batch of products prior to being placed on the market5,6.
Proposed updates to medical device categories in the UK
Due to the quickly evolving state of medical technology, many items that did not previously count as a medical device, such as software and AI, are now needing to be considered as such. New proposals have been put forward as potential amendments to the existing regulations and risk classifications to accommodate newer technologies and devices. Among other proposed changes the following list of novel devices has been recommended for upgrade to the classification of highest risk Class III.
Active implantable medical devices and their accessories
in vitro fertilisation (IVF) and Assisted reproduction technologies (ART)
Surgical meshes
total or partial joint replacements
spinal disc replacements and other medical devices that come into contact with the spinal column
medical devices containing nano-materials
medical devices containing substances that will be introduced to the human body by one of various methods of absorption in order to achieve their intended function.
Active therapeutic devices with an integrated diagnostic function determining patient management such as closed loop or automated systems.
With the shift to a higher risk classification will come increased demand of clinical evidence and clinical testing, including clinical trials, in order for these devices to meet regulatory approval and reach the market. While an increased burden for the manufacturer this will be to the benefit patient safety and satisfaction for the end users. A full list of the proposed changes, including those outside of Class III, can be found here: Chapter 2: Classification – GOV.UK (www.gov.uk)
Medical devices are incredibly heterogenous, ranging from therapeutics and surgical tools to diagnostics and medical imaging software including machine learning and AI. Accordingly, medical device research and development often requires an interdisciplinary approach. During R&D, it is important to consider for whom the device is intended, how it will be used, and under what circumstances. Similarly, it is crucial to understand the risk status of the device. By considering these attributes, the device can be successfully assessed through the appropriate regulatory approval pathway.
Collection and transmission of personal biologic and health information via IOmT connected medical devices requires regulatory oversight and has cybersecurity implications.
Connected medical devices (CMDs) can produce and transmitting patient data, allowing their condition to be monitored by healthcare professionals. They are often used in decentralised clinical trials (DCTs) outside of the clinical trial site, allowing for participants who wouldn’t usually be able to attend. CMDs have led to the Internet of Medical things, a connected network of systems and which produce, transmit and analyse patient data.
CMDs and IoMT have countless applications in the healthcare and medical technology (Medtech) industries, however these devices are susceptible to cyber-attacks and data leaks. These attacks include stealing and selling private patient data to third parties, denial of service (DOS) attacks, and altering medical data which can lead to improper diagnoses and treatments.
It has been suggested by multiple authors that CMDs and other wearable activity trackers are prone to cyber-attack is that data security and privacy issues are often not considered during their development (1). Regulations for the development of CMDs in the UK fall under two categories: regulations concerning medical devices in general, and regulations concerning IoMT including data protection and cybersecurity. Medtech companies must follow both types of regulations if they wish to sell CMDs in the UK and abroad. Here we discuss the current regulations for CMDs in the UK, how they may change in response to these security issues, and how this will impact clinical trials and the approval of CMDs.
Current Device Regulations
Regulations for medical devices in the UK need to be updated to better cover the risks associated with CMDs, as many of these devices can enter the UK market with little-to-no regulatory approval especially in terms of data security. Manufacturers currently need only a Conformité Européenne (CE) mark to be sold in the EU (1). With CE marking, devices are classified according to risk from lowest (Class I) to highest (Class III), with class I devices allowed to enter the market without prior data regarding their safety in the US, EU and Japan. Devices placed in class IIb or III must carry out an audit of the whole quality assurance system or undergo an “Annex III” examination which can include examination of each product/batch, audit of the final inspection, or an audit of the production quality assurance system (2). Clinical trials to evaluate the conformity of CMDs to medical device regulations will have at least one of the following aims: (a) to verify that under normal usage, the device achieves the performance intended by the manufacturer, (b) to establish its clinical benefit as specified by the manufacturer, and (c) to establish its clinical safety (3). Many wearable devices e.g. smartwatches and activity trackers can skip regulatory approval as they aren’t currently classed as CMDs, however to be utilised in DCTs, they will need to be approved as medical devices (4).
In the UK and EU, the General Data Protection Regulation (GDPR) covers the use of medical data, as well as the Data Protection Act 2018 (DPA) in the UK as of 1 January 2021 (5). These regulations prohibit the disclosure of private data to third parties without the patient’s consent and can only be used without consent in the case of direct care and healthcare quality improvement projects. On the 24th of November 2021, the UK government issued the Product Security and Telecommunications Infrastructure (PSTI) Bill to place increased cybersecurity standards on technology companies (6). Requirements of PSTI include banning default and weak passwords, investigation of compliance failures and being transparent about fixes to security issues, with hefty fines in place if these rules aren’t followed. These regulations will force Medtech companies to constantly update devices and software found to be at risk of cyber-attack, as well as keeping the public informed on the updates. In addition, NHS-contracted organisations need to follow the NHS Code of Confidentiality and Code of Practice (5). Medtech companies hoping to sell in the UK should ensure their device meets these NHS requirements, and the NHS Data Security and Protection Toolkit 2021 states that healthcare organisations must keep an inventory of CMDs in their network (7). While these regulations prevent CMD developers from directly releasing data to third parties, they will not prevent cyber-attacks.
On the 26th of June 2022, the UK Government had a press release in which they discussed future regulatory changes regarding CMDs and data security (8). As of the 30th of June 2023, CMDs will need to carry a UK Conformity Assessed (UKCA)marking to be sold in the UK instead of the current CE markings. The UKCA marking is not recognised by the EU market as it only complies to the UK Supply of Machinery (Safety) Regulations 2008 (9), meaning Medtech companies hoping to enter both markets will need to follow the regulations of both markings. In addition, the government intends to introduce pre-market regulations similar to the EU MDR General Safety and Performance Requirement (GSPR) 17.4 regarding cyber security for medical devices. Following this regulation, hardware, IT networks and security measures must meet minimum requirements including protection against unauthorised access needed to allow the software to run efficiently (10).
Potential future intersection between regulations for cybersecurity & medical devices.
Where regulation may fall short of innovation in the changing landscape and possible solutions
Currently, medical device regulations such as the Conformité Européenne (CE) and UKCA markings don’t intersect with cybersecurity and data protection regulations, meaning CMDs can currently be sold in the UK despite being susceptible to data leaks. There is no evidence to suggest that this will change soon, however possible future rules to combine these types of regulation may include classing data security as a component of patient safety in clinical trials. In addition, pre-market trials of CMD cybersecurity could be performed using simulated malware to test for vulnerabilities in CMDs, including software and AI networks (1). These regulations will force Medtech companies to consider the cybersecurity of their devices more strongly during the design and production stages of development, preventing cyber-attacks instead of retroactive changes following data leaks.
CMDs have revolutionised modern healthcare, however IoMT is still in its infancy and cybersecurity risks and subsequent regulatory changes are to be expected. These changes will likely stall the development and sale of CMDs due to increased care during development and stricter pre-market trials, however regulations are necessary to ensure patient data remains private for the safety and security of the public.
References:
1) Hernández-Álvarez L, Bullón Pérez JJ, Batista FK, Queiruga-Dios A. Security Threats and Cryptographic Protocols for Medical Wearables. Mathematics. 2022 Mar 10;10(6):886. – Available from: https://doi.org/10.3390/math10060886
4) Sato T, Ishimaru H, Takata T, Sasaki H, Shikano M. Application of Internet of Medical/Health Things to Decentralized Clinical Trials: Development Status and Regulatory Considerations. Frontiers in Medicine. 2022;9. doi: 10.3389/fmed.2022.903188
Advancements in technology of the past few decades has led to the development of devices capable of connecting to one another via networks such as Wi-Fi and Bluetooth, allowing them to create, transmit and receive data between one another. Medical technology (Medtech) companies have utilised these features to develop connected medical devices. These devices can transmit patient data such as heart rate, blood glucose levels and sleep patterns, which can be monitored by healthcare professionals and clinical trials companies, allowing for accurate remote oversight of a patient’s condition for quick and accurate diagnoses and treatment from anywhere.
The existence of connected medical devices has led to the Internet of Medical Things (IoMT), the connected network of health systems and services able to produce, transmit and analyse clinical data, which is changing the shape of healthcare and clinical trials globally.
Despite the clear potential of IoMTs in the healthcare system, there are several factors affecting the development of connected medical devices and their uptake by the public. Worries regarding the security of their private clinical data in the light of cybersecurity attacks over the past decade, and subsequent data protection regulations put in place to prevent further leaks and their potential impact on future innovations in the medtech industry.
Connected Medical Devices and the Internet of Medical Things (IoMT)
There are over 500,000connected medical devices (CMDs) currently on the market (1), which can be split into three key groups; stationary medical devices typically found in hospitals such as CT and MRI scanners, implanted medical devices such as pacemakers and defibrillators to monitor a patient’s condition more closely, and wearable medical devices such as smartwatches that track patient activity and insulin pumps (1). Many technology companies, including those which wouldn’t be classified as Medtech (Apple, Nike, Huawei) produce smart devices which produce data surrounding user activity such as exercise, heart rate and quality of sleep. In November 2021, the FDA authorised the first prescription-use VR system for chronic lower back pain, further highlighting the increasing opportunities for CMDs in healthcare (2). Artificial intelligence (AI) and machine learning (ML) algorithms can also be classed under CMDs, capable of automated learning using neural networks to search and analyse data much faster (3). These AI are commonly used to search for novel patterns in data, diagnoses and predicting outcomes, and optimising patient treatments and are commonly used in clinical trials (3).
These devices, the data they produce and the development of software capable of compiling and analysing this data has led to the creation of the Internet of Medical Things (IoMT), which has the potential to revolutionise healthcare (1). IoMT allows healthcare professionals to monitor patients in real time from anywhere, increasing the speed and accuracy of diagnoses and treatment. General uptake of IoMT in healthcare may improve disease and drug management, leading to better patient outcomes and decreased costs to healthcare providers.
Medical Devices and Clinical Trials
CMDs have allowed for hybrid and decentralised clinical trials (DCTs), in which trials take place remotely from patient’s homes and during their daily lives instead of on a trial site. The prevalence of DCTs have increased significantly since the start of the COVID-19 pandemic, in which patient access to clinical trials was reduced by 80% and monthly trial starts decreased by 50% (4).
DCTs allow patients to take part who would usually be unable to participate due to geographical or time limitations, while reducing time spent on-site. According to a study by CISCRP, 60% of patients see the location and time spent in a clinical site as important factors when considering clinical trials (5). CMDs can include telemedicines, smart phone apps and AI capable of analysing patient data. As a result of this, there has been ~34% annual compound growth of CMD use in clinical trials (6).These benefits are best portrayed by the significant growth in the IoMT market, which is expected to grow from ~$31 billion in 2021 to a predicted ~$188 billion in 2028 (7), with CMDs and wearable smart devices increasingly used in the home as well as healthcare institutions.
Cybersecurity Issues
Despite the advantages of the IoMT, the adoption of CMDs is hampered by concerns regarding the security of clinical data stored in the cloud, instead of traditional medical records stored on paper or in internal servers which are less susceptible to being leaked. IoMT devices are vulnerable to many types of attack which can interfere with patient monitoring and care. Examples of these include eavesdropping, in which an attacker gains access to private medical records which can then be used to unlock the CMD, gaining further access to unauthorised data and allowing them to tamper with private medical records (8). While the common aim of these attacks is to sell this data to a third party, attacks on IoMT devices could include changing medical data leading to improper diagnoses of patients, the prescription of medication leading to an allergic response, and inaccurate monitoring of medical conditions which would impact patient welfare and have potentially significant financial impacts (8).
There have been many instances of attacks on large technology companies in recent years. Fitbit, one of the largest producers of wearable activity tracking watches, has been revealed to be vulnerable to data leakage via network connection (9), and the Nike+ Fuelband is prone to attack due to its USB connector (10). Technology companies such as Huawei, Xiaomi and Jawbone have suffered data leaks (9).
These incidents have negatively impacted public trust in CMDs collecting medical data, with people typically not wishing to share medical information with non-NHS businesses for reasons other than direct care. While trust was shown to increase after a deliberative workshop, it remained low (<50%) (11). As shown here, public distrust towards CMDs amid cybersecurity scandals will halt the potential growth of IoMT and its applications in healthcare.
CMDs and IoMT provide a promising avenue for quick, efficient diagnoses and treatment of a variety of conditions and allow for DCTs which increases the number of willing participants and allows for remote accurate monitoring of conditions. However, cybersecurity issues halt the progress and uptake of CMDs due to public distrust and misuse of the technology by cyber attackers. Unfortunately, cybersecurity issues can typically only be addressed after the incident occurs, however updates to UK regulations regarding CMDs will help prevent future attacks and data leaks.
Cybersecurity breaches can have a variety of goals.
2) Sato T, Ishimaru H, Takata T, Sasaki H, Shikano M. Application of Internet of Medical/Health Things to Decentralized Clinical Trials: Development Status and Regulatory Considerations. Frontiers in Medicine. 2022;9. – Available from: https://doi.org/10.3389%2Ffmed.2022.903188
3) Angus DC. Randomized clinical trials of artificial intelligence. Jama. 2020 Mar 17;323(11):1043-5. – Available from: doi:10.1001/jama.2020.1039
5) Anderson A, Borfitz D, Getz K. Global public attitudes about clinical research and patient experiences with clinical trials. JAMA Network Open. 2018 Oct 5;1(6):e182969-. Available from: doi:10.1001/jamanetworkopen.2018.2969
6) Marra C, Chen JL, Coravos A, Stern AD. Quantifying the use of connected digital products in clinical research. NPJ digital medicine. 2020 Apr 3;3(1):1-5. – Available from: https://doi.org/10.1038/s41746-020-0259-x
8) Hasan MK, Ghazal TM, Saeed RA, Pandey B, Gohel H, Eshmawi AA, Abdel‐Khalek S, Alkhassawneh HM. A review on security threats, vulnerabilities, and counter measures of 5G enabled Internet‐of‐Medical‐Things. IET Communications. 2022 Mar;16(5):421-32. – Available from: https://doi.org/10.1049/cmu2.12301
9) Jiang D, Shi G. Research on data security and privacy protection of wearable equipment in healthcare. Journal of Healthcare Engineering. 2021 Feb 5;2021. – Available from: https://doi.org/10.1155/2021/6656204
10) Arias O, Wurm J, Hoang K, Jin Y. Privacy and security in internet of things and wearable devices. IEEE Transactions on Multi-Scale Computing Systems. 2015 Nov 6;1(2):99-109. DOI: 10.1109/TMSCS.2015.2498605
With the help of precision medicine, or personalised medicine, modern medicine has moved away from a ‘one size fits all’ approach to treating disease and towards therapeutic approaches that are tailored to individuals and subgroups. These treatments are designed to be more efficacious due to targeting population subgroups based on their genetic or molecular nuances, rather than operating on the assumption that all bodies function and respond the same way and to the same degree to a given treatment. Molecular knowledge can now be utilised to tailor treatment to the patient at the correct dosage and time point, usually with the aid of pharmacogenomic approaches and molecular biomarkers.
Information about an individual’s genetic makeup, such as genetic variants that may influence treatment efficacy, toxicity, and adverse events can help to determine how patients will respond to a certain treatment. In addition to genomic, recent technological advances have led to the identification of many transcriptomic and proteomic biomarkers. This knowledge is useful in all stages of therapeutic development and can influence both the design of the therapeutic itself and of the clinical trial.
Drug Development
Inter-individual variations in drug response can result from polymorphisms in drug metabolizing enzymes. Thorough examination of gene expression and mutations in disease populations can lead to the identification of distinct disease subpopulations that share certain characteristics. Further exploration of these genes and their interactions can uncover possible drug target genes for the treatment of a disease subpopulation.
Furthermore, an awareness of genetic variation in disease subpopulations means that the involved pathways and components can be more accurately recreated in pre-clinical studies. Bringing the gap between animal and human toxicity findings allows for more representative disease models. This allows variability in treatment response and optimal dosage to be explored more precisely.
Clinical Trial Design
Originally, clinical trials were designed to evaluate differences between novel treatments and standard treatments or controls, not among individual responses in treated groups. As a result, a therapeutic that was very effective in only a subgroup of the trial population may not have produced significant results and a therapeutic that caused adverse events in only a small subgroup could have been deemed too toxic for overall use.
The goal of clinical trials to gain regulatory approval remains unchanged. With the emergence of precision medicine come biomarker-driven trials that include patient subgroups in their design. Master protocols for trials enable the application of one treatment to multiple diseases, or multiple treatments to one disease, allowing a trial to adapt during its course. This room for adaptation can reduce financial impact due to ineffective treatments being abandoned earlier and targeting the most suitable groups. Incorporating a diagnostic assay in trial design can offer multiple advantages and prevent research from straying in the wrong direction.
Targeted therapies can be tested in the most appropriate patient groups likely to benefit by biomarker testing of patients prior to clinical trial participation. Screening patients for those more likely to respond well to treatment gives a greater estimate of treatment effect in the subgroup. This increases the likelihood of demonstrating efficacy in a clinical trial. It also reduces the size of the sample population required to see statistically significant results, which can speed up the process.
Identifying responders before enrolment in such a manner minimises the number of exposed patients who would not benefit from treatment. Decreasing the risk of exposing non-responders to potential adverse events can improve the benefit/risk analysis.
Patient stratification is another aspect of trial design that utilises patient’s molecular biomarker profiles. Stratifying trial participants into subgroups can classify disease subtypes. Particularly in oncology, genomic approaches can guide the stratification of patients by their tumour mutations. It is notably useful in umbrella, basket, and platform trials and can reduce the financial impact by allowing for adaptive trials.
Umbrella trials test multiple targeted therapeutics in different biomarker cohorts of a single disease. Basket trials, on the other hand, test one or more targeted therapeutics in a patient cohort with matched biomarkers. Platform trials have a randomised structure and allow the evaluation of multiple targeted therapeutics in multiple biomarker-selected populations.
Application in developed therapeutics
While precision medicine approaches are most beneficial when included throughout the drug development process, their application can also improve or salvage existing treatments and prevent a clinical trial from failing. For example, a developed drug may cause severe adverse events in a small disease subpopulation. Upon investigation it is found that the drug has a secondary target, which is only present in that subgroup. With this knowledge, patients can be screened for presence/absence of the safety biomarker and intervention with said drug can be avoided in that subgroup while continued in the remaining population.
Alternatively, a drug may have clinically meaningful results in only a small number of patients. The responsive subgroup can be explored for potential biomarkers associated with degree of responsiveness to treatment. The clinical trial can then resume with a focus on patients likely to respond well to the therapeutic.
Response Monitoring
Throughout and after a clinical trial, biomarkers can be used as a means of observing patient response to intervention, and account for variability in response. Safety and efficacy monitoring markers will reveal individual cases where treatment is working effectively or needs to be halted due to adverse events. For example, a cancer-related gene mutation or protein detected in blood may no longer be present after successful treatment has been administered, showing that the treatment has worked.
Identified responders or non-responders can be further stratified into subgroups and studied. Genomic information can aid in the understanding of outliers and changes to treatment response. This will contribute to disease and therapeutic understanding, so that the right patients can be given the right dose, getting the most benefit out of treatment.
Challenges of Precision Medicine
It should be noted that the development of a targeted therapy requires the right data, both for the identification of the drug target and suitable patients. Molecular data from disease populations in previous studies may not always be available during drug development. If available, it may not be the correct type of data or generated by the most appropriate assay. Developing a targeted therapy is not possible without suitable data to understand disease mechanisms and identify putative drug targets.
Biomarker-driven therapies require genetic tests and companion diagnostics to identify and distinguish suitable patients. Incorporating diagnostic methods in a clinical trial is an added cost and the process can be burdensome as it can make participant recruitment harder. Clinical intervention according to the results of stratification should also be well-defined before a trial phase commences.
References Di Liello, R., Piccirillo, M., Arenare, L., Gargiulo, P., Schettino, C., Gravina, A. and Perrone, F., 2021. Master Protocols for Precision Medicine in Oncology: Overcoming Methodology of Randomized Clinical Trials. Life, 11(11), p.1253. Dugger, S., Platt, A. and Goldstein, D., 2017. Drug development in the era of precision medicine. Nature Reviews Drug Discovery, 17(3), pp.183-196. Mirsadeghi, S. and Larijani, B., 2017. Personalized Medicine: Pharmacogenomics and Drug Development. Acta Med Iran, 55(3), pp.150-165. Woodcock, J., 2007. The Prospects for “Personalized Medicine” in Drug Development and Drug Therapy. Clinical Pharmacology & Therapeutics, 81(2), pp.164-169.
