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Development and Implementation of a Clinical Study to Support a New Marketing Claim

The Situation

A newly acquired company needs to start a clinical study at multiple US sites, but has no in-house clinical team to assist in developing the protocol or investigational plan.

The Solution

RQMIS acted as the company's clinical team and developed the protocol and investigational plan. The plan received approval from the central Institutional Review Board with no revisions.

RQMIS Develops and Implements a Post-Market Clinical Study

The development and implementation of a Clinical Study to support a new claim is critical in not only monitoring the clinical use of your product, but also addressing additional marketing claims that compete with other products on the market. These marketing claims do not change the indication for use of the medical product (and cleared by the regulatory authorities), but may speak to claims such as fewer adverse events, faster healing, reduced insurance costs, and so on.

The most important document in a clinical study is the protocol and more broadly the investigational plan. All parties within the study look to the protocol/investigational plan for direction and clarity—the Principal Investigator, Investigational Site Staff, Study Monitors, and the Clinical Team to name a few. The design of the protocol/investigational plan must address all patient safety concerns as it will be reviewed by the local Institutional Review Board.

Sponsors of clinical studies of expanded claims prefer to have an investigational plan that assures the product is used within the cleared indication for use, such that costly regulatory oversight by the regulatory authorities is not required. However, in the interest of gaining regulatory clearance of the expanded claim, the sponsor is equally interested in assuring the necessary data is being collected to support this future commercial regulatory submission -- 510(k) or Pre Market Approval (PMA) Supplement. Thus, cost is always a consideration.

The situation: A newly acquired company with an FDA-cleared bone augmentation/replacement material (human tissue plus synthetic) needs to start a clinical study at multiple US sites to determine if bone growth using their cleared bone replacement material allows bony fusion to occur at the same pace as that of bone autograft. The sponsor wants this study to begin in early 2019. The sponsor has no in-house clinical team to assist in developing the Protocol/Investigational Plan, and in addition, wished to understand how a sponsor might collect data supporting an effectiveness claim without requiring an Investigational Device Exemption (IDE) approval.

The sponsor, of course, had no desire to manage a study that was not designed to collect the necessary data that the regulatory authorities would need to clear the expanded claim but also would prefer to avoid the cost of submitting and maintaining FDA approval of an IDE study.

RQMIS acted as the sponsor's clinical team and developed the protocol/investigational plan for the sponsor. First steps:

  • Align with the sponsor on clinical study goals
  • Identify key stakeholders
  • Communicate with potential surgeons to gather input
  • Perform literature searches for background information
  • Work with third parties to determine claim-specific Protocol requirements
  • Develop an investigational plan that assured data integrity, patient safety, and study efficiencies (minimize cost).
  • Assure data generated would support a regulatory clearance for the expanded claim

RQMIS Clinical Project Manager, Data Manager and Clinical Trial Assistant assigned to the study worked together with the investigators to develop clinical and radiographic protocols and investigational plan. While drafting, RQMIS gathered sponsor and key stakeholder feedback on the processes and procedures to implemented. The investigational plan included the use of cloud based electronic database/study management tools and the use of independent radiographic assessment tools. Once all parties approved the Protocol and investigational plan, RQMIS submitted the protocol to the surgeons and a central Institutional Review Board (IRB).

From the initial work writing the Protocol, RQMIS:

  • Delivered clinical protocol and investigational plan to the sponsor in the agreed upon timeframe (one month)
  • Assured protocol design would collect the necessary data to support the future regulatory clearance
  • Received approval from the central IRB with no revisions
  • Was granted management of the clinical study

Need an expanded claims clinical study designed, managed?

RQMIS can develop clinical protocols and investigational plans for phase II/III/IV clinical studies while working with you and your team to get them approved and initiated in a timely manner and within budget.

Contact RQMIS at info@rqmis.com, call as at (978) 358-7307, or just click the Contact button below.

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