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CDISC Italian User Group 16 November 2007

Study Data Tabulation Model (SDTM)

Annamaria Muraro
Helsinn Healthcare

Regulatory Background
1999, FDA guidance Providing Regulatory Submissions in Electronic Format NDAs
SAS XPT datasets Pdf documents: Define.pdf (data contents), blankcrf.pdf (annotated CRF) Case Report Tabulation (Patient Profiles) as pdf files

October 2005: FDA issued the guidance Providing Regulatory submissions in Electronic format using the eCTD specifications September 2006: FDA published in the Federal Register a notice of withdrawal of electronic submission guidance for eNDA.
This notice designates eCTD as preferred format for electronic submissions and notes that beginning Jan 2008 any electronic submission must be eCTD

What is SDTM: Study Data Tabulation Model


This model describes the contents and structure of data collected during a clinical trial The purpose is to provide regulatory authority reviewers (FDA) a clear description of the structure, attributes and contents of each dataset and variables submitted as part of a product application
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SDTM
Animals (SEND)

Humans (SDTMIG)

Implementation Guidelines
http://www.cdisc.org/standards/index.html http://www.fda.gov/oc/datacouncil/cdisc.html

Study Data Tabulation Model, Version 1.1, April 2005


which represents the underlying conceptual model behind the submission data standards (SDS)

SDTM Implementation Guide, Version 3.1.1, August 2005


Detailed Domains description, Variables to be included and their attributes, assumptions and convention, Examples Version 3.1.2 posted for Comment July 2007
New standard domains More details

Controlled Terminology: SDTM Package-1 & Lab Test Controlled Terminology, Package 2A, Package 2B (under development) SEND, Standard for Exchange of Nonclinical Data Implementation Guide for Animal Toxicology Studies, Version 2.3
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Fundamentals of SDTM - Domains


Domain: collection of observations with common topic Case Report Form SDTM domain Dataset
A domain may collect data from more than one CRF form Generally each domain is represented by a dataset

Each domain has a unique two-character domain name (e.g., AE, CM, VS) Variables in domain begin with the domain prefix: (e.g., VSTESTCD) Domain structure: vertical Two categories of domains:
CDISC Standard Domains (spelled out in detail in the Implementation Guide). Custom Domains
Based on one of the General Observation Classes (findings, events, interventions) Basic variables are outlined in the SDTM Rules for creating these are in Section 2 of the IG

SDTM Basics - Structures Based Upon General Observation Classes


Interventions:
Investigational treatments, therapeutic treatments, and procedures administered to or taken by the subject One record per constant dosing/treatment interval Examples: study medications(EX), concomitant medications(CM)

Events:
Occurrences or incidents independent of planned study evaluations occurring during the trial or prior to the trial One record per event Examples: medical history(MH), adverse events(AE)

Findings:
Observations resulting from planned evaluations One record per finding result or measurement Examples: lab data(LB), vital signs(VS)

Each of these has defined structures and variables. No new variables may be added to these domain classes
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SDTM Basics - Special-Purpose Datasets


Not Classified as Interventions, Events, or Findings They Have Special Rules Demographics (DM) Comments (CO): free text comments Trial domains: to describe the design of a trial RELREC dataset: represent the relationship between datasets and records SUPPQUAL: used for data items not included in the SDTM standard

SDTM Standard Domains


Interventions
Exposure
(EX)

Events
Adverse Event (AE) Disposition
(DS)

Findings
Labs
(LB)

Other
Demog
(DM)

Incl/Excl
(IE)

ConMeds
(CM)

Vitals
(VS)

SubjChar
(SC)

Comments
(CO)

Supp Qualifiers Subst Use


(SU)

MedHist
(MH)

PhysExam
(PE)

ECG
(EG)

Relationships Trial Design

Deviations
(DV)

Questionnaire
(QS)

PK Param (PP) Concentrations (PC)


Draft 3.1.2

Microbiology (MB)

Drug Accountability (DA)


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Fundamentals of SDTM - Variables

CDISC categorizes variables as being


Required: variables need to be in the domains
Their values cannot be null Some values may be null

Expected: variables need to be in the domain Permissible: variables included in the domain as needed

CDISC

categorizes variables into five roles

Identifier: identify the study, subject of the observation, the sequence number Topic: specify the focus of the observation (such as the name of the lab test) Timing: describe the timing of the observation (Visit, Start/End date, Days, Time Points, Duration) Qualifier: additional text or numeric values Rule: express an algorithm or method to define start, end or looping conditions in the Trial Design model

Fundamentals of SDTM - Variables


Variables Attributes
Variable Name: limited to 8-chars Variable Label: <=40 chars Variable Type: mainly char Variable Lenght: <=200 chars

Date/time format
ISO 8601 is a text string YYYY-MM-DDT hh:mm:ss (not a SAS format) Has ability to handle incomplete date Example: December 15, 2003 13:14:17 2003-12-15T13:14:17 December 15, 2003 2003-12-15

Controlled Terms or Format


Controlled terminology or text should be used instead of, or in addition to arbitrary number codes ( No SAS format!!) CT (**) published externally (ex.MedDRA or follow CDISC-specific terminology) CT (*) value from a sponsor-defined codelist

Raw data (as originally collected) and derived values (e.g. conversion to standard units, age)
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Example: DM

CRF Derived Sponsor Defined External Lab

Required Expected Permissible Details

YYYY-MM-DDThh:mm:ss

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Example: DM

Reference standards

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Example: DS

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Example: DS

DISPOSITION EVENT PROTOCOL MILESTONE OTHER EVENT

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Example (LB)

ORIGINAL RESULT

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Example (LB)

STANDARD FORMAT, char

STANDARD FORMAT, num

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Trial Design Model


Defines a standard structure for representing the planned sequence of events and the treatment plan for the trial Trial Arms (Planned): described each planned arm in the trial
(ordered sequence of elements)

Trial Element (Planned): describes the Element, rules for


starting/ending the element

Trial Visits (Planned): describes the planned order and number


of visits in the study
tion c e S IG , 7.1 e 87 pag

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Trial Design Model


Subject Element (Actual), Subject Visit (Actual) Subject Element and Subject Visit are specialpurpose domain in the draft version SDTMIG 3.1.2 Trial Inclusion/Exclusion Criteria: lookup table: one record for
each inclusion/exclusion criterion. Not subject oriented

Trial Summary: descriptive attributes of trial like trial phase, title, objective etc.)

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SDTM adoption by FDA


July 2004: FDA has endorsed the CDISC standards

October 2005, FDA Guidance for ICH eCommon Technical Document (eCTD) is updated. CDISC SDTM format is recommended for clinical data and define.xml for metadata

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Dec 2006: Proposed Rule


The Food and Drug Administration is proposing to amend the regulations governing the format in which clinical study data and bioequivalence data are required to be submitted for new drug applications (NDAs), biological license applications (BLAs), and abbreviated new drug applications (ANDAs). The proposal would revise our regulations to require that data submitted for NDAs, BLAs, and ANDAs, and their supplements and amendments be provided in an electronic format that FDA can process, review, and archive. The proposal would also require the use of standardized data structure, terminology, and code sets contained in current FDA guidance (the Study Data Tabulation Model (SDTM) developed by the Clinical Data Interchange Standards Consortium) to allow for more efficient and comprehensive data review.

Federal Federal Register Register // Volume Volume 71, 71, No. No. 237 237 // Monday, Monday, December December 11, 11, 2006 2006

The CDISC SDTM is still the preferred data specification. It will become required data specification when the proposed rule is approved.
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FDA standard tools


Data standards allow FDA to develop standard tools for review (http://www.fda.gov/oc/datacouncil/meetings/oliva.pdf)
WebSDM was developed under a Cooperative Research and Development Agreement (CRADA) between the FDA and Lincoln Technologies with the goal of providing a user-friendly environment for browsing and reviewing CDISC SDTM-compliant clinical trial. This product has been in use at FDA since 2004 For each domain, users can access variable summary statistics, data visualization tools and drill down into individual subject data and patient profiles

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SDTM Adoption by FDA


SDTM / ADaM Pilot projects
Pilot regulatory submission using SDTM/ADaM (data from Eli Lilly company, lesson learned reported at CDISC Interchange 2006) Integrated Safety Data Pilot is now underway

CDISC SDTM Training at FDA: In preparation for the


increasing volume in SDTM submissions to the FDA, CDISC and FDA have joined forces to ensure that FDA personnel, "speak SDTM". On 9 July 2007, there was an open SDTM training session for FDA at the White Oak facility in Maryland. Approximately 50 people from FDA attended with representation from statistical, data management, and programming functions (CDISC newsletter,

Sept 2007)

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Implementation: Helsinn experience


Integrated approach to standardization Team work and training Standards applied to any study, any phase Mapping to CDISC standards
CDISC general assumptions 100% implemented Include any Required and Expected variables Select Permissible variables based on data we collect Some deviations from CDISC acceptable Need to develop code lists (lab parameter, pk parameters, etc.), CDISC controlled terminology not available yet Clear understanding of the SDTMIG Are custom domains needed? Where to collect cancer history? How to map data collected by patient diary? Coding for CM, intermediate levels were needed Trial domains mapping for cycle based studies, cross-over studies

Interacting with CROs and providers


Provide CROs with a clear understanding of CDISC mapping requirements Central Lab, Bioanalytical provider: collect data CDISC compliant from the source

Integration of old clinical data


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Should SDTM be used for submissions to the FDA only?


Benefit of SDTM as internal data standard
No need to convert data for esubmission Reduce data transformation efforts Efficient (and coste effective) data exchange with providers (CROs, Central Lab, etc) Easier interaction with CROs, in-licensing made easier, mergers less painful To maximize clarity in the process using a data standard which everyone will be familiar: integrated process from CRF to submission To use standards with large consensus with pharma industry instead of maintain its own standard

But dont expect it to be easy! Expect resistance e.g. whats wrong with my existing standard, we dont have time/resource Have answers ready for questions such as How long will it take? How much resource will be required? What is the cost of doing this? What are the cost savings if we implement this?
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Questions

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Representing Relationship Back-up


Relating groups of records in a domain for a subject
Use the variable --GRPID

Relating non-standard variables to a parent domain


SDTM does not allow the addition of new variables Use the SUPPQUAL dataset to capture non-standard variables and their association to parent records Suppl variables may be collected by separete SUPP dataset (convention SUPP where is the two letter domain code (example SUPPLB, SUPPDM)

Relating independent records in separate domains


Use the RELREC dataset

Relating datasets
Use the RELREC dataset

, 8.1 . r pa IG, e 121 pag

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Creating a New Domain: BACK-UP slide


Ensure that there is a definite need to create a new domain Assign a 2-letter domain code Choose the general observation class (Interventions, Events or Findings) that best fits the data Add variables as follow: Identifier Variables (studyid, domain, usubjid, --seq), Timing Variables, Topic & Qualifiers No new sponsor-defined variables can be added to SDTM Follow SDTM conventions for variable order, name/label/type

, 2.6 . r pa IG, e 13 pag

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