How the LA Freeway explains failures in regulatory compliance monitoring

By Danny Lieberman, CEO , Flask Data Ltd. 


GCP (Good Clinical Practice) is an international regulatory framework for conducting clinical trials on humans.

A drug company must comply with 3 things – ensure data integrity, assure safety of patients and compliance with the clinical trial protocol.

Drug companies, amazingly enough, enforce GCP compliance with physical onsite visits by people called study monitors.     The study monitors use reports and dashboards that are 2-6 weeks old.

A freeway paradigm helps explain why onsite visits by people study monitors don’t work and helps us plan and implement an effective system for protocol compliance monitoring of all sites, all data, all the time that saves time and money.

Selective attention.

Humans focus on the interesting facets of a scene ignoring the rest. This is explained by selective attention theory.

Selective attention is a cognitive process in which a person attends to one or a few sensory inputs while ignoring the other ones.

Selective attention can be likened to the manner by which a bottleneck restricts the flow rate of a fluid.

The bottleneck doesn’t allow the fluid to enter into the body of the bottle all at once; rather, it lets the fluid enter in certain amounts depending on the flow rate, until all of it has entered the bottle’s body.

Selective attention is necessary for us to attend consciously to sensory stimuli in such a way that we will not experience sensory overload. See the article in Wikipedia on Attenuation theory.

However, the challenge to compliance monitoring  does not end with selective attention; it only begins with it.

Your compliance monitoring, if done manually, will probably be limited to monthly visits at best.

A good compliance monitor will use a best practice of repeatable process, doing the same thing each time and looking at the same interesting facets of the scene each time.

Repeating the same subset of a scene at a site, is the compliance monitoring analog of the person with 1 year of experience repeated 20 times, which is not equivalent to 20 years of experience in a variety of tasks and jobs.

In our freeway paradigm – it is equivalent to standing on the same overpass and counting cars at the same time once every 4 weeks which is hardly comparable to using cameras that count license plates 24 hours / day.

The impact of selective attention on compliance monitoring

For example, in the Second European Stroke Prevention Study, data on 438 patients were fabricated at one site.

This was first detected by statistical anomalies in the data and later confirmed by a central review of blood results: A visit to the site had failed to identify any transgression.[5,6]

Quis custodiet ipsos custodes?

Consider that study data is available in real time from the clinical data collection  system. Using statistical methods we may trace discrepancies in the data and identify outliers.

If not automated, then statistics may turn into a tool for manipulation in the presence of greed, as witnessed by the sad story of Andromeda Biotech who colluded with a bio-statistics firm in Israel to cook the results.

In 2014, Hyperion Therapeutics Inc. (Nasdaq: HPTX) canceled its acquisition of Israeli company Andromeda Biotech, which was developing a Type 1 (juvenile) diabetes drug DiaPep277.

According to Hyperion, Andromeda colluded with a third-party biostatistics firm in Israel to improperly receive un-blinded DIA-AID 1 trial data and to use such data in order to manipulate the analyses to obtain a favorable result. See Hyperion cancels Andromeda acquisition.

The freeway model of compliance monitoring.

Imagine an observer standing on an overpass over a freeway watching cars that are moving at a fairly uniform pace.

After a very short period of time, the observer will generally ignore cars traveling at the same speed (“consistent events”).

The observer will  however notice slow-moving vehicles or cars speeding and weaving in and out of traffic (“novel events”).

Consistent events are bad news for people who audit a process

Consistent events however, may be bad news events for patient safety or protocol compliance.

Consider the case of the psychiatric study where 55 percent of the subjects were consistently under-dosed – both a protocol violation and potentially a safety issue for the  treatment.

Compliance monitors did not detect these consistent under-dosing events for the same reason that our casual observer on the freeway overpass doesn’t notice that the majority of cars are speeding, bumper to bumper.

6 things you must do in order to achieve effective compliance monitoring.

  1. Compliance Monitoring highly benefits from automation.

Your monitoring operations should not be dependent on manual export and import and manual processing of data from your transaction processing system.

Manual data extracts, transformation and  load  are highly vulnerable to human error and human greed as we see from the Hyperion Andromeda debacle.

  1. An automated compliance monitoring system should behave in a manner similar to our human freeway observer.

It will first learn the normal, consistent events and then detect novel or inconsistent events.  We see capabilities like this in so-called smart highways and every day in traffic light management systems that adapt to traffic patterns.

A key point in an automated monitoring system is that the software learns novel or inconsistent events over time.

Life is dynamic. Plan for change.

This is in contrast to the traditional approach of using static risk signatures ignoring changes and difficulties that develop during the normal course of business.

  1. Know what you don’t know.

The process of compliance monitoring is dynamic just like freeway traffic.

The tools you need to monitor traffic on the San Diego freeway at 3AM are different from those that work at 930 AM since the weather and road conditions can change unpredictably.

A visit by a US President to a meeting of the DNC in Beverly Hills can disrupt the entire system.

  1. Rapid response in a slow moving situation.

Compliance violations usually move very slowly.

However, when they do happen;  compliance violations, whether premeditated or mistaken, need to be addressed immediately by the management and not brushed under the table.

Rapidly iterate to improve

Issues can pop up anywhere.

The users of automated monitoring technology need to be able to rapidly iterate in order to improve the performance of their tools using search and visualization to discover questions they never thought of asking at the kickoff meetings with the sites.

Move quickly in a slow-moving situation

5. Total ownership

Getting back to Quis custodiet ipsos custodes? (the Latin phrase in the work of the Roman poet Juvenal from his Satires is  literally translated as “Who will guard the guards themselves?”   Monitor your CRO.

  1. Compliance automation technology is a tool used by people.

The technology must be reliable, fast, friendly and communicative and allow the sponsor to do much more with his monitoring dollar which accounts for 30% – 50%  of the budget in  Phase 2-3 trials.

In summary:

We have seen that a freeway model describes the challenges of remote risk-based monitoring and also provides a framework for meeting those challenges.

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