Using Statistical Modeling for Enhanced and Flexible Pharmacovigilance Audit Risk Assessment and Planning.

BACKGROUND: The European Medicines Agency Good Pharmacovigilance Practices (GVP) guidelines provide a framework for pharmacovigilance (PV) audits, including limited guidance on risk assessment methods. Quality assurance (QA) teams of large and medium sized pharmaceutical companies generally conduct annual risk assessments of the PV system, based on retrospective review of data and pre-defined impact factors to plan for PV audits which require a high volume of manual work and resources. In addition, for companies of this size, auditing the entire "universe" of individual entities on an annual basis is generally prohibitive due to sheer volume. A risk assessment approach that enables efficient, temporal, and targeted PV audits is not currently available. METHODS: In this project, we developed a statistical model to enable holistic and efficient risk assessment of certain aspects of the PV system. We used findings from a curated data set from Roche operational and quality assurance PV data, covering a span of over 8 years (2011-2019) and we modeled the risk with a logistic regression on quality PV risk indicators defined as data stream statistics over sliding windows. RESULTS: We produced a model for each PV impact factor (e.g. 'Compliance to Individual Case Safety Report') for which we had enough features. For PV impact factors where modeling was not feasible, we used descriptive statistics. All the outputs were consolidated and displayed in a QA dashboard built on Spotfire®. CONCLUSION: The model has been deployed as a quality decisioning tool available to Roche Quality professionals. It is used, for example, to inform the decision on which affiliates (i.e. pharmaceutical company commercial entities) undergo audit for PV activities. The model will be continuously monitored and fine-tuned to ensure its reliability.

Enabling Data-Driven Clinical Quality Assurance: Predicting Adverse Event Reporting in Clinical Trials Using Machine Learning.

INTRODUCTION: Adverse event (AE) under-reporting has been a recurrent issue raised during health authorities Good Clinical Practices (GCP) inspections and audits. Moreover, safety under-reporting poses a risk to patient safety and data integrity. The current clinical Quality Assurance (QA) practices used to detect AE under-reporting rely heavily on investigator site and study audits. Yet several sponsors and institutions have had repeated findings related to safety reporting, and this has led to delays in regulatory submissions. Recent developments in data management and IT systems allow data scientists to apply techniques such as machine learning to detect AE under-reporting in an automated fashion. OBJECTIVE: In this project, we developed a predictive model that enables Roche/Genentech Quality Program Leads oversight of AE reporting at the program, study, site, and patient level. This project was part of a broader effort at Roche/Genentech Product Development Quality to apply advanced analytics to augment and complement traditional clinical QA approaches. METHOD: We used a curated data set from 104 completed Roche/Genentech sponsored clinical studies to train a machine learning model to predict the expected number of AEs. Our final model used 54 features built on patient (e.g., demographics, vitals) and study attributes (e.g., molecule class, disease area). RESULTS: In order to evaluate model performance, we tested how well it would detect simulated test cases based on data not used for model training. For relevant simulation scenarios of 25%, 50%, and 75% under-reporting on the site level, our model scored an area under the curve (AUC) of the receiver operating characteristic (ROC) curve of 0.62, 0.79, and 0.92, respectively. CONCLUSION: The model has been deployed to evaluate safety reporting performance in a set of ongoing studies in the form of a QA/dashboard cockpit available to Roche Quality Program Leads. Applicability and production performance will be assessed over the next 12-24 months in which we will develop a validation strategy to fully integrate our model into Roche QA processes.