Although prospective registration of clinical trials is becoming an
international standard, the debate continues over public access to clinical
trial results, especially investigational trials conducted by pharmaceutical
companies.
Recent legislation, which has been signed into law by President Bush,
reflects increasing pressure to disclose clinical trial information to the
public. A solution to the disclosure problem must balance conflicting
interests, including commercial interests, the public's right to be informed,
unbiased publication of medical research, copyright and proprietary
information, and therapeutic guidelines.
In its 2004 editorial, the International Committee of Medical Journal
Editors (ICMJE) admitted that the registration of study protocols "is
only part of the means to an end; that end is full transparency with respect
to performance and reporting of clinical trials." This end remains
elusive today. There is no open, searchable, central repository for results of
most clinical studies, like
ClinicalTrials.gov
has done for trial registration. Simply knowing the existence of certain
trials does not entirely prevent underreported negative and inconclusive study
results. The editors believed that study sponsors and researchers should
openly and honestly report clinical trial results—an ethical obligation
they owe to trial participants' "altruism and trust that make clinical
research possible."
Some researchers routinely post PubMed links to journal articles containing
results of their registered trials on
ClinicalTrials.gov,
although it is unclear whether the National Library of Medicine, which runs
PubMed, has a mechanism to ensure prompt, consistent reporting and updates of
these publications. Results not published in biomedical journals would not be
posted on the Web site Publication in a peer-reviewed journal can be a lengthy
process, causing considerable delays in posting the citation online. As ICMJE
pointed out, negative or inconclusive study results are less likely to be
published than positive results. A study of published psychiatric clinical
trials linked authors' conflicts of interest with a greater likelihood that
study results were favorable to the intervention studied (Psychiatric
News, October 21, 2005).
In a 2005 joint policy statement, the European Federation of Pharmaceutical
Industries and Associations, International Federation of Pharmaceutical
Manufacturers and Associations (IFPMA), Japanese Pharmaceutical Manufactures
Association, and Pharmaceutical Research and Manufacturers of America (PhRMA)
recommended voluntary disclosure of "the results of all clinical trials,
other than exploratory trials, conducted on a drug that is approved for
marketing and is commercially available in at least one country" in a
free, publicly accessible clinical trial results database.
For investigational products that are not successfully developed and
approved by regulatory agencies, they encourage sponsors to post study results
if possible and if the results have "significant medical importance and
may have an impact on...labeling." PhRMA advises members to post results
of "studies conducted after a drug's approval," which may include
postmarketing surveillance studies or phase 2 or phase 3 clinical trials for
unapproved indications.
PhRMA has sponsored a study-results database,
ClinicalStudyResults.org,
since 2006. It appears to be the most comprehensive results repository
available and contains clinical trial results for drugs that are already
marketed in the United States. Study results are contributed by PhRMA members,
which include major U.S. pharmaceutical companies but only a few
biopharmaceutical companies.
Eli Lilly and Co. has adopted a broader policy of disclosing results of all
trials, regardless of the phase, that the company has conducted in support of
a product's initial registration "no later than when the first
indication is approved and the drug is commercially available for patient use
anywhere in the world." PhRMA's policy remains silent on the
retrospective disclosure of preapproval clinical trial results.
It is unknown how many PhRMA member companies routinely and consistently
follow the organization's guidelines and post trial results on the Web site.
Reporting on
ClinicalStudyResults.org
remains voluntary and is not monitored by an outside group. The Web site
states that "PhRMA hopes that database administration will eventually be
transferred to an independent third party." By the end of April, the Web
site contained clinical study results for 351 prescription drugs.
The World Health Organization Registry Platform has established the Study
Group on the Reporting of Findings of Clinical Trials to provide advice to it
on the reporting of clinical trial findings. A lack of consensus on
international standards is cited as one hurdle to be overcome before an
effective mechanism is ready to be adopted worldwide.
The ICMJE, for example, supports reporting study results "in the form
of a brief (< 500 words) structured abstract or table" before they
are published in a biomedical journal, due to concerns about first-publication
rights. Extensive revelation of study results could be considered a form of
publication and, at least theoretically, could jeopardize its eligibility to
be published as primary research. Alternatively, the ICMJE suggests that study
results be posted in a public registry "24 months after closure of data
collection if results are not published in a peer-reviewed venue by that
time."
Public Citizen, a consumer advocacy group, emphasizes the need for
summaries of study results using nontechnical language in a results database."
Clinical trial results should be given in a way that's palatable to the
lay public. A lay person can go to PubMed and search for journal articles, but
the technical language is more likely to confuse and mislead them,"
Peter Lurie, M.D., deputy director of the organization's Health Research
Group, told Psychiatric News.
PhRMA takes a different position on the issue. Ken Johnson, senior vice
president of PhRMA, stated in a September 17 press release that "it is
crucial that during the evaluation of clinical trial information, researchers
acknowledge that the analytical methods used—such as
meta-analysis—have limitations as well as strengths. And it is important
not to reach hasty conclusions until all studies and data have been
evaluated."
Some researchers are concerned about misinterpretation or disproportional
reaction to study conclusions. Clinical studies are often complex and yield
ambiguous findings. In a commentary in the May 16 Journal of the American
Medical Association, Deborah Zarin, M.D., director of
ClinicalTrials.gov,
and coauthors pointed out that attempting to convey complex study results
using simple summaries could pose risks for misinterpretation or unintended
consequences. The accuracy of non-peer-reviewed results and the reliability of
data, if directly provided by sponsors with vested interests, are of
particular concern. Without peer review and editorial commentaries, studies
with poor design and questionable conclusions may be disseminated, and the
public may not be able to distinguish these from peer-reviewed reports with
higher quality.
The Food and Drug Administration (FDA) Amendments Act (HR 3580), which
passed the House of Representatives and Senate in late September and has been
signed into law, mandates prospective registration for clinical trials of all
drugs, biologics, and medical devices (see Increased Industry Fees to Help FDA
Better Monitor Drug Safety). Registration in a searchable public database,
which will likely be an expanded version of
ClinicalTrials.gov,
will be required for all clinical trials except those in phase 1. "Basic
results" from clinical trials of approved products will be required to
be submitted to the database as well. The secretary of Health and Human
Services will make additional rules as to whether the database will include
results from trials of unapproved products and the datasets that must be
submitted. The FDA will have the authority to issue civil monetary penalties
in enforcing the law.
This legislation is expected to hasten the standardization and
centralization of clinical trial disclosure and bring far-reaching changes to
the communication among clinical research, pharmaceutical industry, biomedical
journal publishing, medical practitioners, and the general public.
Following is a list of current clinical trial results databases:
PhRMA's joint policy paper is posted at<www.phrma.org/files/2005-01-06.1113.PDF>;
the Federation of American Scientists' report for Congress is posted at<www.fas.org/sgp/crs/misc/RL32832.pdf>;
the FDA Amendment Act is posted at<thomas.loc.gov/cgi-bin/bdquery/z?d110:h.r.03580:>.▪