Navigating Regulatory Biostatistical Requirements | Page 12

Furthermore, rather than writing the protocol so that dropout by a participant results in a lack of measured study outcomes, which can limit the inferences regarding the effects, the NAS report on missing data recommends that: ‘‘ Sponsors should continue to collect information on key outcomes on participants who discontinue their protocol-specified intervention in the course of the study, except in those cases for which a compelling cost-benefit analysis argues otherwise, and this information should be recorded and used in the analysis.3 In addition, to avoid data-driven method selection, all of the relevant aspects of the analysis, including those for missing data and interim analyses, should be included in the protocol and SAP.5 To minimize the potential of introducing operational biases into the trial by making changes to the trial conduct based on the accumulating data, the protocol should also specifically address who will have access to the data and conclusions. Ideally, the personnel who see unblinded results should not have involvement in trial conduct or analysis decisions. For example, the IDMC could see the unblinded results, but the recommendations to the trial sponsor would not include these results. 12 The FDA and other regulatory authorities have published several documents that highlight potential concerns and issues that can occur d \