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Update Website: feedback from FDA from January Meeting #135
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Update Website: feedback from FDA from December/January Meeting
Update Website: feedback from FDA from January Meeting
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…from-fda-from-decemberjanuary-meeting Closes #135 Feedback from January 2024 Meeting
This was referenced Jan 16, 2024
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Compile by @robertdevine
The FDA Review indicated that using the R generated ADaM data sets
in Pilot3, the reviewers were able to replicate the results of the
four analyses used in Pilot1.
The FDA Reviewer (Hye Soo) did identify (so far) several issues
and presented observations and questions for response from the
Pilot3 Team.
Items [1] through [3] are Actionable. Items [4] and [5] are
Non-Actionable.
[1]FDA Reviewer observed no statistical analysis plan (SAP) was
included with the Pilot3 submission.
Action Item: Confirm with FDA Reviewers that the SAP should be
included if a re-submission is requested. Given
Question 1(b) inclusion of the SAP may provide
clarity regarding correctness.
[2]The Primary output in Pilot 3 was different from the Pilot 1
result due to the QC findings. QC findings in the ADRG include
all of the discrepancies between the original ADaM datasets.
Action Item: Respond to FDA Review Question #1: How did you know
this was an issue from the CDISC ADADAS (Pilot1)
and how did you correct them?
Observation: FDA Reviewer shared an example using USUBJID 01-705-1292
Question 1(a): Why was LOCF required when there was no
missing data in the QS?
Observation: FDA Reviewer (Hye Soo) noted in the primary results
(i)slight difference in rounding and (ii)quite different
p-values. [Appears to be due to QC Findings discrepancies.]
Action Item: Respond to FDA Review Question 1(b): Which primary analysis
output is correct? Hye Soo noted lack of clarity regarding
determination of correctness due to unavailable SAP.
[3]FDA Review also presented an observation noting that in the
Pilot3 Summary Tables and Figures Report you noted that
different open-source packages were used when generating
each of the 4 analysis outputs to test wider use case
scenarios. However, the R packages and scripts seem identical
to Pilot1.
Action Item: Respond to FDA Review Question #2:
What exactly has changed?
*This was discussed at the R Consortium WG and
Ning responded to the question by stating the
language used in the Pilot3 submission was
carried over from Pilot1 to Pilot3. The Pilot3
response should confirm Ning's response to Hye Soo.
[4]Moderator Observation: Quality Control (Non-Actionable)
Should we have a standard or checklist for tracking differences between
Pilot1 and Pilot3 and Pilot(n).
Action Item: Recommend or suggest a checklist for comparison to a
single-point-of-truth as a Quality Factor.
[5]WG Team Observation (Non-Actionable)
The idea of using AI tools to check consistency was mentioned by Ning
Action Item: Review applicable AI Tools for application integration to
address inconsistencies, for example, Copy & Paste
differences which were noted by FDA Reviewer Paul
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