08 December 2011

Why do we still organize clinical research reports by the IMRAD convention?

Here is Part 2 of the questions I posed in my previous blog post.

I have been thinking about this question for some time now. I remain curious as to why we still organize clinical research reports by the long-standing convention of Introduction, Objectives, Methods, Results, Discussion, and Conclusion? The IMRAD form of organization. The year 1665 is often cited as the origin of the platform commonly referred to as scientific papers. It was not until the second half of the 1800s that these documents moved in the direction of “theory – experiment – discussion.” Then starting in the early 1950s the IMRAD structure became the prominent norm for the structure of a scientific paper. 

The supposed reason for the IMRAD structure is that this organizational approach facilitates literature review, allowing readers to navigate articles more quickly to locate material relevant to their purpose. It has been suggested that the IMRAD structure effectively supports a reordering that eliminates unnecessary detail, and allow the reader to assess a well-ordered and noise free presentation of the relevant and significant information. I can see how this argument may apply to research manuscripts published in Journals, but it certainly does not apply to the kinds of study reports submitted to regulatory agency health authorities.  

Unfortunately, the supposedly neat order of the IMRAD arrayed report rarely corresponds to how regulatory readers consider using documents to help them make decisions. That is, decisions about how study results support or fail to support broad or narrowly defined questions/arguments. People are surprised to learn that health authority review agents rarely read study reports. They certainly engage with study reports and make use of the content. But read these documents? No, that is an approach not normally taken by the health authority review agent. 

Frankly, I cannot blame them. After all, the IMRAD form of organization does little to help them get answers to their questions or support their approach to making decisions.

Over the past 50 years, the idealized sequence of the IMRAD structure has on occasion been criticized for being too rigid and simplistic. Perhaps the most famous castigation was made by Peter Medawar in the early 60s. He criticized the IMRAD design for not giving a realistic representation of the thought processes of the writing scientist. And then in the mid 80s A. G. Gross wrote a paper titled: “The form of an experimental paper: A realization of the myth of induction” that challenged the notion of the IMRAD structure as well. 

I am right there too in questioning the merits of this approach. At least when it comes to study reports submitted to health authorities.

I believe the reason for rigid adherence to the IMRAD approach for research document organization is the precedence of the past. Not that it affords the most effective stucture for the reader to get what they want from a document.

As for me—I’d prefer a Question & Answer approach—something along the lines of organizing the report by study objectives with the study methods appropriately subordinated at the back of the report. Give me a report organized as follows: Objective—Results—Discussion—Assignment of Significance. Each section of the report deals with only one study objective and information is presented in the sequence I have suggested. Then the last section of the report would be Conclusions where you integrate and contextualize the study findings to answer the really big question of so what do all these findings mean?

So what do you think is the most effective form of organization for a regulatory clinical study report?

06 November 2011

Why do we do some of the things we do in clinical study reports? Part 1

Over the past three months I have been doing a series of workshops focused on the authorship of clinical research reports for a couple clients. This work has me posing questions about two very specific notions
  1. Why do people still demand that a clinical research report intended for incorporation into regulatory submission packages must be written as “stand-alone” documentation?
  2. Why do we still organize clinical research reports by the long-standing convention of Introduction, Objectives, Methods, Results, Discussion, and Conclusion?

In this post let’s consider the notion of the “stand-alone” clinical study report.

First question I have is why must these documents be stand alone? The term “stand alone” generally refers to a document or device that is self-contained and does not require any other document or device to fully function. I argue that a clinical study report submitted to a drug regulatory agency is part of a larger corpus and as such the report should never be construed as a stand-alone document.

It is a given that most submissions made to drug regulatory agencies contain multiple research studies. So you will never have a “stand-alone” research study. So an individual study is part of a corpus of clinical research that best operates collectively. Also regulatory submissions have multiple sections as mandated by guidance that are topoi (places of argument) for different and often integrated attributes of clinical research drawn from this corpus. So clearly the clinical study report is not a stand-alone document in the instance of interpretation and argumentation.

Another point, a clinical study report incorporated into a regulatory submission will have numerous appendices including the final version research protocol and the statistical analysis plan. So I struggle to understand the premise that says you must incorporate extensive elements of the protocol and stats plan into the body of the clinical study report in order to assure the report is a stand-alone document. I truly fail to see the merit of this premise.

My last point is why do so many feel it is necessary to write the Introduction Sections to clinical study reports in the classic inductive form of rhetoric that moves from describing the disease condition, to the therapeutic void, to the chemical or biological construct of the drug under study and how this drug’s pharmacological action addresses a therapeutic void. The standard response is, “well we want to make this a stand-alone document.” Why? All the rhetorical moves you are trying to make in the Introduction will happen for sure elsewhere in the drug submission package in the appropriate topos. So why waste your time here, at the low level of the clinical study report? In my way of thinking the study report Introduction is intended to convey only two points:
  1. Why are you doing the study (the answers to what questions do you want at the end of the study that you do not have now?)
  2. What previous work has informed the design of this study?

21 October 2011

Designing Regulatory Submission Documents for Decision Making

I have made blog posts from time to time talking about users of various document genre represented in communication about life science research. I believe that for many, my portrayal of how people engage with documents presents a different picture than what they hold in their imagination. At least I hope it is the case that they are designing documents to a meaningful mental model, as that helps to explain why so many documents I examine are rather ineffectual communication vehicles. Unfortunately I believe most documents are generated according to the model of precedence--"what did we do last time?" I think this is generally the only question consistently asked in the life sciences regarding document design.

In this post I want to talk about designing documents to satisfy readers who must make decisions, like a regulatory health agency reviewer. These reviewers must decide whether a drug, biologic, or device can be marketed as desired by the sponsoring company.

There is nice body of work in the cognitive sciences that describes the mind set and reading style of the selective professional reader who is reading documents in order to make a decision or a set of decisions. It is clear from this research that these readers are not empty cups waiting to be filled up with whatever you want to send their way in your documents. Not only is the professional reader very selective in what they will read, they are also very critical. That is, they read against the information you have submitted in your documents looking for insufficiencies and weaknesses.

Remember that the selective professional reader working in the the health regulatory agencies is a very sophisticated reader and in many instances they know what type of information they need right after they review the requested marketing claims for the drug or the medical device.

Here is the part that many people miss in creating their documents. No matter how logical and detailed your information may be, if you have not correctly anticipated what the selective professional reader needs in terms of information and the necessary level of detail, then you have failed. It is that simple.

Research shows clearly that decision-making is a function of schema-based cognitive processes deployed by the selective professional reader. The process is really well understood now and suggests that all documents  to be used in a decision-making environment should be designed to support a schema-based reading style versus the approach of reporting information or summarizing findings.

Schema activation is at the heart of decision making. Schema provide the interpretive framework for a reader to pass judgement on data and written discourse. In the process of reviewing drug and device submissions, the selective professional regulatory reader will make use of many, many schemata during the course of the decision-making process. Each schema they deploy will have multiple slots for information. They will want to fill every slot and they search documents and data bases looking for the details associated with the various slots in a particular schema. For example, a specific schema can be characterized by this question: "will the indicated drug dose lead to an undesirable toxicity profile in the elder, under weight, and hepatically compromised patient?" They will then examine the documents presented to find all the information they desire in making the decision whether the drug label language regarding dosing is acceptable or needs to be modified. And they read only looking for what they believe are the necessary details. In essence, they read at the virtual exclusion of anything within the document(s).

This is why we talk about  the selective professional reader scanning documents looking for very specific information and now using some sophisticated search tools to navigate through documents looking for specific pieces of information and data.

Much of what the selective professional reader at regulatory agencies do is further characterized as an attribute-based search. The attributes are often compared against known standards, but may also be subjective standards. The attributes they are considering are largely tied into the product label claims the sponsor wants to make.

So the net-net here is that life science research professionals need to reconsider what they believe to be acceptable document design parameters. It is essential to build out effective working models for how the selective professional reader using your documents makes decisions and what schemata are being deployed in this process and then design documents that support these specific reading methods.

Presentation: Why Most Document Reviews are Not Really Reviews

View Greg's presentation slide set from the recent DIA Clinical Forum:

12 October 2011

Notes on Managing Reviews Presentation and Discussions at DIA Clinical Forum

We had an interesting set of presentations and discussions yesterday at the DIA (Drug Information Association) Clinical Forum in Basel, Switzerland related to managing reviews. Here are my summary notes on the session.

I spoke along with Barry Drees from Trilogy Medical Writing and Rhys Stoneman from GlaxoSmithKline. We each covered aspects of improving review outcomes for clinical research documentation.

I addressed the topic that to affect change you must look at the root causes of poor review outcomes not merely the symptoms of poor outcomes. Barry and Rhys talked about how their organizations--a contract writing house  and a large multinational pharmaceutical company, respectively--look to improve review outcomes.

I talked about the underlying root cause of most poor review outcomes fit into two boxes

  1. No formal training in review methods
  2. Poor reviewer discipline

Note: Jessica will get my presentation slide set posted to the M/C web site.

I stressed that without training most people are left to inspect and edit documents and generally are not sensitive to how rhetorical situations vary with audience and document genre.  I talked about reviewer discipline is difficult to modify without  making process changes and applying performance mandates.

Barry  talked about methods he uses to influence behavior of review teams. He had a great line on one of his slides addressing lengthy review cycles: "We do not have enough time or money to do it right, but there is always time and money to do it over."

Rhys talked about the steps taken to transform work practices and belief systems related to the authorship and review of clinical documents. We did a lot of support and training work at GSK on this project, so I have seen firsthand the changes. It is fair to use the descriptor, dramatic, to characterize how they have reformed work practices and outcomes.

Not surprisingly, the topic of greatest interest to the audience was issues related to reviewer discipline and what can be done to modify or blunt the impact of bad behavior.

10 September 2011

Why Do Life Science Research Groups Fail to Improve Review Practices?

I've been away from the posting entries here for much of the summer as I had quite a bit going on both with McCulley/Cuppan projects and some personal writing projects. One of those writing projects is a collaboration with my long-standing colleague at the University of Delaware, Stephen Bernhardt. We worked together on a paper I was looking to submit to the Journal of Business and Technical Communication (JBTC) summarizing our examination at two large pharmaceutical companies of review practices applied to clinical research reports written to support new drug registration submissions.

The paper is titled: Missed Opportunities in the Review and Revision of Clinical Study Reports. It is scheduled to be published next April in JBTC.  

The paper summarizes findings derived from formal interviews, examinations of review efforts on succeeding drafts of various clinical study reports, observations of roundtable discussions of draft reports, and our formal assessments of document quality between early draft and final report versions.

The key finding is that we found document review was too focused on low-level edits as opposed to global revisions that would improve the arguments and address audience concerns. We also found that time-consuming document reviews did not lead to demonstrable improvement in report quality, with evident and important problems left unattended from draft to draft. The interviews showed most reviewers felt that over 80% of their review effort attended to intellectual versus structural aspects of the document where as our assessment of those review efforts showed that nearly 75% of review efforts in fact attended to numerical and grammatical accuracy and other structural aspects of the documents. Further, the interviews showed that very few individuals had any meaningful insight into what other reviewers attempted to accomplish during their course of their reviews.

Reviews generated voluminous remarks and edits, but the vast majority of both in-text edits and marginal comments addressed data integrity, simple reordering of information, and low-level features of style and language. Few remarks in any round of review addressed construction, completeness, or representation of arguments, logic trails linking purpose and objectives to discussions and conclusions, resolution of difficult issues, or study design rationales that would satisfy a skeptical regulatory reader.

The volume and type of review remarks were relatively similar between early drafts and late drafts. Reviewers spread similar remarks in similar proportions throughout the documents, whether the review was of an early or late draft.

Reviews did not significantly improve communication quality, as measured by assessment of initial draft compared to final report version. The review effort apparently had little impact on the communication quality of the final version of the reports we examined.

Troublesome issues regarding soundness or completeness of evidence, irregularities in study conduct, and interpretation of data frequently went unaddressed in final reports.

A theme throughout the literature is that document review frequently brings into play conflicting or competing purposes. We clearly saw this too in our examinations.

We have now done extensive assessment of review performance in eight pharmaceutical companies. The problems mentioned above are clearly widespread.

Clearly there is need for companies to become more evaluative and methodical regarding their own work practices, in part because the costs associated with planning, authoring and reviewing individual research reports are substantial. If we consider the time and costs of authoring, review, and publication preparation, we estimate that a final clinical research report might range in cost from $50,000 to well over $200,000. Now if we add in the opportunity costs for the time spent in inefficient review efforts (most companies stipulate in their SOPs that reviews are to be completed in two rounds yet few ever attain that standard) and having to respond to regulatory agency inquiries because of poor communication quality of a research report, then the costs for a final version clinical research report quickly swell and the cost-per-page of the final report approaches $2,500/page. Numbers I find incredible.

Even more astounding is the continued tolerance for such wholesale inefficiencies within these companies. The big question is why. Why do these life science organizations tolerate such costs? I recognize that changing non-productive, conditioned, inefficient practices is not an easy matter and that a company must do a lot of work to counter poor reviewer discipline and the ingrained tendencies of review teams to focus on low-level stylistic edits as opposed to high-level rhetorical concerns. However, other industries have placed a premium on good review performance and invested the effort to change practice and behavior to achieve the desired outcomes. 

28 July 2011

When is good regulatory writing "good enough"?

Here's another blog post worth repeating (originally published in 2010):

We do not talk much on this blog regarding the use of language or the application of terms in science writing. Principal reason is that much of what we see in regulatory submission documents is genuinely “good enough.” However, others do not necessarily see it that way. I want to share with you how discussions in review roundtables can end up getting focused at really absurd levels of detail with a misapplied sense of establishing quality communication. 

In our consulting work, we try to be disciplined during our document reviews and only comment on language when it truly obscures or alters meaning. Being grammatically perfect in regulatory submission documents is a nice notion, but in practice consumes way too much time and organizational energy and will yield little in terms of outcomes.

We share this point with people all the time...but at times the advice goes unheeded and even worse…at times people just do not know when to move on and address real big concerns in their documents.

A case in point is a situation I observed regarding a long winded discussion in a review meeting over the use of the term “very critical”. The term “critical” in a medical sense means: of a patient's condition having unstable and abnormal vital signs and other unfavorable indicators. In theory, the meaning of critical is a black-or-white proposition without qualifications regarding gradation. Something is either critical or it is not. Therefore there should be no adverbs, like “very” in front of the term “critical” to connote a measureable degree of criticality. In this roundtable review the team got caught up in a 30 minute discussion that involved only two people arguing whether to use the term “very critical” or change it to “critical.”

Being pragmatic, I’d have to say: “Guys what are you thinking? You hold a team hostage for 30 minutes to argue over grammatical accuracy? To argue over something that will not matter when and if read by a regulatory reviewer. There were 10 professionals sitting in the room and 8 did nothing for 30 minutes. Cost of salaries alone is enough argument to say “Forget about it, let’s move on…we cannot afford to argue over such insignificant detail.” When we add in the opportunity cost (what these 10 people collectively could have been doing with their time), then for sure you have to make the argument.

This above episode gets played out time and time again in review sessions all over the pharma and medical device industries and is the reason why I am steadfast in my position that the vast majority of people involved in authorship and review do not know the answer to the question “How do you know when is good, good enough?” The end result is inordinate amounts of time can be applied at the wrong level of detail in reports and submission documents.