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Overview Of “Good Clinical Practice"

One Sheet
May 24, 2024
This One Sheet discusses Good Clinical Practice (GCP) guidelines, which stem from the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use. GCP ensures that all clinical trials are conducted ethically, with the well-being of participants
General GCP stems from the work of the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (“ICH”). Section 6 of the ICH Efficacy Guidelines deals with GCP, and can be found here. These guidelines have been adopted in virtually all developed countries, including the U.S. GCP concepts are self-evident, and consistent with the manner in which all good physicians behave. They can be summarized as follows:“All clinical trials should be conducted in accordance with ethical principles, sound scientific evidence and clear detailed protocols. The benefits of conducting trials should outweigh the risks. he rights, safety and well-being of trial participants are of paramount importance and these should be preserved by obtaining informed consent and maintaining confidentiality. The care must be given by appropriately qualified personnel with adequate experience. Records should be easily accessible and retrievable for accurate reporting, verification, and interpretation. Investigational products should be manufactured according to Good Manufacturing Practice.” (See here.) GCP And Real-World Evidence GCP is relevant to real-world evidence studies. In its December 2019 guidance on the use of RWE for regulatory decision- making, the FDA explicitly stated:“Many of the considerations and best practices for generating RWE are derived from the same principles that govern generation of clinical evidence from traditional clinical studies, which are generally referred to as good clinical practice (GCP).” GCP CertificatesA study sponsor depends on GCP compliance. They typically require that each investigator (or his/her organization) holds a GCP certificate. GCP certificates are issued by independent parties. The CITI Program is commonly used. Programs are available for organizations as well as individuals. The current cost is about $130 per person, and the course requires about 4 hours of time.GCP certificates provide value for independent physicians. They support the ability to participate in industry-sponsored studies. They offer legal protection. They give comfort to patients. They satisfy typical IRB requirements. They provide a useful checklist for study protocols. A clinician will want to refer to GCP in the context of any article, post or conference presentation based on a study design and/or results.InCytes™, Circles And GCPMuch of GCP depends on proper, auditable record-keeping. This and other GCP elements are accommodated by inCytes™ and associated processes.‍Reference Materials https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3097692/pdf/biij-04- e5.pdf. (Historyof GCP.)https://www.fda.gov/media/174819/download. (FDADecember 2023 Draft Guidance on real-world evidence studies.)https://www.ich.org/page/efficacy-guidelineshttps://www.youtube.com/watch?v=6pAtb4X1UPU (FDA presentation on data integrity.)https://www.fda.gov/about- fda/center-drug-evaluation-and- research-cder/good-clinical-practicehttps://www.fda.gov/science-research/clinical-trials-and-human-subject-protection/regulations-good- clinical-practice-and-clinical-trialshttps://www.fda.gov/science-research/clinical-trials-and-human-subject-protection/good-clinical-practice-gcp-inspection-collaboration-international-regulators-drug-development
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Why Track Outcomes. How To Do So Properly

Article
May 15, 2024
The large majority of clinicians do not track outcomes. Even in large academic medical centers, meaningful outcomes capture is limited. Given the intrinsic importance of outcomes monitoring, this failure is surprising. This article will explain why to capture outcomes and how to do it properly
TABLE OF CONTENTS THE REALITY ABOUT PROPER OUTCOMES CAPTURE 3 PROPER OUTCOMES CAPTURE IS RARE 3 FORMS OF OUTCOMES TRACKING 3 Anecdotal 3 Outcomes Only 3 Poor Transparency/Integrity 3 Clinically Irrelevant 3 Biosensors 3 THE UNFORTUNATE CONSEQUENCES 3 Evidence-Based Medicine? 3 Standards of Care? 4 Value-Based Care? 4 Health Equity? 4 WHY TRACK OUTCOMES 4 CLINICAL DECISION-MAKING 4 REIMBURSEMENT 4 PROFESSIONAL FULFILLMENT 5 REGULATORY/LEGAL COMPLIANCE 5 DEMOCRATIZING RESEARCH 5 PATIENT ENGAGEMENT 5 FINANCIAL AND REPUTATIONAL VALUE 5 HOW TO TRACK OUTCOMES 6 GOOD CLINICAL PRACTICE 6 ASK THE RIGHT QUESTIONS 6 COLLABORATE 6 TRANSPARENT AND ACCESSIBLE PUBLICATION 6 OTHER CONSIDERATIONS 6 VALUE TO THE CLINICIAN 6 Data Ownership 6 Data Monetization 7 MINIMAL CLINICAL BURDEN 7 TOTAL COST 7 ENDNOTES 7 THE REALITY ABOUT PROPER OUTCOMES CAPTURE Proper Outcomes Capture is Rare The large majority of clinicians do not track outcomes. Even in large academic medical centers, meaningful outcomes capture is limited. Given the intrinsic importance of outcomes monitoring, this failure is surprising. There are multiple reasons explaining healthcare’s poor record of clinically significant outcome capture. These include cost, lack of incentives, insufficient time, administrative burden, perceived complexity, and poor patient compliance. Forms of Outcomes Tracking Patients and physicians frequently see reference to “clinically proven”, “long-term efficacy” and similar claims implying validated GCP outcomes capture. These claims rarely withstand scrutiny. The reality of claims allegedly based on outcomes can be summarized as follows. Anecdotal Some claims are in essence based on word-of-mouth (including among providers), online case histories, testimonials, or similar forms of anecdotal “evidence”. Outcomes Only “ePROs” and other forms of surveys are easily available. However, their use by clinicians is infrequent, and patient compliance is poor. Moreover, these are poorly correlated (if at all) with the specific clinical interventions and patient populations needed to derive useful causal relationships. Poor Transparency/Integrity Healthcare is awash with data. Registries, journal articles, clinical trials, meta-studies, research files, etc. Most of these, however, suffer from limited accessibility, incompleteness, and the inability to validate/audit the underlying data. Clinically Irrelevant EMR platforms are principally dedicated to CPT codes and similar reimbursement schema. Patient quality surveys reflect subjective satisfaction. Re-admission rates, RVUs, facility utilization may provide some information on the “value” part of value-based care, but in practice do little to support everyday clinical-decision-making. Biosensors Apple watches, Pelotons and similar health outcome sources are already widely used by consumers/patients. More clinically sophisticated biosensors will soon become commonplace. These represent valuable outcomes datasets, but they are only rarely anchored to diagnoses, treatment protocols or well-structured clinical/scientific hypotheses. The Unfortunate Consequences Evidence-Based Medicine? For over a century, “evidence-based medicine” has been — in principle — a central tenet of medical education and care. By definition, evidence-based medicine should be grounded on standardized patient outcomes closely correlated to a specific condition and treatment protocol. However, in reality, genuine GCP outcomes tracking is typically relegated to premarketing approvals for medical products or other highly limited contexts. Standards of Care? Many of today’s “standards of care” are backed by poor levels of evidence. Moreover, in an era of personalized medicine one-size-fits-all standards of care are inapplicable to most situations. They fail to account for co-morbidities, differences among patient population groups, new medical science, facilities access, a patient’s ability to pay, and other considerations. Value-Based Care? VBC has been a goal of payers, providers, and patients for decades. The “care” in VBC refers to quality care personalized to the patient’s condition and objectives. The “value” can, in theory, be whatever the patient and provider wish. At its most impactful, however, value should equal superior and predictable long-term outcomes compared with clinical baselines. To date, genuine “value-based care” and “health equity” largely remain laudable goals rather than reality. Health Equity? Access to health care varies widely by location, income, education, and other factors. Prevalence of conditions, and outcomes for a given treatment protocol, can vary widely according to gender, race, age, and other factors. Health equity and social determinants of health are major objectives in modern healthcare delivery. However, without outcomes tracking specific to particular population groups, those objectives cannot realistically be achieved. WHY TRACK OUTCOMES Clinical Decision-Making Proper outcomes capture allows a clinician to make better evidence-based decisions regarding a patient’s care. That decision-making is not limited to a single visit or intervention; it can continue throughout the outcomes reporting period. It allows the clinician to identify potential adverse events, suggest supplemental procedures where appropriate, and maintain patient engagement in a meaningful way. Reimbursement Inevitably, healthcare’s fee-for-service revenue model will be replaced by value-based care. VBC can take many forms. Today, it is based principally on readmission rates, broadly defined population panel metrics, and even patient quality surveys. Increasingly, however, reimbursement rates will be determined by validated long-term outcomes measures This is already happening at the payer level. For example, CMS is tying IQR reimbursement to patient reported outcomes in the context of total knee and hip arthroscopies. This government payer focus on patient outcomes will certainly be extended in the near future to other specialties and conditions. Professional Fulfillment “Burnout”, depression, and other forms of professional dissatisfaction are well reported among physicians. A root cause is loss of clinical autonomy. A practitioner can regain a strong sense of professional independence and growth by posing thoughtful clinical questions, and monitoring standardized patient outcomes to develop causal correlations for his particular patient panel. Regulatory/Legal Compliance Providers have always operated in a complex legal and regulatory environment. That environment will only become more challenging in the years to come. Whether a sole practitioner or a large academic medical center, proper outcomes capture is an important tenet of good clinical practice. As such, it can provide key documentary support for regulatory compliance, marketing claims and litigation defense. Democratizing Research Impactful medical research depends on posing clinically relevant hypotheses, and developing validatable datasets generating statistically significant correlations. Longitudinal and standardized outcomes measures are a key element of those correlations. It is the busy clinician who can pose the most clinically relevant questions. Similarly, it is her patients who are best able to provide validated long-term outcomes corresponding to those questions. If cost and administrative burden can be minimized, then those datasets – often called real-world evidence – can democratize medical research for the benefit of all healthcare constituencies. Patient Engagement Patients are increasingly educated about their providers, treatment protocols and other healthcare options. They want to be involved in their healthcare decisions. They also want to monitor their outcomes, with or without the support of their physician. Financial and Reputational Value Monitoring outcomes not only reduces legal/regulatory risk (and therefore costs), but creates multiple value categories. These include materials for conference presentations and articles, as well as proprietary datasets supporting investigator fees, intellectual property, and licensing revenues. HOW TO TRACK OUTCOMES Good Clinical Practice Usable healthcare outcomes capture is not a matter of sending out perioding surveys. It requires appropriate and consistent assessment scores, regular and high patient compliance over at least a year, auditable correlations between clinical/scientific questions and the outcomes, and statistical significance. Ask The Right Questions Outcomes unrelated to specific clinical/scientific hypotheses are of little value. In the words of the FDA, they are not “fit-for-purpose”. Collaborate The most powerful statistical significance is based on a large “n” dataset comprising coherent and longitudinal data. Moreover, to have real clinical impact, those data should be collected across – and be capable of being parsed among – several patient population groups. This requires the efficient collaboration of multiple investigators in multiple locations. Transparent and Accessible Publication Properly structured outcomes datasets represent important information for practitioners and patients around the world. They deserve to be communicated promptly and widely allowing those practitioners to improve care for their patients. Moreover, because such datasets have been generated on the basis of good clinical practice, the authors’ data can be thoroughly validated. OTHER CONSIDERATIONS There are several approaches to track outcomes in a GCP and impactful manner. However, there are certain factors to be considered in choosing among those approaches. Value To The Clinician Data Ownership Who owns the aggregated datasets representing longitudinal outcomes is an important but often ignored question. It should be the clinician, but often is not. Data Monetization Ownership is important because outcomes datasets have value. They are copyrightable and licensable in their own right. They may contain the foundation of monetizable intellectual property. In the fast-advancing world of generative artificial intelligence, those datasets represent valuable sources for training large language models and other AI applications. Minimal Clinical Burden To have value, outcomes datasets must be based on good clinical practice. However, GCP can interrupt clinical flow, and represent substantial administrative burden. This need not be the case. Total Cost EMRs and other health data systems are already too expensive for many provider groups. (Hospital bankruptcies attributed to EMR installations are not uncommon.) As indicated, outcomes datasets can represent substantial value for provider groups. For them to represent a profit center however, the total cost should be taken into account. That cost includes initial and ongoing financial charges, as well as necessary support personnel, interrupted clinical flow and similar factors.
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Circles Newsletter_April 2024

Client News
April 25, 2024
Real-world evidence (RWE) is at the heart of value-based care. In this newsletter, we summarize recent Real-World Evidence Programs launched by provider groups, manufacturers, and distributors, and highlight several major use case categories.
Welcome Real-world evidence (RWE) is at the heart of value-based care, and arguably the most important category of health data in the 21st century.Circles harness the power of RWE to create proprietary and statistically significant datasets in the context of any medical specialty, and representing value to all healthcare constituencies. In the Select Client Activities section of this newsletter, we summarize Real-World Evidence Programs recently launched by provider groups, product manufacturers, and distributors. In Select Company Activities, we highlight several major use case categories.Please contact us to discuss how Real-World Evidence Programs can advance your clinical, scientific, and commercial objectives.Select Client Activities ROSM Real-World Evidence ProgramWith eight locations in the Washington D.C. area, ROSM is one of the largest non-surgical orthopedic practices in the country. ROSM has always selected its diverse protocols in an evidence-based manner. It will now broaden that effort by applying focused, real-world evidence strategies against every ROSM clinical intervention.By deploying no fewer than seven Circles, ROSM will own, and generate sustainable value from, many rich, statistically significant, and tightly integrated datasets. Dr. Imran Siddiqui, Director of Clinical Operations at ROSM, says:“RegenMed shared our strategic vision, and with its turnkey platforms and deep regenerative medicine experience, was the natural partner to help us design and expand this broad initiative.”For more information, including how to join ROSM’s Circles, see here.EmCyte™ Real-World Evidence ProgramEmCyte Corporation is a world leader in the design, manufacture, and distribution of integrated systems for platelet rich plasma, bone marrow cell concentrate, adipose concentrate, bone marrow harvesting, and PRP analysis. EmCyte also supports Gulf Coast Biologics, led by Peter A. Everts, PhD, FRSM. GCB is a separate entity dedicated to the education and training of doctors from around the world in the evidence-based clinical use of biologics-based therapies.EmCyte and GCB have long been using the Circles platform to develop clinically and statistically significant datasets supporting various biologics treatments for knee and shoulder pathologies. (These have included patients presenting with bi-lateral conditions.)Dr. Everts says: “I have been working with RegenMed for almost two years on our “GCB Circles Program” successfully. I believe they have more to offer than any other company with regard to technological tools, costs, and flexibility.The platform has accommodated our highly specific research objectives. Customer engagement and feedback have been overwhelmingly positive. We have already generated valuable, statistically significant data for up to one year.” For more information on the EmCyte and Gulf Coast Biologics Real World Evidence Program, see here.Summus Medical Laser Real-World Evidence ProgramSummus Medical Laser® has partnered with RegenMed to establish a comprehensive Real-World Evidence Program. The program will support thousands of providers around the world by developing and sharing best practices for improving patient recovery and care. The RWE Program will expand Summus Laser's Class IV Laser Therapy research to generate validated and statistically significant datasets that will be used to enhance patient care, outcomes, and to further product innovations. Pete Cousins, the COO of Summus Medical Laser, says: "We look forward to unlocking new frontiers of innovation and patient care through the RWE Program. Collaborating with RegenMed presents an invaluable opportunity to accelerate and push the limits of laser therapy and its capabilities, ultimately advancing medical science and enhancing patient outcomes."For more information, including how to join the Summus Medical Laser Circles, see here. Breakthrough Regenerative Orthopedics Launches SI Joint CircleTimothy Mazzola, M.D practices non-operative orthopedic medicine at Breakthrough Regenerative Orthopedics. For patients presenting with pain and dysfunction in the lower back, hip, and knee regions, he focuses on instability of the sacroiliac (SI) ligament and its myofascial attachments. Dr. Mazzola’s Circle will evaluate the efficacy of ultrasound guided PRP and MFAT injections for such patients. Baseline and longitudinal outcomes measures will incorporate his proprietary physical examination measurement, “Millimeters of Motion,” to quantify SI ligamentous laxity. Dr. Mazzola says:“Breakthrough Regenerative Orthopedics is proud to partner with RegenMed to collect real world evidence on treating SI dysfunction and ligamentous laxity. RegenMed has become our go-to partner for clinical data collection based on their commitment to user-friendly, customer-focused data collection solutions for busy clinicians like ourselves.”Dr. Mazzola will also be delivering the keynote address at the upcoming C3 Annual Summit: Treatment Strategies for Lumbopelvic Pain and Dysfunction.More details on Dr. Mazzola’s Circle, as well as the opportunity to participate, can be found here.ISNS Launches Consumer-Facing Real-World Evidence Program For NutraceuticalsThe International Science and Nutrition Society is an international organization comprising physicians, scientists, and other experts in complementary and integrative medicine. Its advances science-based knowledge in nutrition, nutraceuticals, phytology, and ecology. ISNS works closely with RootBrands in preparing and distributing nutraceuticals and other health/wellness products throughout North America and Europe.ISNS and RootBrands have launched a Real-World Evidence Program to track long-term outcomes against customer reported baselines. The Circles design and data analyses will involve ISNS clinicians and scientists. Outcomes assessments include BMI, SF-12 Mental, SF-36 Emotional, SF-12 Physical, and SF-36 Energy/Fatigue.For more information on the ISNS Circles, see here.Select Company ActivitiesCo-Marketing ProgramsCircles create proprietary and statistically significant datasets representing value to all healthcare constituencies. Categories of value include clinical decision-making, product development, regulatory approvals, monetization, competitive differentiation, and patient and HCP engagement.Circles Co-Marketing Programs accelerate that value for both provider and industry Clients. Program elements include:Regular Client ReportsCircle AcademiesCircle Member RecruitmentPublicationContinuity of CareThird-Party SupportDataset MonetizationTo find out more about Circles Co-Marketing Programs, see here.Types of Real-World Evidence ProgramsReal-World Evidence Programs deliver clinical, scientific, and financial value for all healthcare constituencies. Recent articles published by RegenMed and covering various use cases include: CREATING LICENSABLE REAL-WORLD EVIDENCE DATASETS CIRCLES FOR OTC PRODUCT MANUFACTURERS CIRCLES FOR INDEPENDENT PROVIDER GROUPS CIRCLES FOR SUSTAINED MENTORING BY CLINICAL LEADERS REAL-WORLD EVIDENCE PROGRAMS FOR ACADEMIC MEDICAL INSTITUTIONS REDISCOVERING AND RE-IMAGINING MEDICAL RESEARCH CIRCLES FOR ASSESSMENT OF COGNITIVE IMPAIRMENTCopyright © 2024 Regenerative Medicine LLC
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Summus Medical Laser® Press Release

Post
April 24, 2024
Summus Medical Laser® has partnered with RegenMed to establish a comprehensive Real-World Evidence Program. The program will support thousands of providers around the world by developing and sharing best practices for improving patient recovery and care. The RWE Program will expand...
Summus Medical Laser® has partnered with RegenMed to establish a comprehensive Real-World Evidence Program. The program will support thousands of providers around the world by developing and sharing best practices for improving patient recovery and care. The RWE Program will expand Summus Laser's Class IV Laser Therapy research to generate validated and statistically significant datasets that will be used to enhance patient care, outcomes, and to further product innovations. Summus' RWE Program builds upon recent FDA guidance on the use of RWE to support regulatory decision-making for medical devices. The program is based on Circles, RegenMed's patented, technical platform and turnkey process for generating clinical, scientific, and financial value from real-world evidence. The program's initial Circles will collect and analyze real-world evidence on peripheral neuropathy from dozens of providers in the U.S. In the coming months, the program will grow to include additional pathologies and providers outside of the U.S. Dr. Phil Harrington, an internationally recognized expert in laser therapies, will be instrumental in developing the program's clinical surveys and outcomes assessments. Dr. Harrington says, "I am excited to be working with RegenMed in executing the RWE Program. This will help to expand Summus' clinical and scientific correlations and reach a broader team of providers to collect valuable data." Pete Cousins, the COO of Summus Medical Laser, adds: "We look forward to unlocking new frontiers of innovation and patient care through the RWE Program. Collaborating with RegenMed presents an invaluable opportunity to accelerate and push the limits of laser therapy and its capabilities, ultimately advancing medical science and enhancing patient outcomes." About Summus Medical Laser: Summus Medical Laser is a renowned leader in the laser therapy industry, providing laser products to over 51 countries that have resulted in millions of treatments performed worldwide. With a strong commitment to continued innovation, reliable stateside customer service, and growing brand awareness, Summus Medical Laser is devoted to empowering healthcare professionals to provide optimal patient care through the use of advanced laser therapy. To learn more, visit https://www.summuslaser.com. About RegenMed: RegenMed is the category leader in developing and executing Real-World Evidence Programs for provider groups, medical societies, and medical product manufacturers around the world. Those RWE Programs are redefining and democratizing impactful medical research. More information can be found at https://www.rgnmed.com/. Click here to review the initial Peripheral Neuropathy Circle SOURCE Summus Medical Laser
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Breakthrough Regenerative Orthopedics Launches SI Joint Circle

Post
April 24, 2024
Timothy Mazzola, M.D., a triple-board certified physician, practices non-operative orthopedic and regenerative medicine at Breakthrough Regenerative Orthopedics in Boulder, Colorado. He designed a Circle-based study to “Evaluate Efficacy of US-Guided PRP and MFAT Injections for Patients with ...
Timothy Mazzola, M.D., a triple-board certified physician, practices non-operative orthopedic and regenerative medicine at Breakthrough Regenerative Orthopedics in Boulder, Colorado. Many of his patients present with pain and dysfunction in the lower back, hip, and knee regions. He has recognized that treatment of the secondary symptomatic areas fails to address the primary root cause -- instability of the sacroiliac (SI) ligament and its myofascial attachments. Dr. Mazzola’s has therefore designed a Circle-based study to “Evaluate Efficacy of US-Guided PRP and MFAT Injections for Patients with Abnormal SI Ligamentous Laxity”. Baseline and longitudinal outcomes measures in this Circle will incorporate a unique physical examination objective measurement, “Millimeters of Motion,” to quantify SI ligamentous laxity. More details on Dr. Mazzola’s Circle, as well as the opportunity to participate, can be found here. Dr. Mazzola will also be delivering the keynote address at the upcoming C3 Annual Summit: Treatment Strategies for Lumbopelvic Pain and Dysfunction. In addition to Dr. Mazzola’s SI Joint Circle, topics at the conference will include:  Labral tears, hip pain and SIJ dysfunction – what do these problems have in common and which one came first.  How to stabilize hypermobile patients and train the core appropriately.  How does one assess stretch/flexibility without destabilizing ligaments, decreasing fascial integrity, or weakening muscle.  How to treat fascia of the lumbopelvic girdle to enhance whole body movement.  Which regenerative treatments and targets can more effectively stabilize and strengthen the lumbopelvic girdle. Each of these questions deserves answers based on real-world evidence. As he is doing with his Abnormal SI Ligamentous Laxity study, Dr. Mazzola and other musculoskeletal practitioners around the world are likely to collect that evidence through Circles in the coming months. For more information regarding Dr. Mazzola’s SI Joint Circle, the C3 Summit, or to undertake your own Circle, please contact us.
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