December 17, 2016, is less than five months away.

As we all know by now, studies starting on or after that date must be submitted to the Food & Drug Administration electronically. They must also utilize the most-recent FDA-acknowledged version of data standards.

To support the latter point, FDA is requesting that sponsors submit a Study Data Standardization Plan (SDSP) as part of the IND application.

With time running out quickly, two big questions have taken on a new urgency:

Have you ever wondered how Pinnacle 21 implements rules for ADaM validation? Below is a list of commonly asked questions.

1. Does Pinnacle 21 implement the validation checks published by CDISC?

   Yes, Pinnacle 21 rules are an implementation of CDISC validation checks. In fact, P21's Michael DiGiantomasso and Sergiy Sirichenko are both active members of the CDISC ADaM Compliance subteam. Since 2011, the subteam produced 4 versions of CDISC validation checks, with Pinnacle 21 supporting the industry by releasing 7 updates to the open source rule implementations. This close collaboration between Pinnacle 21 developers, ADaM team core members, and representatives from across the industry is what makes it possible to continuously improve rule definitions and implementations.

2. Why do the message text and rule counts differ?

   CDISC check definitions are designed to serve as requirements to machine implementation, "a programmable test, written such that an affirmative response represents a failure of the requirement. This text is intended for use as a requirement specification which could be implemented in a variety of programming languages". P21's rule messages and descriptions, on the other hand, are designed for the end user to help them quickly identify and fix the cause of validation issue.

In late 2014, the FDA announced that, starting December 17, 2016, all new clinical and nonclinical studies must be submitted electronically and contain data in conformance with the standards specified in FDA’s Data Catalog. This is part of an effort to accelerate the regulatory review process.

At the time of this writing, that deadline is only nine months away. So, the big question looms: Are you 100% ready for FDA submission? Because when December 17th comes, any doubt you have may represent a risk of slowing down the review process. More importantly, you’ll be missing out on an opportunity to get your new drug to market faster than ever before.

On November 24th, the Japanese Pharmaceuticals and Medical Devices Agency (PMDA) published its first official list of validation rules for CDISC SDTM, ADaM and Define.xml. These long awaited rules cover conformance, reviewability and quality requirements, as described in the PMDA Technical Conformance Guide on Electronic Study Data Submissions. The rules will ensure that data conform to the standards and support ease of use and meaningful analysis.

The PMDA agency is asking sponsors to validate their study data before submission — using these published validation rules — and either correct any validation issues or explain why they could not be corrected in the data guide. PMDA has introduced new “Reject” rules, which, if violated, will cause the review to be suspended until issues are corrected. PMDA can also suspend review if explanations for certain issues are not provided.

OpenCDISC has begun a rebranding process. The first step in that process, effective immediately, is that our organization will no longer be using the name “OpenCDISC” for any product, service or event.

Going forward, OpenCDISC Community will now be known as Pinnacle 21 Community; and OpenCDISC Enterprise will now be known as Pinnacle 21 Enterprise.

Why? After many years of mutual support and understanding, the CDISC organization has asked us to stop using the name “OpenCDISC.”

What does this mean to you? Ultimately, nothing. The staff at Pinnacle 21 will continue to develop our open source software and make it available to all, free of charge. And we will continue to help and support our users as we always have.

Pinnacle 21 is proud to announce the launch of OpenCDISC Enterprise 3.0, which will be available November 2, 2015. This enhanced, comprehensive, web-based application makes it easier than ever to manage standards compliance over the entire study life-cycle.

Now, instead of validating data right before regulatory submission (and unearthing a world of problems), you can manage it from the beginning: controlling your process, mitigating your risk, and reducing your time to market.

“Continuous Compliance” is Pinnacle 21’s proprietary approach for managing and ensuring consistent data from the moment you design the protocol all the way through to FDA and PMDA submission — and OpenCDISC Enterprise 3.0 is the tool that drives it. The result is an intelligent process that:

• Eliminates risk
• Saves time and money
• Achieves faster FDA approval

Pinnacle 21 is pleased to announce that we’ve been awarded a renewed contract to provide software and services in ongoing support of the FDA’s DataFit program.

According to the FDA’s Center for Drug Evaluation and Research (CDER), which made the decision:

Pinnacle 21 is honored to announce that our president and CEO, Max Kanevsky, has been named to the PharmaVOICE 100 Class of 2015.

The PharmaVOICE 100 is an annual list that recognizes the year’s most inspiring people in the life-sciences industry — leaders who have made a significant impact on their peers, their colleagues, their companies and their communities, as well as the industry at large.

When CDISC published Version 1.3 of its ADaM Validation Rules, a lot of you wondered what to make of it.

According to CDISC: “Some checks have been reworded for clarification … [and] 75 new checks have been added to cover rules not previously addressed. [These] additional checks cover the addition of checks for Adverse Events (ADAE) and the ADaM Basic Data Structure for Time-to-Event Analyses (BDS-TTE).”

To paint a clear picture of what all this means, and how the industry should respond, Pinnacle 21 hosted a recent webinar on this topic. The webinar — titled, “ADaM Validation Update from OpenCDISC” — provided an overview of these changes, and shared our experience of the most common issues in ADaM submission data observed across the industry.

The 2015 PharmaSUG Annual Conference, in Orlando, Florida, was an important and telling event. Pinnacle 21 was there, as both a presenter and exhibitor. The event drew more than 600 attendees, who generated a wealth of intriguing questions and discussions over the four-day stretch.

If you attended our programs, or witnessed the buzz of activity around the booths, then you saw what we saw: pharmaceutical software users who were eager to learn more about how to navigate FDA regulatory submissions in the months and years to come.

Pinnacle 21 ran two important programs to try to answer some of our attendees’ biggest concerns: