Epoch is a permissible variable in CDISC, but it’s also a variable requested by FDA in CDER Common Data Issues document and should be included in the dataset for these domains:
This is an example of the very bad practice that a stakeholder is changing the standard after its publication, where it had the opportunity to request for the incorporation of the variable during the review period. How can we trust standards when a stakeholder deviates from it and creates its own “dialect”?
Thanks, helpful answer, and something that’s not easy to discover from the FDA website! Downloaded OpenCDISC just a couple of days ago and already it’s proving very helpful!
SDTM 3.1.3 was published after this guidance. Do you know if CDISC simply chose not to change EPOCH’s core value from Perm to Req for certain domains ?
Think of the SDTM 1.x as the generic model for the 3 general observation classes: FINDINGS, INTERVENTIONS, EVENTS. It defines the blue print and superset of variables available for those classes. The order of variables is a general starting point.
The IG then inherits and implements a generic class as a domain while supplying domain specific semantics (controlled terminology assignments, assumptions, prohibiting use of some variables). In some cases, the domain will override the variable order. in the case where a variable is not mentioned and not prohibted, its order is inherited from the parent class.
This is why they publish two separate docs. Base Parent (Model) and IG (instance of model).
SDTM 1.x is implemented by the following:
SDTM-IG 3.x (clinical/human)
SEND-IG 3.x (non-clinical/toxicology/animal)
AP-IG 1.0 (Associated Persons)
MD-IG 1.0 (Medical Devices)
PGx-IG 1.0 (Pharmacogenomics/genetics)
TA-UGs (currently over 20 Therapeutic Area User Guides)
“..variable EPOCH should be included for every clinical subject-level observation … This will allow the reviewer to easily determine during which phase of the trial the observation occurred as well as actual intervention the subject experienced during that phase”
My take / long answer…
while MH is “supposed” to be collected during screening phase, perhaps a use case will develop where it is collected throughout the study. Perhaps for early stage alzheimer’s. The other use case is if some database warehouse or tool wants to stack all EVENTS observations into one table. Having EPOCH populated for medical history will allow a consistentency in the combined view. Finally, at any point during a study (especially for pediatric studies) it’s possible someone could simply offer up more medical history than what they previously recalled. Or a parent/guardian recalls something signficant about their child in a study which was not previously recorded.
Bottom line, from a tech perspective (mapping), it’s easy just to hardcode this variable to SCREENING if that is your case and move on to more challenging endeavors.
How would you populate the EPOCH variable in the CM domain in the event that dates are partially known? Does one needs to impute dates in order to determine the EPOCH?
What if the CM dates indicates that the medication was taken long before the study screening period? for example few years before the study ever conducted, will it be accurate to mention the EPOCH as screening period?
partial dates: do NOT impute EPOCH (imputations are not allowed in SDTM).
medication taken long time before study start:
EPOCH is an extensible codelist. So you can add your own terms. For example, you could add “PRESCREENING” to the codelist in the define.xml (do not forget to add the attribute def:ExtendedValue=“Yes”) to the “CodeListItem” or “EnumeratedItem” element, and use that for all dates (also partial ones) that are clearly before the study start date. For example “2015-01” is clearly before the study start date “2015-02-01”.
While MH is typically collected during screening, the timing of the events captured in MH is, by definition, before the screening epoch (medical events occurring during or after screening are AEs).
Epoch timing periods are by definition during the study. Epoch describes the timing of the occurrence (event/intervention/finding), not the collection of the occurrence. By definition, events occurring prior to the first defined epoch (generally screening) cannot have a value for epoch.
From the above two comments, it is expected that MH events would not have a value for the EPOCH variable. As EPOCH is a permissible variable, when null for all records it should be omitted from the dataset.
This is also true for all pre-study records, so while the EPOCH variable should be in CM, it should not be populated for prior medications taken historically before the study.
Pretty sure the current implementation of checks does not require EPOCH in MH. I’d be cautious with concepts like pre-screening epochs. Unless supported by study materials, this could be a misapplication of the epoch concept.
Regards,
Carlo
Here is a 1:1 copy of what is in the latest “Study Data Technical Conformance Guide” (October 2015):
“Please include the variables EPOCH for every clinical subject-level observation (e.g., adverse events, laboratory, concomitant medications, exposure, vital signs). This will allow the reviewer to easily determine during which phase of the trial the observation occurred (e.g., screening, on-therapy, follow-up), as well as actual intervention the subject experienced during that phase.. Inclusion of ELEMENT and ETCD (element code) is desired as well, to help reviewers understand timing of events whose durations span multiple epochs. However, because of implementation challenges associated with this request, CDER is not yet requiring these for submission of SDTM data”. (see http://www.fda.gov/downloads/ForIndustry/DataStandards/StudyDataStandards/UCM384744.pdf).
So the previous statement of one of the contributors “… it’s also a variable requested by FDA in CDER Common Data Issues document and should be included in the dataset for these domains” looks like a complete overinterpretation of the FDA’s position.
“Please include …” does not sound like an obligation to me, and “e.g. adverse events …” does not sound like a complete list (MH is even missing in that list). So I think this rule should either disappear or be downgraded to “INFO”.
BTW, reviewers should be able to derive EPOCH themselves - it is really piece of cake to do so.