ICH-E20, Regulators, and False Choices

In this episode of "In the Interim…", host Dr. Scott Berry undertakes a detailed, methodical critique of ICH-E20 draft guidance language as applied to adaptive clinical trial design. Focusing on an innocuous but corruptible paragraph in Section 3.1, Scott scrutinizes the logic behind regulatory reluctance to appreciate multiple or complex adaptations in confirmatory trials. Drawing on extensive experience, he highlights how such restrictive interpretations do not reflect practical development realities, instead setting up “false choices” where alternative designs desired by regulators are infeasible. Through operational scenarios—including the SEPSIS-ACT trial, an enrichment design, and sample size re-estimation examples—Scott illustrates the empirical benefits of seamless and multi-adaptive trials for sponsors, patients, and regulators. Technical discussion addresses misconceptions about complexity and bias and stresses the value of presenting realistic alternatives when engaging with regulatory authorities. The episode ultimately encourages a more nuanced dialogue to advance efficient and scientifically robust clinical trials.

Key Highlights

• Discussion of ICH-E20 section 3.1 guidance and its operational impact on adaptive designs.
• Dissection of “false choice” dilemmas in regulatory interactions, referencing real adaptive trial submissions.
• Case-based examples: SEPSIS-ACT, enrichment, and sample size adaptation trials.
• Highlighting myths regarding bias and operational burden from multiple interim analyses.
• Emphasis on practical strategies for more effective regulatory communication about adaptive trials and realistic alternatives.

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