Independent · non-commercial · publishes on a quarterly cycle|Current cycle 2026 Q3
Compound Evidence InstituteEvidence synthesis · established 2023Graded assessments of compounds, trials, methods and supply
Document set current to 30 July 2026
Public comment period · §2

Draft synthesis: The consequences of a wholly… — submissions

The 10 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-110/2
Series
Public comment period
Version
1.0
Published
18 Oct 2024
Last reviewed
18 Oct 2024
Next review
18 Oct 2025
Identifier
10.71829/cei.cp.110
Certainty
Not rated
Cycle
2024 Q3
Window
13 Jul 2024 – 11 Sep 2024
Status
Closed
Submissions
10

§2Submissions and responses

10 submissions were received. Each is published in full below with its declared interest, the secretariat response and the disposition. The Institute publishes submissions it did not accept in the same form as those it did.

Dr Odalys Thorsby-Nakamura, MSc (Epidemiology) Academic clinical pharmacology unit
DRAFT-SPONSOR-COND/005 received 17 Jul 2024

Results at materially different follow-up durations are pooled

Contributing trials report the outcome at durations ranging across more than a year. The draft pools them into a single estimate. The respondent states that a mean at one duration and a mean at another are not estimates of the same quantity when the effect is still changing.

The respondent proposes that estimates be reported by duration band.

Declared interest. Holds a patent relating to a delivery technology referenced in the draft.
Secretariat responseAccepted09 Oct 2024

The secretariat accepts this submission. Pooling across durations assumes a plateau the contributing trials do not demonstrate.

Estimates are now reported by duration band, with the number of contributing trials and participants in each band stated, and no estimate is pooled across bands.

Dr Ursina Ellsworth-Vance, MSc, CChem Academic sports-medicine and anti-doping laboratory
DRAFT-SPONSOR-COND/008 received 28 Jul 2024

The document should state what a reader ought to do

The draft assesses evidence and stops. The respondent, a practising clinician, states that a reader arriving at the document with a decision to make is left to convert an assessment into an action without help, and proposes that each document close with a recommendation.

The respondent argues that other evidence bodies issue recommendations and that declining to do so transfers the difficult part of the work to the reader.

Declared interest. Employed by a national competent authority. This submission is made in a personal capacity and does not represent the position of that authority.
Secretariat responseNot accepted25 Sep 2024

The secretariat does not accept this submission, and records that the point is a reasonable one rather than a misunderstanding.

The Institute assesses evidence and does not issue recommendations, because a recommendation embeds values and a resource context that the Institute does not hold and cannot state. That constitutional limit is published on the methodology page and is not varied by consultation. The submission remains published in full.

Dr Piotr Hollingworth, MPharm, MRPharmS Academic nephrology unit
DRAFT-SPONSOR-COND/007 received 30 Jul 2024

The search strategy as published cannot be re-run

The strategy is described in prose rather than reproduced as executed. The respondent, an information specialist, attempted to reconstruct it and obtained a different yield, which may reflect the reconstruction or the original.

The respondent proposes that the strategy be published line by line as run in each database, with the interface, the date and the number of records retrieved at each line.

Declared interest. No financial interest. Has published a systematic review reaching a different conclusion from the draft, which the respondent declares as a non-financial interest.
Secretariat responseAccepted14 Oct 2024

The secretariat accepts this submission. A strategy that cannot be re-run cannot be checked, and a review whose search cannot be checked rests on an assertion.

The full line-by-line strategy for each database is now published with the interface, the run date and the yield at each line, and the total retrieved is reconciled against the screening flow.

Dr Yehudit Quaresma, PharmD, MSc National medicines information service
DRAFT-SPONSOR-COND/002 received 04 Aug 2024

A sortable table implies a comparison the underlying data do not support

The draft presents a sortable table whose columns are drawn from sources of differing quality. The respondent states that sorting on such a column produces an ordering that looks like a ranking and is not one.

The respondent proposes that sorting be disabled on any column whose values are not commensurable.

Declared interest. No interest to declare. The respondent is a graduate student and states that the submission forms no part of any assessed work.
Secretariat responseNoted, no amendment09 Oct 2024

The secretariat notes this submission and records that the point is correct in principle.

No amendment arises here because every sortable table in the document set already carries a standing statement above it that the ordering is not a ranking and that the values in each column are commensurable only where the column header says so. The proposal to disable sorting was considered and not adopted, because a reader who cannot sort a table generally sorts it elsewhere and without the statement.

Dr Oisín Rautavaara, MD, MPH Primary-care research network · industry submission
DRAFT-SPONSOR-COND/010 received 05 Aug 2024

Two factual descriptions of the sponsor's programme are inaccurate

The submission is made on behalf of the marketing-authorisation holder and is confined to two matters of fact. The draft describes a trial as terminated where the sponsor closed it at a pre-specified interim analysis, and gives a dose in a unit that does not match the approved labelling.

Supporting documentation, comprising the published trial report and the current summary of product characteristics, accompanied the submission. No view is expressed on the certainty ratings, which the sponsor considers a matter for the assessment committee.

Declared interest. Is an employee of a marketing-authorisation holder for a compound named in the draft. This submission is made on behalf of that company and is identified as an industry submission throughout.
Secretariat responseAccepted25 Sep 2024

The secretariat accepts this submission. Both points are matters of fact, both were checkable against documents the Institute holds, and both were wrong in the draft.

The trial status now reads as completed at a pre-specified interim analysis, with the analysis identified, and the dose is stated in the unit used in the approved labelling. The submission is identified as an industry submission on its face in accordance with the conflicts policy.

Dr Anselm Mountstephen, MD, FRCS Academic peptide-chemistry group
DRAFT-SPONSOR-COND/004 received 15 Aug 2024

The same concern is used to downgrade in two domains

The draft downgrades for both indirectness and imprecision citing the same feature of the contributing trials. The respondent states that this double-counts a single concern and produces a rating lower than the framework supports.

The respondent proposes that the rating be raised by one level.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted in part09 Oct 2024

The secretariat accepts this submission in part. The double count is real in one of the two outcomes identified and not in the other, where the two domains rest on different features.

The rating for the first outcome has been raised by one level and the domain reasoning restated, and the reasoning for the second has been rewritten to make clear that the two downgrades rest on different features of the evidence.

Dr Gaspard Wintringham, PharmD, MSc National medicines information service · industry submission
DRAFT-SPONSOR-COND/009 received 16 Aug 2024

The document should not describe uses outside the approved indication

The submission is made on behalf of a marketing-authorisation holder. It states that the draft describes uses of the compound that fall outside the approved indication, that such uses are not supported by the sponsor, and that describing them may be read as legitimising them.

The sponsor asks that the sections concerned be removed, or in the alternative that they carry a prominent statement that the sponsor does not support such use.

Declared interest. Is an employee of a marketing-authorisation holder for a compound named in the draft. This submission is made on behalf of that company and is identified as an industry submission throughout.
Secretariat responseNot accepted09 Oct 2024

The secretariat does not accept this submission. The Institute records what is supplied and what is used, because a reader encountering a compound outside a regulated route is the reader most in need of an assessment of the evidence for it.

The sections remain. Every such section already states the regulatory status of the use described and states that the evidence for it is assessed separately from the evidence for the approved indication. The submission is published in full and identified as an industry submission.

Dr Yolanda Norrington-Bhatt, BPharm, PhD National pharmacovigilance centre
DRAFT-SPONSOR-COND/001 received 24 Aug 2024

Patient-reported outcomes are collected by the trials and not reported by the review

The respondent, a trustee of a patient organisation, states that several contributing trials measured quality of life and function and that the review reports neither, having selected outcomes on the basis of what could be pooled.

The respondent proposes that these outcomes be reported narratively where they cannot be pooled.

Declared interest. Employed by a health technology assessment body that has issued guidance on a compound named in the draft.
Secretariat responseAccepted in part09 Oct 2024

The secretariat accepts this submission in part. The outcomes are reported narratively. The proposal to pool them is declined because the instruments used are not comparable and pooling would produce a figure with no interpretation.

Patient-reported outcomes measured by any contributing trial are now reported narratively by instrument, with the instrument named and its minimum important difference stated where one is published, and the absence of a pooled estimate explained.

Sigrún Vercingetorix, PhD (Analytical Chemistry) Patient advocacy organisation
DRAFT-SPONSOR-COND/006 received 29 Aug 2024

A surrogate outcome is used as the anchor without validation evidence

The anchor outcome in the draft is a surrogate. The respondent states that the relationship between the surrogate and the outcome a decision turns on is itself an evidential question, and that the draft assumes it.

The respondent proposes that no surrogate serve as an anchor.

Declared interest. Is a trustee of a patient organisation that has received a restricted educational grant from a manufacturer in the class under assessment.
Secretariat responseAccepted in part09 Oct 2024

The secretariat accepts this submission in part. The anchor is retained where the surrogate is the only outcome the contributing trials measured, and the validation question is addressed rather than assumed.

Where the anchor is a surrogate, the synthesis now states the evidence for the surrogate relationship, rates it separately, and downgrades the anchor rating for indirectness accordingly rather than carrying the surrogate as though it were the outcome of interest.

Dr Wilhelmina Oppenheimer-Ade, MD, MPH Primary-care research network
DRAFT-SPONSOR-COND/003 received 07 Sep 2024

The document is unreadable without specialist training

The respondent, a trustee of a patient organisation, states that the draft is written for a reader who already understands certainty grading, and that the people most affected by the subject matter will not reach the assessment at all.

The respondent proposes a plain-language summary at the head of every document, written to the same standard of accuracy as the document itself and not as a promotional abstract.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted in part09 Oct 2024

The secretariat accepts this submission in part. A plain-language summary is added. The proposal that it replace the technical abstract is declined, because the abstract is the part of the document other assessors read and cite.

Every document now opens with a plain-language summary of not more than 150 words, placed above the technical abstract and carrying the same certainty language, so that the two cannot diverge.

References cited on this page

References are numbered in order of first citation in this document. Each superscript in the text links to its entry below.

  1. International Organization for Standardization. ISO/IEC 17025:2017 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC Standard 2017;3rd edition. identifier not held by the Institute

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