Bayer is fully committed to disclosing information about our planned and ongoing clinical trials. Bayer will also make results of trials in patients public and provide free access to this information on the internet, irrespective of whether the results of a trial for one of our products are positive or negative.
Public disclosure of clinical trial information is done in line with the position of the global pharmaceutical industry associations laid down in the “Joint Position on the Disclosure of Clinical Trial Information via Clinical Trial Registries and Databases" (https://www.ifpma.org/wp-content/uploads/2010/11/Joint-Position-on-Disclosure-of-CT-Info-via-CT-Registries-Revised-Jan2018-vFINAL.pdf).
As a member company of EFPIA and PhRMA, Bayer complies with their declared principles on responsible clinical trial data sharing, which aim to benefit patients and foster scientific discovery. Increased transparency while maintaining patient privacy will ultimately encourage innovation and benefit patients.
Bayer is supporting efforts by the European Medicines Agency (EMA) and the EU Parliament to further increase the transparency of data from clinical studies as laid down in the EMA policy on publication of clinical data for medicinal products for human use and the EU Clinical Trials Regulation EU No 536/2014.
Bayer has implemented a thorough monitoring and quality control process to ensure that high standards for transparency of clinical trial information for Bayer medicines are fully met and that information on clinical trials as outlined in this policy is publicly disclosed in time and is of high quality.
Bayer publicly discloses information on its clinical trials by the use of freely accessible Clinical Trial Registries. This includes summaries of trial design usually disclosed before the trials will start, and summaries of the results of clinical trials, independent whether the results are favorable or unfavorable to a Bayer product.
Bayer commits to sharing upon request from qualified scientific and medical researchers patient-level clinical trial data, study-level clinical trial data, and protocols from clinical trials in patients for medicines and indications approved in the United States (US) and European Union (EU) as necessary for conducting legitimate research.
To process related scientific research requests, Bayer has joined the Center for Global Clinical Research Data, Vivli (www.vivli.org). Researchers can use this site to request access to anonymized patient-level data and supporting documents from clinical studies to conduct further research that can help advance medical science or improve patient care. Information on the Bayer criteria for listing studies and other relevant information is provided in the ‘Members’ section of the portal.
Data access will be granted to anonymized patient-level data, protocols and clinical study reports after approval by an independent scientific review panel. This applies to data on new medicines and indications that have been approved by the EU and US regulatory agencies on or after January 01, 2014. Bayer is not involved in the decisions made by the independent review panel. Bayer will take all necessary measures to ensure that patient privacy is safeguarded.
To members of steering committees and coordinating principle investigators of its clinical trials, Bayer grants the right to request access to patient-level clinical trial data, study-level clinical trial and clinical documents after completion of the respective trial, for the purpose of independent verification of results and for secondary analyses. This commitment goes beyond Bayer’s standard scope for sharing data with other third-party researchers, in recognition of the established expertise of the steering committee members, their pre-existing collaborative relationship with Bayer as sponsor, and their contribution to designing and conducting the respective clinical trials. Bayer will still take all required measures to ensure trial participants’ privacy is safeguarded. Requests of this kind will be evaluated internally for their scientific validity as well as their compatibility with the Bayer publication and regulatory submission strategy.
Bayer submits information on its clinical trials to the publicly funded website www.ClinicalTrials.gov. Trials sponsored by Bayer of drug development phases II, III, and IV, and trials concerning Bayer’s Medical Devices are registered. Covered are interventional clinical trials related to Bayer’s drug development which started after July 01, 2005. Additionally, trials in patients of drug development phase I which started after January 01, 2010 are registered.
Observational studies based on primary data collection evaluating the effects of Bayer drugs and initiated and funded by Bayer are registered on www.ClinicalTrials.gov if started after May 1, 2007. This registration commitment is extended from May 01, 2014 onwards to include observational studies initiated and funded by Bayer based on secondary data collection focusing on the evaluation of efficacy and safety of Bayer drugs.
Clinical Trial Registry information on Bayer trials are also provided in the Bayer Clinical Trials Explorer application on the Bayer website.
Trial Result Summaries of Bayer’s sponsored clinical trials in drug development phases II, III and IV are provided in the Bayer Clinical Trials Explorer application, if such trials have been conducted on Bayer’s drugs approved for marketing and commercially available.
Bayer posts results of interventional clinical drug trials in this scope that have been completed after July 01, 2005, this includes results disclosure for terminated trials. Additionally, results of phase I trials in patients which started after January 01, 2010 are disclosed. Results of Phase II-IV clinical trials and Phase I trials in patients that were part of a terminated development project will also be disclosed.
Results summaries of observational studies registered by Bayer are provided in the Bayer Clinical Trials Explorer application.
The study result information is usually available within 12 months of the trial completion date or within 12 months of the termination date of the trial or of the development project.
The content of the disclosed Trial Result Summaries conforms to the principles required by the International Conference on Harmonization of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH) Guidelines for Industry: Structure and Content of Clinical Study Reports (ICH E3 Guidance).
In addition, results of clinical drug trials, and results of trials in patients with Bayer’s Medical Devices cleared for marketing will be provided on the publicly funded website www.ClinicalTrials.gov in line with the rules defined in the FDA Amendment Act. Results of clinical drug trials will also be disclosed on EU Clinical Trial Register (https://www.clinicaltrialsregister.eu) in line with the rules defined in the EU Clinical Trials Regulation No 536/2014..
Access to the above mentioned databases including the Bayer Clinical Trials Explorer is unrestricted and free-of-charge.
In order to help inform patients about the clinical trials in which they participate, Bayer has set up processes for providing factual summaries of clinical trial results in plain language. The lay-friendly summaries are understandable for the non-research audience and published usually within 12 months after end of the trial or within 12 months of the termination date of the trial or of the development project. Phase I-IV interventional drug studies in patients and trials in patients concerning Bayer’s Medical Devices are in scope of disclosure in plain language, when completed on or after April 1st, 2019. In line with the company’s focus on patient centricity, all plain language summaries of clinical trial results will be posted in English plus 8 key languages, and every other language where the study took place. The plain language summaries of results will be posted on Bayer’s Clinical Trials Explorer website: https://clinicaltrials.bayer.com .
Bayer-sponsored clinical trials are considered for publication in the scientific literature irrespective of whether the results of these clinical trials are positive or negative. At a minimum, results from all phase 3 clinical trials and any clinical trial results of significant medical importance are submitted for publication. In addition, results from trials in patients are made publicly available through scientific publication and presentations, or on a public website e.g., ClincalTrials.gov, EU Clinical Trials Register, or on the Bayer Clinical Trials Explorer website. This commitment also pertains to investigational medicines whose development programs have been discontinued.
Though information on Bayer’s trials may be found in other public databases as well, the above-mentioned databases provide the most comprehensive overview on Bayer’s clinical trials. The search engine offered by the WHO (https://trialsearch.who.int) collects registry information from multiple databases and thus provides an overview on information about worldwide pharmaceutical research published in leading Clinical Trial Registries.
If you have questions concerning Bayer’s clinical trial disclosure activities and this policy please contact us via email: [email protected]