Continuing to Clarify the NIH Definition of a Clinical Trial

By Mike Lauer

A few weeks ago we released some case studies and FAQs to help clarify for our research community whether their human subjects research study meets the NIH definition of a clinical trial. These resources prompted a number of follow-on questions and thoughtful suggestions from the community that have helped us refine both the FAQs and the case studies. We are grateful for your thoughtful and constructive comments and suggestions, many of which we have incorporated into our revised documents and communications.

In addition to providing additional rationale for our conclusions in the case studies, we made a number of changes, to include clarifying: what it means to be “prospectively assigned”; what we consider to be a “health-related biomedical and behavioral outcome”; how to classify “ancillary studies”; in what circumstances we would consider a mechanistic study to be a clinical trial; the use of surveys, questionnaires and user preferences; and more.

One of the key clarifications is the distinction between an observational study and an interventional study. There was a lot of very productive discussion around case study 18, which resulted in our breaking the one case study into 6 variations on a theme. The new case studies 18 a-f should help the community understand the nuances of when a measurement is a measurement, and when a measurement tool or task is considered an intervention.

The case studies and FAQs are living documents. We fully expect them to evolve as we work together to think through various scenarios. Unsure whether your human subjects study meets the NIH definition of a clinical trial? Ask the NIH program official (scientific contact) listed in the funding opportunity announcement or on NIH’s website who is responsible for your area of research.

It is important that we get this right. We have an ethical mandate to assure the public that the results of all NIH-funded trials will be made available in a timely manner. We know that under the current state of affairs, over half of all completed NIH-funded trials are not reported out within 2.5 years of completion; the problem is widespread and pervasive. This is an unacceptable state of affairs; it should not be optional to report results. We look forward to continuing to work with you as we move towards higher levels of trust and transparency.