In the Interim...

Discussions on the ICH E20 Draft Guidance

Aug 25, 2025
Kurt Viele, a partner at Berry Consultants and expert in adaptive clinical trial designs, dives into the ICH E20 draft guidance's implications. He emphasizes the need for clear justification in adaptive trials and explores the distinctions between Bayesian and frequentist methods. The discussion highlights real-world applications, like the Sepsis ACT trial, and critiques areas of the guidance that may pose challenges. With practical insights on regulatory dialogue, operational biases, and future trends, Kurt offers valuable advice for researchers navigating this evolving landscape.
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ADVICE

Use The Guidance As A Regulatory Roadmap

  • Use ICH E20 as a roadmap to discuss adaptive designs with regulators and avoid surprises.
  • Prepare to explain which features are routine and which need extra discussion when you first meet agencies.
INSIGHT

Confirmatory Bayes And Seamless Designs Recognized

  • The draft recognizes Bayesian, simulation, seamless, and enrichment approaches can be confirmatory.
  • That recognition materially advances acceptance of varied adaptive methods.
ADVICE

Push Back On Unnecessary Caution

  • Avoid over-interpreting cautionary adjectives that may discourage adaptive use; focus on the substantive issues.
  • When drafting comments, ask to remove language that labels common approaches as 'incredibly difficult.'
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