Sunday 6 January 2008

CDISC Implementation Step by Step: A Real World Example

CDISC Implementation Step by Step: A Real World
Example



CDISC Implementation Step by Step: A Real World Example

Sy Truong, Meta-Xceed, Inc., Milpitas, CA



ABSTRACT

Implementation of the CDISC SDTM data model is no longer a theoretical
academic exercise but is now entering the real world since the FDA issued a
guidance in April, 2006, specifying its use. This paper will walk you through
the lessons learned from implementations of CDISC SDTM version 3.1.1. It will
cover both technical challenges along with methodologies and processes. Some
of the topics covered include:

• Project Definition, Plan and Management

Data Standards Analysis and Review

Data Transformation Specification and Definition

• Transforming Data to Standards

• Review and Validation of Transformations and Standards

• Domain Documentation for DEFINE.PDF and DEFINE.XML



The regulatory requirements are likely to include CDISC in the near future and
the benefits of industry-wide standardization are obvious. It is therefore
wise and prudent to implement these standards with techniques and processes
refined from lessons learned from real life implementations.

INTRODUCTION

CDISC (Clinical Data Interchange Standards Consortium) standards have been in
development for many years. There have been major structural changes to the
recommended standards from version 2 to 3. It is still an evolving process but
it has reached a point of critical mass such that organizations are
recognizing the benefits of taking the proposed standard data model out of the
theoretical realm and putting it into real life applications. The complexity
of clinical data coupled with technologies involved can make implementation of
a new standard challenging. This paper will explore the pitfalls of the CDISC
SDTM (Subm ission Data Tabulation Model) transformation and present
methodologies and technologies that make the transformation of nonstandard
data into CDISC efficient and accurate.

There are some tasks within the process that can be applied asynchronously,
but the majority of the steps depend on each other and therefore follow a
sequence. The process is described below:



It is important to have a clear vision of the processes for the project before
you start and to be aware that the effort is resource-intensive. This provides
the ability to resource and plan for all the processes and enables adherence
to deadlines and budgets. The organization and planning for this undertaking
is an essential first step towards an effective implementation.

PROJECT MANAGEMENT

Before any data is transformed or any programs are developed, a project
manager needs to clearly define the project for CDISC implementation. This is
an essential step which will clarify the vision for the entire team and will
galvanize the organization into committing to this endeavor. The project
definition and plan works on multiple levels by providing a practical
understanding of the steps required to create a consensus building team
effort. This can avoid the potential political battles which do arise among
distinct departments within an organization. The following steps will walk you
through the project planning stage.

STEP 1: DEFINE SCOPE – The project scope should be clearly stated in a
document. This does not have to be long and can be as short as one paragraph.
The purpose of this is to clearly define the boundaries of the project since
without this definition the project has tendencies towards scope creep. It can
therefore potentially exceed your resource budget. Some of the parameters to
be considered for the scope of the project include:

• Pilot – For an initial project, it is a good idea to pilot this on one
or two studies before implementing this broadly. The specific study should be
selected based on being representative of other studies likely to be converted
to CDISC.

• Scope – This could be scoped as a limited roll out of a new standard or
a global implementation for the entire organization. This also requires
quantifying details such as how many studies are involved and which group(s)
will be affected. Not only does this identify resources in the area of
programming and validation, but it also determines the training required.

• Standard Audience – The scope should clearly identify the user groups
who will be affected by this standard. It can be limited to the SAS
programming and biostatistics group, or it can have implications for data
management, clinical operations, publishing, regulatory affairs, and
electronic submission groups.
electronic submission groups.

• Validation – The formality of the validation is dictated by the risk
analysis. The scope defines if the project includes validation, or if this
would be part of a separate task.

• Documentation – Data definition documentation is commonly generated as
part of an electronic submission. It is a task that is performed with a CDISC
implementation. The scope would identify if the data definition is part of the
project or considered another project altogether.

• Establishing Standards – The project may be used to establish a future
set of standards. The scope should identify if establishment of global
standards is expected or if it is just a project specific implementation.



The scope document is a form of a requirements document which will help
identify the goals for the project. It can also be used as a communication
method to managers and team members to set the appropriate level of
expectations.

STEP 2: IDENTIFY TASKS – Capture all the tasks that are required to
transform your data to CDISC. This may vary depending on the scope and goals
of the project. If the project is a pilot, for example, the tasks would be
limited compared to a global implementation. The following is an example list
of a subset of tasks along with the associated estimated time of performance.

Data Transformation to CDISC
Data Transformation to CDISC

Project Tasks

Estimated

Work Units

Initial review of study’s data standards including checking all data
attributes for consistency. Generation of necessary reports for documentation
and communication.

17

Reconciliation of internal data standards deviations with organization’s
managers.

17

2Project Tasks Estimated Work Units

Data integrity review including invalid dates, format codes and other
potential data errors. Generation of reports documenting any potential data
discrepancies.

17

Initial data review against a prescribed set of CDISC SDTM requirements and
guidelines. Generation of a report with recommendations on the initial
application of CDISC SDTM standards.

17

Decisions on implementing initial CDISC SDTM data review and identification of
tasks to be performed.

17

Performance of a thorough review of all data and associated attributes.
Identification of all recommended transformation requirements. This is
documented in a transformation requirement specification.

42

Creation of transformation models based on the transformation specifications
for each data set.

25

Generation of the code to perform transformations for each transformation
model.

50

Generation of test verification scripts to verify and document each
transformation program against the transformation requirements specification.

42

Performance of testing and validation of all transformations for data
integrity. Reconciliation and resolution of associated deviations.

42

Execution of the transformation programs to convert the data into CDISC SDTM
format.

25

Performance of data standard review and data integrity review of newly created
transposed data in CDISC SDTM format.

17

Documentation in summary reports of all transformations. This also includes a
summary of all test cases explaining any deviation and how it was resolved.

17

Project management activities including coordinating meetings and summarizing
status updates for more effective client communication pertaining to CDISC
SDTM data.

25

Total Estimates

370



This initial step is only meant as an estimate and will require periodic
updates as the project progresses. It should be detailed enough so that team
members who are involved with the project have a picture of and appreciation
for the project. The experience of the project manager will determine the
accuracy of the tasks and associated time estimates. In this example, it has
not been specified how many person hours this will be but in the real world,
this will more closely reflect your team’s efforts in estimated hours.

This document is used to communicate with all team members that will
potentially work on the project. Feedback should be incorporated to make the
identified tasks and the estimates as accurate as possible.

STEP 3: PROJECT PLAN – Once the tasks have been clearly documented, the list
of tasks will be expanded into a project plan. The project plan is an
extension of the task list including more of the following types of
information:

• Project Tasks – Tasks are grouped by function. This is usually
determined by the skills required to perform the task. This can correlate to
individuals involved or whole departments. Groups of tasks can also be individuals involved or whole departments. Groups of tasks can also be
determined by the chronological order in which they are to be performed. If a
series of steps requires that they be done one after another, they should be
grouped.

3

• Tasks Assignments – Once the tasks have been grouped by function, they
are assigned to a department, manager or an individual. The logistics of this
depends on the SOPs of your organization. This however needs to be clearly
defined for planning and budgeting purposes.

• Schedules of Tasks – A time line is drafted noting at a high level when
important deliverables or milestones are met. The titles of the tasks are the
same as the title for the group of tasks. This will allow users to link back
to the list of tasks to understand the details from the calendar. The schedule
is also shown in calendar format for ease of planning.



A subset and sample of the project plan is shown here:

Study ABC1234 CDISC Transformation Project Plan

Overview This project plan will detail some of the tasks involved in
transforming the source data of study ABC1234 into CDISC SDTM in preparation
for electronic submission. The proposed time lines are intended as samples
which can be adjusted to reflect project priorities.

Project Tasks

The following tasks are organized into groups which have some dependency. They
are therefore organized in chronological order.

1. Data Review

1. Evaluate variable attributes differences within internal data of ABC1234

2. Evaluate variable attributes between ABC1234 compared to ACME Standards

3. Evaluate ABC1234 differences and similarities with CDISC SDTM v3.1.1

4. Evaluate potential matches of ABC1234 variable names and labels against
CDISC SDTM v3.1.1
CDISC SDTM v3.1.1

5. Evaluate ABC1234 against CDISC formats

6. Generate metadata documentation of the original source data from ABC1234

2. Data Transformation Specifications

1. Perform a thorough review of all data and associated attributes against
CDISC SDTM v3.1.1. Identify all recommended transformation requirements. CDISC SDTM v3.1.1. Identify all recommended transformation requirements.
Document this in a transformation requirements specification.

2. Create transformation models based on the transformation specifications for
each data domain.

3. Distribute transformation models for review and feedback.

4. Update the specification to reflect feedback from review



Task Assignments

Project Tasks

Project Manager

Team Managers

Data Review

James Brown, Director of Data Management

Alicia Keys Billy Joel Joe Jackson

Data Transformation Specification
Data Transformation Specification

Janet Jackson, Manager of Biometry

Elton John Mariah Carey Christina Aguilera



STEP 4: VALIDATION – Validation is an essential step towards maintaining
accuracy and integrity throughout the process. It can be determined to be
within or outside the scope of some project. The following list itemizes some
of the validation tasks to be performed.

4

• Risk Assessment –Each task or group of tasks is evaluated for risk and
the appropriate level of validation is determined.

• Test Plan – This documents the testing approach and methodologies to be
used during the validation testing. It describes how the testing will be
performed and how deviations will be collected and resolved. It also includes
test scripts to be used during testing.

• Summary Results – This documents the results of the testing. It
quantifies the number of deviations and documents how they are to be fixed.

The following example shows a form used to collect tasks and associated risks.

Risk Assessment Title

Risk Assessment of analysis files for sample study.

Identify the task where the programs reside which contributes to the risk.

䀃?

Task Name and Location

Interim Analysis on my server

Identify the groups of programs to see which categories they appear in.

䀃?

Analysis Files (20)

Listings (5)

Summary Tables (10)

Graphs (10)

Edit Checks (5)
Edit Checks (5)

Other:

This is a subset of the analysis files Just as an example.

Score:

20

From the group of programs identified, classify the types of programs.

䀃?

Single Use Program in One Study (5)

Single Use Program (10)

This is a single use program and it is going to be used in this study only.

Multi Use Program in One Study* (20)

Multi Use Utility or Macro in Multiple Studies* (30)

Multi Use Utility or Macro in All Studies * (40)

Other

Score:

5

What is the likelihood that the program would produce errors or incorrect
results?

• Are the specifications not clearly defined?

• Does the program use custom logic versus SAS PROCs or standard macros?

䀃?

Error Likelihood Detection (0-20)

Since there are some derivations and hard coded values in this code, I will
give it some degree of error likelihood.

Score:

10



The test plan can vary depending on the amount of details and level of
formality determined by the risk assessment. The following example shows a
subset of a more formal test plan. This can be abbreviated to handle
transformation tasks that are deemed to be of lower risk.

This document is used both to instruct team members on how to perform the
testing and to define how programs are validated. The following is an example
of the validation testing approach and execution procedure.

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4. VALIDATION TESTING APPROACH

4.1 Operational Qualification (OQ)

4.1.1 OQ will provide assurance that the system meets minimum requirements,
required program files are executed, and resulting reports and data produced
are operational according to the requirements.

4.1.2 Testers will follow the instructions provided in the Test Scripts to
perform the tests as documented in Appendix 1.

4.1.3 All supporting documentation (printouts, attachments, etc.) must be
saved and included.

4.2 Summary Report

4.2.1 After all the tests scripts for this validation plan are executed and
all deviations have been resolved, a summary report of the test results will
be prepared. This summary report will include a discussion of the observed
deviations and their resolutions and the storage location of any data not
included within the summary report.

5. GENERAL EXECUTION PROCEDURES

5.1 Prerequisites for testing are described in "Test Scripts Setup"
in Appendix 1. Once these steps have been completed, the programs for the Test
Scripts can be run.

5.2 The testing will be executed either with a batch program or through an
interactive visual inspection of reports. For each test, the results will be
compared to the expected results either manually or with the aid of comparison
tools. The results of such comparisons will be recorded by the tester on the
Test Scripts.

5.3 Deviations that occur during testing will be recorded in the Deviation
Report, a template for which is included in Appendix 2.



Test Scripts The format of the test scripts can also vary depending on the
formality of your testing. It is important to have each test case contain a
unique identifier such as a test case number. This is what a tester and
reviewer use to track the test and its associated deviations.

System Name and Version:

Wonder Drug ABC1234 CDISC

Functional Area/Module:

Standardize ABC1234 Data

Test Script Number:

1 (Requirement 4.1)

Overall Test Objective:

Verify the variable attributes of the existing source data of Wonder Drug
ABC1234

Specific Test Condition:

Tester has read access to input data.

Test Program Run Location:

Test Area

Test Program Name(s):

difftest_avf.sas

Test Script Prerequisites:

None

Step

Instruction

Expected Result

Actual Result

Initials/Date

1

Right mouse click on test script program and select batch submit.

Script file is executed.

2

Evaluate log file for errors.

No errors are found.

3

Evaluate output files to verify that the attributes results match the report
that is performed using %difftest as part the summary report.

Output is verified against output.

Recovery:

Resubmit the program.

Signature/Date

6Step Instruction Expected Result Actual Result Initials/Date

Final Expected Result:

Verify the variable attributes of the existing source data of Wonder Drug
ABC1234.

Actual Result:

Pass

Fail

Comments:

Reviewed By:



The format presented in the test plan such as the summary report can follow
the same format. The examples of this paper only show a subset of the entire
test plan and are intended to give you a conceptual understanding so that you
can apply the same concepts to all the other parts of the documentation.

STEP 5: TRANSFORMATION SPECIFICATION – The specification for transforming to
CDISC standards is a detailed road map that will be referenced and used by all CDISC standards is a detailed road map that will be referenced and used by all
team members during the transformation implementation and review. There can be
different technologies used to perform this task. The following example
utilizes tools including MS Excel and Transdata™. Dataset transformation is
a process in which a set of source datasets and their variables are changed to
meet new standard requirements. The following list describes some of the
changes that can occur:

1. Dataset Name - SAS dataset names must be updated to match SDTM standards,
which require them to be no more than 8 characters in length.

2. Dataset Label - The descriptive labels of SAS datasets must be modified to
conform to SDTM standards.

3. Variable Name - Each variable within a SAS dataset has a unique name.
Variable names can be the same across different datasets, but if they share
the same name, they are generally expected to possess the same attributes.
Variable names are no more than 8 characters in length.

4. Variable Label - Each variable has an associated label that describes the
variable in more detail. Labels are no more than 40 characters in length.

5. Variable Type - A variable’s type can be either character or numeric.

6. Variable Length - A character variable can vary in length from 1 to 200
characters.

7. Format - Variable format will be updated.

8. Yesno - If the value of the variable is "yes", it will produce a
new row with the newly assigned value of the label.

9. Vertical - Multiple variables can be assigned to one variable that will
produce a row if it has a value.

10. Combine - Combine values of multiple source variables into one destination
variable.

11. Drop - The variable from the source dataset will be dropped when creating
the destination data.

12. Same - The same variable with all of the same attributes will be kept in
the destination data.

13. Value Change - This can have either a recoding of values or a formula
change. This will change the actual values of the variable.



There may be other types of transformations, but these are the common
transformation types that are usually documented in the specification. The
transformation specification is stored in an Excel spreadsheet and is
organized by tabs. The first tab named "Tables" contains a list of
all the source tables. The subsequent tabs contain the transformation
specifications for each source dataset as specified in the initial tables tab.

7

Tables Tab The Tables tab contains the list of source datasets along with
descriptions of how each one transforms into the standard data model. It also
records associated data structures such as Relational Records and Supplemental
Qualifiers.

ABC1234 Data Transformation

Source Data

CDISC Data Name

SDTM 3.1.1 Label

Related Records

Supplemental Qualifiers

Ae

AE

Adverse Events

AE

AE, CM, EX, DS

Blcancer

DC

Disease Characteristics

DC

Conduct

DV

Protocol Deviations

DV

Death

DS

Disposition

DS

DS

Demog

DM

Demographics Domain Model

DM, EX, DC

Discon

DS

Disposition

DS

Elig

IE

Inclusion/Exclusion Exceptions

MH

Lab

LB

Laboratory Test Results

LB



This will list all the source datasets from the original study. There is not
always a one to one transformation. That is, there may be many source datasets
used to create one CDISC dataset or one source dataset populating several
CDISC datasets. This will act as an index of all the datasets and how they
relate to each other. The transformation is not limited to the relationship
between source and destination data domains, but also specifies which
variables are destined for the "Relational Records" and
"Supplemental Qualifiers" datasets. These related data structures
are used within SDTM to include data which do not fit perfectly into existing
CDISC domains.

Transformation Model Tab Each source dataset will have a separate
corresponding spreadsheet detailing the transformation. The following is an
example of an adverse event transformation model tab.

Adverse Event Data Transformation from Study ABC1243 to CDISC SDTM 3.1.1

Variable

Label

Transformation Type

Update To

Domain

PATIENT

Subject ID (Num)

name label length

usubjid label="Unique Subject Identifier" length=$15

STUDY

Clinical Study

name label length

studyid label="Study Identifier" length=$15

AECONCAU

Causal Con Med

name label length combine

aerelnst label="Relationship to Non-Study Treatment" length=$140

CM

AECTC

Adverse Event CTC

name label length

aeterm label="Reported Term for the Adverse Event" length=$150

AE

AECTCORG

Organ System CTC

name label length

aebodsys label="Body System or Organ Class" length=$30

AE

AECTCOS

Other Specify CTC

Drop

AE

AEDES

AE Description

name label length combine

aeout label="Outcome of Adverse Event" length=$200

AE

AEDES2

AE Description 2

name label length combine

aeout label="Outcome of Adverse Event" length=$200

AE

Key

Relational Records

Supplemental Qualifiers

Comments



In this example, the source variable AECTCOS is moved to the supplemental
qualifiers structure. Most of the transformations are pretty straightforward
attribute changes. However, the transformation of type "combine"
will concatenate multiple

8

source variables into one target variable. Most of these are going towards the
AE domain except for the variable AECONCAU which is being transformed into the
CM (concomitant medications) domain. This example illustrates how various
details of data transformations can be expressed concisely with great detail
in the form of a transformation specification.

STEP 6: APPLYING THE TRANSFORMATION – In an ideal world, the specification
is completed one time and you apply the transformation according to the
specification. In the real world, however, the specification goes through
changes throughout the duration of the project. You therefore need to make an
executive decision at specified times to apply the transformation even when
things are still changing. Because of the dynamic nature of the data, a tool
can be very useful since the transformation specification needs to also be
dynamic to keep up with the changing data. Changes to transformations have
implications for re-coding transformation logic, and manually programming
transformations and updates becomes a very resource intensive task. To
automate this process, the transformation specification is captured in a SAS
dataset and managed with the following screen.

All the source variables and associated labels can be managed and displayed in
the left two columns. The type of transformations including the most commonly
used ones are listed with check boxes and radio buttons for ease of selection
and application. The new attributes of the target variables listed in the
specification spreadsheet can also be captured here. Besides being able to
edit these attributes, standard attributes from CDISC are also listed as
recommendations. The advantages to managing the specifications in this manner
compared to Excel include:

1. An audit trail is kept of all changes.

2. The selection choices of transformation type and target attributes make it
easier to generate standardized transformations.

3. Transformation logic coding and algorithms can be generated directly from
these definitions.

4. A refresh of the source variables can be applied against physical datasets
to keep up with changing data.



Program Transformation Once the transformation specification has been clearly
defined and updated against the data, the program(s) must be written to
perform these transformations. A sample program may look like this:

9

***********************************************;

* Program: trans_ae.sas

* Path: c:\temp\

* Description: Transform Adverse Events data

* from DATAWARE.AE to STDMLIB.AE

* By: Sy Truong, 01/21/2006, 3:49:13 pm

***********************************************;

libname DATAWARE "C:\APACHE\HTDOCS\CDISC\DATA";

libname STDMLIB "C:\APACHE\HTDOCS\CDISC\DATA\SDTM";

data STDMLIB.AE (label="Adverse Events"

);

set DATAWARE.AE;

retain obs 1;

*** Define new variable: aerelnst that combined by old variables: aeconcau
aerelat;

attrib aerelnst label="Relationship to Non-Study Treatment"
length=$140;

aerelnst = trim(trim(aeconcau) ' ' aerelat);

drop aeconcau aerelat;

*** Define new variable: aeout that combined by old variables: addes addes2;

attrib aeout label="Outcome of Adverse Event" length=$200;

aeout = trim(trim(addes) delimit_aeout0 addes2) delimit_aeout1;

drop delimit_aeout0 delimit_aeout1 addes addes2;

run;



There are many different types of transformations. The comment and simple
examples described above demonstrate the updates of attributes and assignment
to the correct CDISC variables. There are cases where more elaborate
transformations are required. The amount of time required to transform each
variable in multiple ways makes this step one of the most resource intensive
steps.

STEP 7: SPECIAL PURPOSE DOMAIN – CDISC has several special purpose domains.
Among these are three named SUPPQUAL, RELREC and CO.

SUPPQUAL - The Supplemental Qualifiers domain is used to capture
non-standard variables and their association to parent records in domains,
capturing values for variables not presently included in the general
observation-class models.

RELREC - The Related Records domain is used to describe relationships
between records in two (or more) datasets. This includes such records as an
"event" record, "intervention" record, or a
"f inding" record.

• CO - The Comments special-purpose domain is a fixed domain that provides a
solution for submitting free-text comments related to data in one or more
domains which are collected on a separate CRF page dedicated to comments.



These three are similar in structure and capture values that are related to
the main domains.

Supplemental Qualifiers An example of the SUPPQUAL is shown here:

Preview of Dataset Name: SUPPQUAL

Obs

Study Identifier

Related Domain Abbreviation

Unique Subject Identifier

Identifier Variable

Identifier Variable Value

Qualifier Variable Name

Qualifier Variable Label

Data Value

Origin

1

23423

AE

1803

seqnum

64001

ae

ADVERSE EXPERIENCE

derived

2

23423

AE

101

seqnum

64007

ae

ADVERSE EXPERIENCE

(R) PLEURAL EFFUSION

derived

3

23423

AE

1102

seqnum

64003

ae

ADVERSE EXPERIENCE

(SOB) SHORTNESS OF BREATH

derived

4

23423

AE

1103

seqnum

64001

ae

ADVERSE EXPERIENCE

ABDOMINAL CRAMPING

derived

5

23423

AE

102

seqnum

64009

ae

ADVERSE EXPERIENCE

ABDOMINAL DISTENTION

derived

10

Most data operationally used in clinical trials are not stored in this manner.
The "qualifier variable name" is usually one of the columns in the
dataset. However, in this case, it is transposed and the column variable is
stored as one of the column values. This allows the structure to handle
different variables and to be more flexible. However, this may require you to
perform a transposition from your source data.

Since the destination value is a character field, the transformation may
require additional conversions. Here is an example code segment that performs
this type of transformation.

*** Transpose the for variable TRTCYC ***;

data work. suppqual;

set sourcelib.ae;

*** Convert numeric idvar ***;

idvar="aerbdt";

idvarvan = aerbdt;

idvarval = left(trim(put(idvarvan,DATE9.)));

qvaln = trtcyc;

qval = left(trim(put(qvaln,best.)));

usubjidn = patnum;

rdomain = "AE";

qnam = "otherae";

qlabel = "Other Specify Adverse Event";

run; *** Append data to the final destination SUPPQUAL ***;

data SDTMLIB. suppqual (label = "Supplemental Qualifiers for Adverse
Events");

set SDTMLIB. suppqual_ae

work.suppqua2;

if compress(studyid) = '' and compress(usubjid) = '' then delete;

run;



This code segment only shows you part of what is happening. It does however
illustrate the need to handle transformations one variable at a time and the
need for handling different variable types. If there are many datasets with
many variables, this type of transformation can cumulatively add up to a big
task. Specialized tools can handle such transformations of structures
including SUPPQUAL, RELREC and CO.

The following decisions need to be made when working with the SUPPQUAL
dataset:

1. Input Dataset – Select all the input datasets from the source location
that need to contribute to SUPPQUAL.

2. Input Variables – Select variables that are not part of the main domain
but are considered supplemental. These are deemed important enough to be part
of the final subm ission yet do not fit perfectly to the variables within the
specified domain.

3. Source Type – Define the type of source of specified variables. This can
have values such as CRF, Assigned, or Derived.

4. Related Domain – Determine the related domain to which this dataset
pertains.

5. Study Identifier – Document to which study or protocol name and number
this data belongs.

6. Identification Variable – Identify what key fields can be used to
uniquely identify the selected fields. This can be a sequence variable, group
ID, or unique date variable.

7. Unique Subject ID – Identify the variable which contains the unique
subject identification value.



The above decisions can be made with the following interface.

11

Once all the variables are selected, the user can decide upon the origins. The
interface provides default values that can assist the user in making quick
decisions. Once the user is proficient at making these types of selections, a
macro interface can be used for efficient production batch processing.

Related Records The related records data domain is similar in structure to the
supplemental qualifier domain. These variables are found in events, f indings,
or intervention records. The domains which are identified in these records
include:

Interventions

1. Concomitant Medications

2. Exposure

3. Substance Use



Events

1. Adverse Events

2. Disposition

3. Medical History



F indings

1. ECG Test Results

2. Inclusion/Exclusion Exceptions

3. Laboratory Test Results

4. Physical Examinations

5. Questionnaires

6. Subject Characteristics

7. Vital Signs

12

This covers a wide range of fields. The types of fields selected to be related
records can be very flexible, but the data structure which is used to store
RELREC data is strict. The following decisions need to be made to transpose RELREC data is strict. The following decisions need to be made to transpose
the data into a related record.

1. Input Dataset – Select all the input datasets from the source location
that need to contribute to RELREC.

2. Related Domain – Determine the related domain to which this dataset
pertains.

3. Study Identifier – Document to which study or protocol name and number
this data belongs.

4. Identification Variable – Identify what key fields can be used to
uniquely identify the selected fields. This can be a sequence variable, group
ID, or unique date variable.

5. Unique Subject ID – Identify the variable which contains the unique
subject identification value.



A graphical user interface can be used to assist in making these decisions.

The interface also has a "f ind related" tool which assists you in
identifying fields that are potentially considered to be a related record
field. It searches through the variable names and labels for key words. A
report is then generated showing the possible related field.

F ind Related Domain for: DEATH

Obs

Dataset and Variable

Data Table Name

Variable Name

VariableLength

Variable Label

Variable Type

Matched Criteria

1

death.event

death

EVENT

8

EVENT LEADING TO DEATH

N

Variable label (to )

Generated on: 02/12/2006, 5:03:10 pm, Sy Truong

Located at: C:\GLOBAL\PROJECT1\STUDY1\SOURCE DATA



In this example, the key word it found was the word "to" in the
label. This report is an example of how the tool can assist in expediting the
selection and the creation of your related record domain dataset.

13

Comments An analysis file or source data from an operational database usually
has the comment fields stored in the same dataset upon which it is commenting.
For example, if there is a comment captured on a CRF pertaining to adverse
events, you would f ind this in the adverse event dataset. CDISC data is
different in that all comments from all different sources are gathered
together and stored separately in their own dataset named CO. In doing so, you
have to identify additional information such as to which domain the comment is
related, among other identification variables. The decision process is similar
to SUPPQUAL and RELREC. Similar to the "f ind related", there is a
tool named "f ind comment". This will search through variables and
labels f inding possible comment fields. This is usually pretty accurate since
comment fields often have labels that have key words such as
"comment" in them.

The three special purpose structures defined by CDISC are very flexible. They
are vertical in structure so they can handle just about any source data. It
is, however, unusual for data to be stored in this manner when being entered
or analyzed. It is therefore necessary to perform transformations, which are
time consuming since they must be handled one variable at a time. Automated
macros and tools can help expedite these types of transformations.

STEP 8: SEQUENCE, ORDER AND LENGTHS – Data value sequence along with
variable order and length need to also follow standards. CDISC does specify
guidance for data sequences and variable order but is not as strict on
variable lengths. In either case, you need to apply these consistently in
order for the data to be standardized.

Sequence Any dataset that contains more than one observation per subject
requires a sequence variable. The sequence variable identifies the order of
the values for each subject. If your data does not contain this sequence
variable, you need to add it. Besides the subject ID, you also need to
identify a unique identifier variable that distinguishes between the
observations within one subject. This can be another group type of
identification variable or a form date.

A tool named ADDSEQ adds this sequence based upon the choices you decide for a
specific dataset.

The ADDSEQ tool will then create a new sequence variable containing sequential
values after it sorts the data by the subject ID and identification variable.
In addition to creating the sequence variables, there is also a tool that
tells you if the dataset requires a sequence variable or not. It essentially
verifies if there is more than one observation per subject. This will then
help prompt you to add sequence variables in case that has been overlooked.

Variable Order The data that is delivered in CDISC format needs to be ordered
in a standard manner. All the key fields need to be first in order followed by
the rest of the variables. The rest of the variables are then shown in
alphabetical order. SAS datasets have their variables stored in a specified
order and it is not necessarily in this standard order. A standard tool can
re-order the variables with the keys appearing first, followed by the rest of
the variables. The rest can be optionally alphabetized or left in their
original order. This task may appear mundane but can be very helpful for the
reviewer who is navigating through many datasets.

Variable Lengths Variable lengths are not strictly specified by CDISC
guidelines. Nevertheless, it is important to have variable lengths follow a
standard for consistency. This includes:

1. Consistent lengths between variables that are the same across different
data domains

14

2. Optimal lengths set to handle the data



In order to accomplish the first rule of standards, if you were to assign a
length for one variable such as USUBJID in one dataset, you should set this
variable to the same length in all other datasets. The second rule suggests
that if the maximum length of this variable across all datasets is 9
characters, it would probably be optimal to set the length to 10. It makes
sense to round up to the nearest ten to give it some buffer but not too much
so that it would not be wasteful. Datasets can be very bloated and oversized
for the values they carry if the second rule is not applied. The following
tool named VARLEN assigns the length optimally.

In this example, the rounding option can be set to 10, 20 or none. It can
therefore assign the exact maximum length which the data value contains if
that is what is required. This creates the proper length statement so that
your data will have the optimal lengths used for the values stored in that
data.

STEP 9: DATA DEFINTION DOCUMENTATION – When you plan for a road trip, you
need a map. This is analogous to understanding the data that is going to be
part of an electronic submission. The reviewer requires a road map in order to
understand what all the variables are and how they are derived. It is in the
interest of all team members involved to have the most accurate and concise
data documentation. This can help your team work internally while also
speeding up the review process, which can really make or break an electronic
subm ission to the FDA.

Levels of Metadata There are several steps in documenting the data definition,
most involving metadata, which is information about the data. There are
several layers to the metadata. These include:

1. General Information – This pertains to information that affects the
entire set of datasets. It could be things such as the name of the study, the
company name, or location of the data.

2. Data Table – This information is at the SAS dataset level. This includes
things such as the dataset name and label.

3. Variable – This information pertains to attributes of the variables
within a dataset. This includes such information as variable name, label, and
length.



The order in which the metadata is captured should follow the same order as
the layers that are described.

Capture General Information The following table lists the types of information
that are important:

Metadata

Description

Company Name

This is the name of the organization that is submitting the data to the FDA.

Product Name

The name of the drug that is being submitted.

Protocol

The name of the study on which the analysis is being performed, which includes
this set of data.

15

Layout

The company name, product name, and protocol are all going to be displayed on
the final documentation. The layout information will describe if it will be in
the footnote or title and how it is aligned.



This high level metadata will be used in headers and footers on the final
documentation.

Dataset Level Information Some of the dataset level information can be
captured through PROC CONTENTS but others need to be defined when you are
documenting your data definition. Some of the information includes:

Metadata

Description

Data Library

Library name defines the physical path, server, and location of the data. This
can also be in the form of a SAS LIBNAME.

Key Fields

Keys usually correlate to the sort order of the data. These variables are
usually used to merge the datasets together.

Format Library

This is where the SAS format catalog is stored, if applicable.

Dataset Name

The name of each SAS dataset included.

Number of Variables

A count of the number of variables for each dataset.

Number of Records

Number of observations or rows within each dataset.

Dataset Comment

A descriptive text describing the dataset. This can contain the dataset label
and other descriptive text explaining the data.



SAS Tools such as PROC CONTENTS can contribute to most of these items.
However, comments and key fields can be edited which may differ from what is
stored in the dataset.

Variable Level Information The last step and level to the domain documentation
is the variable level. This includes the following:

Metadata

Description

Variable Name

The name of the SAS variable.

Type

The variable type, such as Character or Numeric.

Length

The variable length.

Label

The descriptive label of the variable.

Format

SAS formats used. If it is a user defined format, it would need to be decoded.

Origins

The place from where the variable came. Sample values include Source and
Derived.

Role

This defines the role of the variable. Example values include Key, Ad Hoc,
Primary Safety, and Secondary Efficacy.

Comment

This is descriptive text explaining the meaning of the variable or how it was
derived.



Similar to the data set level metadata, some of the variable level attributes
can be captured through PROC CONTENTS. However, fields such as origins, role,
and comments need to be edited by someone who understands the meaning of the
data.

Automation Tools such as PROC CONTENTS and Excel do have capabilities to
customize and automate the documentation to a degree. They are not however
intended specifically for creating data definition documentation. These tools
therefore have limitations. A tool was developed entirely in SAS specifically
for generating this type of documentation. This tool contains both a

16

graphical user interface and a macro interface to fit the user’s
requirements. The tool addresses all the disadvantages of the manual methods.
It uses a similar PROC CONTENTS type of mechanism for capturing the initial
metadata. However, it only retains the specific information that is pertinent
to the data definition documentation.

Definedoc automatically captures attributes produced by PROC CONTENTS. For
other attributes, it presents possible values that users can select for ease
and consistency.

The tool also keeps track of all edits in an audit trail capturing who has
updated what column so that if anything goes wrong, it can easily be traced
back and fixed. One of the main advantages is that if any of the variable
attributes are updated, this can be "refreshed" with a click of a
button. It will not affect those fields that the user has entered, but rather,
it updates other attributes such as variable names and labels.

Definedoc has the flexibility of exporting the pertinent information to an
excel spreadsheet so that those users who prefer to edit their values within excel spreadsheet so that those users who prefer to edit their values within
Excel can do so.
Excel can do so.

17

This provides the best of both worlds. It captures just the values that you
want and exports this to Excel for those who prefer this interface. Once you
are finished with editing the information in Excel, the same spreadsheet can
be re-imported so that the information is handled centrally. Besides the
dataset and variable level metadata information, Definedoc also helps automate
the capture of the high level general information.

This handles both the editing of the information and layout of the final
report. Generating Documentation The last step in the process is to generate
the documentation in either PDF or XML format. The challenge is that in order
to make the documentation useful, it requires hyperlinks to link the
information together. The manual method allows you to format the information
in Word and this can be converted into PDF. Even though Word and Excel can
generate XML, they do not have the proper schema so there is no manual way of
generating the needed XML version of the report. The definedoc has the
flexibility of generating the report in Excel, RTF, PDF, and XML.

18

It utilizes ODS within SAS to produce output in all these formats. In addition
to the XML file, the definedoc tool also produces the accompanying cascading
style sheet to format the XML so that you can view this within a browser in a
similar format as in a web browser. An example PDF output would look like
this:

CONCLUSION

There are many challenges in working with CDISC SDTM version 3.1.1. It can
accommodate a wide variety of data but it is structured differently from data
on which users would perform analysis. CDISC is intended to be used for
subm issions, so transformation will likely be necessary. Since transformations
are different for each variable, the sum of the work can be tremendous. It
requires organization before execution and optimization in implementation. The
techniques, methodologies, and tools presented in this paper demonstrate ways
of optimizing conversion to CDISC structures based on real world experience.
Armed with efficient and tested approaches, you can avoid mistakes and
implement CDISC with success.

REFERENCES

SAS and all other SAS Institute Inc. product or service names are registered
trademarks or trademarks of SAS Institute Inc. in the USA and other countries.
® indicates USA registration.

CDISC Builder, Transdata and Definedoc and other MXI (Meta-Xceed, Inc.) CDISC Builder, Transdata and Definedoc and other MXI (Meta-Xceed, Inc.)
product names are registered trademarks of Meta-Xceed, Inc. in the USA.

Other brand and product names are registered trademarks or trademarks of their
respective companies.

ABOUT THE AUTHOR

Sy Truong Meta-Xceed, Inc.

1751 McCarthy Blvd.

Milpitas, CA 95035

(408) 955-9333


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 



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