What do you call a country with quality research facilities, efficient ethics and regulatory framework, diverse participant recruitment pool, research tax incentives and flexibility in conducting research?
Some call it a dream destination, others Australia!
It’s a country that has the world’s best researchers and health professionals, boasts a world-class research infrastructure and high standards of clinical trials conduct. This obviously leads of good quality, increased speed and high confidence in the result.
Questions that arise for those interested in Australia for clinical trials include
- What are the regulatory processes (hurdles?), and
- How can we find the sites to conduct trials there?
In this articles, let’s try to address these questions.
Clinical Trial Regulatory in Australia
Therapeutics Goods Administration (TGA)
TGA is the regulatory body in Australia. To conduct a clinical trial in Australia, the trial must have an Australian sponsor. The sponsor may be an
- Individual (for example a medical practitioner),
- A body or organisation (for example hospitals, area health services, non-government organisations), or
- A company (for example pharmaceutical companies, CROs).
TGA would deal directly with the Australian sponsor on all matters relating to the trial.
Where to submit Trial Application ?
There are two major systems for submission of clinical trial proposal for therapeutic goods that have not been evaluated by the Therapeutics Goods Administration (TGA) and entered into the Australian Register of Therapeutic Goods (ARTG) for general marketing
- Clinical Trial Notification (CTN) or
- Clinical Trial Exemption (CTX) schemes.
To submit CTNs or CTX applications, clinical trial sponsors must obtain a TGA client Identification Number (Client ID).
In this case, scientific and ethical review should be provided by a human research ethics committee (HREC), with subsequent notification to the TGA.
Whereas in this scheme, the TGA has a direct role in the review of trial scientific data and must give an ‘approval’ for the proposed trial program to go ahead.
Human Research Ethics Review
All clinical trials in Australia require review and approval of trial proposals
by an ethics committee.
Ethics committee must have notified its existence to the Australian Health Ethics Committee (AHEC) of the National Health and Medical Research Council (NHMRC) and provided assurances that it is operating within its guidelines.
Ethics committees in Australia provide a combined ethical and scientific review process.
Approval Process time
Human Research Ethics Committee(HREC) review takes 1-3 months(however, depends upon the institution) and CTN takes about 7-14 days
Type of approval
Approval process for conducting clinical trial is Parallel.
Legends: CTN- Clinical trial Notification, CTX- Clinical trial Exemption, TGA-Therapeutic Goods Administration, HREC-Human Research Ethics Committee
NOTE: HERC Review time depends upon the institution
CTN Submission Process
- CTA called clinical trial Notification (CTN) can be submitted online by accessing to secure online TGA Business Services (TBS)site.
- If the organization already has online access to TBS, will have a Client ID without online access to TBS.
An administrator should be nominated via the Organisation details form to gain access to TBS.
- This applies to those organisations that already have a TGA client identification number (Client ID), as well as new organisations.
- If does not have a Client ID then should apply for a new Client ID.
CTX Scheme – Process
- A sponsor submits an application to conduct clinical trials to the TGA for evaluation and comment.
- A TGA Delegate decides whether or not to object to the proposed Usage Guidelines for the product. If an objection is raised, trials may not proceed until the objection has been addressed to the Delegate’s satisfaction.
- If no objection is raised, the sponsor may conduct any number of clinical trials under the CTX application without further assessment by the TGA, provided use of the product in the trials falls within the original approved Usage Guidelines. Each trial conducted must be notified to the TGA.
- A sponsor cannot commence a CTX trial until written advice has been received from the TGA regarding the application and approval for the conduct of the trial has been obtained from an ethics committee and the institution at which the trial will be conducted.
CTX Scheme – Forms
There are two forms, each reflecting separate processes (Parts), that must be submitted to TGA by the sponsor.
- Part 1 constitutes the formal CTX application. It must be completed by the sponsor of the trial and submitted to TGA with data for evaluation.
- Part 2 is used to notify the commencement of each new trial conducted under the CTX as well as new sites in ongoing CTX trials. The Part 2 form must be submitted within 28 days of the commencement of supply of goods under the CTX. There is no fee for notification of trials under the CTX scheme.
Here are the Fee / charges for various categories.
For prescription medicine, biological, and other listed and registered therapeutic goods CTN – $345 AUD.
For prescription medicine CTX for 30-day evaluation – $1,665 AUD.
For prescription medicine CTX for 50-day evaluation – 20,800 AUD.
For biological CTX – $25,200 AUD .
Applications for clinical trials under the CTX scheme cost more than notifications under the CTN scheme because of the increased work needed to evaluate the CTX application data.
Applications for clinical trials under the CTX scheme cost more than notifications under the CTN.
More information on these charges can be found on https://www.tga.gov.au
Human Research Ethics Committees
- Ethics committee must have notified its existence to the Australian Health Ethics Committee (AHEC) of the National Health and Medical Research Council (NHMRC) and provided assurances that it is operating within its guidelines.
- Ethics committees in Australia provide a combined ethical and scientific review process,
- HRECs have a pivotal role in clinical research in Australia, by virtue of the fact that they undertake the key responsibilities of clinical trial approval and oversight
- HRECs operate under the auspices of the Australian Health Ethics Committee.
- Additionally, public hospitals are required to undertake a research governance step in the form of a site-specific assessment (SSA) for each project.
- Therefore, for public sites, HREC and an SSA is required for a clinical trial to commence.
- The institution or organisation where the trial will be conducted will give the final go-ahead for conducting the trial at the site, having taken into account advice given by the HREC.
- CTN research projects must not start at a site until the research project and investigational site have been notified to the TGA and the appropriate notification fee paid.
- It is preferable to wait for the TGA to confirm receipt of the CTN before recruitment commences.
Medical Device Trials
Clinical trial regulatory process for devices is essentially similar to that for medicines. Often, the protocol is sent in by the sponsor/principal investigator(s) with the CTN notification form, and in such instances comments are provided on the document by the medical advisory staff. CTX applications for medical devices are rare.
Finding Sites and Assessing Feasibility in Australia
Australia offers investigators that are open to discuss new clinical trials, quick to respond to feasibility and willing to dedicate their time to research generally. At Credevo, we come across many such examples.
Try finding sites and conducting feasibility with Australian investigators and you will be able to save lot of time and cost in doing so. Here are quick steps to start
- Sign up on Credevo and post your project, or
- Simply write to us with your requirements at firstname.lastname@example.org
Once you get started with these steps, be prepared to reap following benefits of Australian clinical trial system.
Benefits of Conducting Clinical Trials in Australia
Quality research and facilities
for its highly trained clinical workforce and the high-quality data produced by its experienced, trained (and accredited) research teams.
Efficient ethics and regulatory framework
Research proposals are submitted directly to Australian Human Research Ethics Committees (HRECs) which assume the primary review responsibility for ethical and scientific review.
The usual review cycle takes only 4 to 8 weeks and is based on the submission of a protocol, investigator brochure and if required, an independent toxicology report.
Diverse participant recruitment pool
Australia has an informed and willing population of potential trial participants, resulting in a higher level of research participation than would be expected from a population of its size.
The Australian Government’s generous Research & Development (R&D) Tax Incentive encourages more industry investment in R&D.
The Incentive provides businesses investing in eligible R&D with generous tax offsets:
- A 45 per cent refundable R&D tax offset (equivalent to 45c per $1 of eligible R&D) for companies with aggregated annual turnover of less than A$20 million; and
- A 40 per cent non-refundable R&D tax offset (equivalent to 40c per $1 of eligible R&D) for all other eligible companies.
Companies conducting clinical trials in Australia do not require the US FDA Investigational New Drug (IND) application approval.
Data output from studies carried out in Australia meet global standards and can be used to support international regulatory applications, including the US FDA IND submission. This makes the process more efficient, flexible yet ethical.