Independent · non-commercial · publishes on a quarterly cycle|Current cycle 2026 Q3
Compound Evidence InstituteEvidence synthesis · established 2023Graded assessments of compounds, trials, methods and supply
Document set current to 30 July 2026
Public comment period · §2

Draft synthesis: Oral compared with injectable presentations… — submissions

The 15 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-101/2
Series
Public comment period
Version
1.0
Published
10 Oct 2024
Last reviewed
10 Oct 2024
Next review
10 Oct 2025
Identifier
10.71829/cei.cp.101
Certainty
Not rated
Cycle
2024 Q3
Window
18 Jul 2024 – 01 Sep 2024
Status
Closed
Submissions
15

§2Submissions and responses

15 submissions were received. Each is published in full below with its declared interest, the secretariat response and the disposition. The Institute publishes submissions it did not accept in the same form as those it did.

Dr Zebedee Zaleski-Mbeki, PhD (Pharmaceutics) Endocrine surgery service
DRAFT-ORAL-VS-INJE/008 received 19 Jul 2024

The review question is drawn too broadly to be answerable

The respondent states that the population as registered spans groups in which the intervention would be expected to behave differently, and that a single estimate across them is uninformative.

The respondent proposes that the question be split and the review re-registered.

Declared interest. Holds a patent relating to a delivery technology referenced in the draft.
Secretariat responseNot accepted19 Sep 2024

The secretariat does not accept this submission. The breadth was registered before screening, the pre-specified subgroups address the variation the respondent identifies, and re-registering after the results are known would convert a pre-specified analysis into a post hoc one.

The question stands as registered. The point is recorded in the limitations, and the assessment committee has noted it for the protocol of the next version of this review, which will be registered before the search is run. The submission remains published in full.

Dr Bertrand Steenkamp-Ferreira, MSc (Clinical Trials) Regional hospital pharmacy department
DRAFT-ORAL-VS-INJE/011 received 19 Jul 2024

Analytical surveys are treated as evidence about suppliers when they establish only what was in a sample

Several included surveys purchased material anonymously and analysed it. The respondent states that where the chain from a named supplier to the analysed vial cannot be documented, the result describes a sample and not a supplier.

The respondent proposes that provenance be an explicit eligibility dimension, with surveys reported separately according to whether it could be established.

Declared interest. No financial interest. Has published a systematic review reaching a different conclusion from the draft, which the respondent declares as a non-financial interest.
Secretariat responseAccepted11 Sep 2024

The secretariat accepts this submission. Moderate certainty evidence from the included surveys supports statements about material circulating in a market; it does not support statements about any named supplier's output.

Provenance is now assessed for every included survey and reported as a study characteristic, surveys without establishable provenance are reported separately rather than pooled with those that have it, and no supplier-level inference is drawn from a sample-level result.

Yusuf Whitmarsh-Obi, PhD (Medicinal Chemistry) University department of public health · industry submission
DRAFT-ORAL-VS-INJE/003 received 20 Jul 2024

Two factual descriptions of the sponsor's programme are inaccurate

The submission is made on behalf of the marketing-authorisation holder and is confined to two matters of fact. The draft describes a trial as terminated where the sponsor closed it at a pre-specified interim analysis, and gives a dose in a unit that does not match the approved labelling.

Supporting documentation, comprising the published trial report and the current summary of product characteristics, accompanied the submission. No view is expressed on the certainty ratings, which the sponsor considers a matter for the assessment committee.

Declared interest. Is an employee of a marketing-authorisation holder for a compound named in the draft. This submission is made on behalf of that company and is identified as an industry submission throughout.
Secretariat responseAccepted07 Sep 2024

The secretariat accepts this submission. Both points are matters of fact, both were checkable against documents the Institute holds, and both were wrong in the draft.

The trial status now reads as completed at a pre-specified interim analysis, with the analysis identified, and the dose is stated in the unit used in the approved labelling. The submission is identified as an industry submission on its face in accordance with the conflicts policy.

Dr Katarzyna Oppenheimer-Ade, BPharm, PhD National pharmacovigilance centre
DRAFT-ORAL-VS-INJE/014 received 23 Jul 2024

The same concern is used to downgrade in two domains

The draft downgrades for both indirectness and imprecision citing the same feature of the contributing trials. The respondent states that this double-counts a single concern and produces a rating lower than the framework supports.

The respondent proposes that the rating be raised by one level.

Declared interest. Is a trustee of a patient organisation that has received a restricted educational grant from a manufacturer in the class under assessment.
Secretariat responseAccepted in part30 Sep 2024

The secretariat accepts this submission in part. The double count is real in one of the two outcomes identified and not in the other, where the two domains rest on different features.

The rating for the first outcome has been raised by one level and the domain reasoning restated, and the reasoning for the second has been rewritten to make clear that the two downgrades rest on different features of the evidence.

Dr Wolfram Kaltenbach-Mensah, PhD (Toxicology) Health-technology assessment agency
DRAFT-ORAL-VS-INJE/002 received 25 Jul 2024

The same concept is given three different names in one document

The draft refers to the same quantity as a response rate, a responder proportion and a categorical outcome in different sections. The respondent, who works in health-technology assessment, states that a reader cannot tell whether the three refer to one thing or to three.

The respondent proposes that the glossary term be used at every occurrence and that the glossary entry be linked at first use in each section rather than only at first use in the document.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted02 Oct 2024

The secretariat accepts this submission. The variation was stylistic and its cost to the reader exceeds any benefit.

A single term is now used throughout for each defined concept, and the glossary entry is linked at first use within each section rather than once per document.

Dr Anselm Ashworth-Danquah, PhD (Biostatistics) University department of medicinal chemistry
DRAFT-ORAL-VS-INJE/012 received 27 Jul 2024

Risk-of-bias judgements are reported as an overall rating without the domains

The draft reports a single overall risk-of-bias judgement per study. The respondent states that the overall judgement conceals which domain drove it, and that a reader assessing whether the concern applies to their question needs the domain.

The respondent proposes a domain-level table with the supporting quotation for each judgement.

Declared interest. Employed by a national competent authority. This submission is made in a personal capacity and does not represent the position of that authority.
Secretariat responseAccepted08 Sep 2024

The secretariat accepts this submission. The overall judgement is a summary of the domains and publishing only the summary makes it uncheckable.

Risk of bias is now reported at domain level for every included study, with the text on which each judgement was based quoted and referenced, and the overall judgement derived from the domains rather than asserted alongside them.

Dr Ivo Quintanilha, MD, MSc Community pharmacy practice, doctoral candidate
DRAFT-ORAL-VS-INJE/013 received 27 Jul 2024

The document is unreadable without specialist training

The respondent, a trustee of a patient organisation, states that the draft is written for a reader who already understands certainty grading, and that the people most affected by the subject matter will not reach the assessment at all.

The respondent proposes a plain-language summary at the head of every document, written to the same standard of accuracy as the document itself and not as a promotional abstract.

Declared interest. Holds a patent relating to a delivery technology referenced in the draft.
Secretariat responseAccepted in part01 Oct 2024

The secretariat accepts this submission in part. A plain-language summary is added. The proposal that it replace the technical abstract is declined, because the abstract is the part of the document other assessors read and cite.

Every document now opens with a plain-language summary of not more than 150 words, placed above the technical abstract and carrying the same certainty language, so that the two cannot diverge.

Dr Dmitri Nordhagen, PhD (Chemistry), MRSC University department of pharmacy practice
DRAFT-ORAL-VS-INJE/005 received 04 Aug 2024

A superseded version should remain reachable from the version that replaced it

The respondent states that the draft supersedes an earlier document and that a reader who cited the earlier version has no way to reach it from the new one, which makes it impossible to see what changed.

The respondent asks that every version carry a link both to what it supersedes and to what supersedes it.

Declared interest. Has received consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseNoted, no amendment13 Sep 2024

The secretariat notes this submission. The corrections and versioning policy already requires bidirectional version links and every superseded document is retained at its own address.

No amendment arises. The requirement is stated in the corrections and versioning policy and the amendment log of this document links to the version it replaced. The respondent is correct that the link was absent from the draft page furnished for consultation, which was a defect of the consultation copy and not of the policy.

Dr Ottoline Fitzgerald-Nwosu, MD, MRCP Independent analytical consultancy
DRAFT-ORAL-VS-INJE/007 received 06 Aug 2024

Two included studies do not meet the registered eligibility criteria

The respondent identifies two studies in the included set whose duration falls below the minimum stated in the protocol, and one excluded study that appears to meet every criterion.

The respondent proposes that the three be reassessed and that the outcome of the reassessment be recorded whichever way it goes.

Declared interest. Is a trustee of a patient organisation that has received a restricted educational grant from a manufacturer in the class under assessment.
Secretariat responseAccepted in part02 Oct 2024

The secretariat accepts this submission in part. On reassessment, one of the two included studies does fall below the minimum duration and has been removed. The second reports a duration that met the criterion in the protocol version registered at the time. The excluded study was excluded for a reason not clearly recorded, which was a documentation failure.

One study has been removed from the included set and the estimate recomputed, the exclusion reason for the third study has been corrected in the excluded-studies table, and the screening decisions are now recorded against the protocol version in force at the time of screening.

Dr Amara Quaresma, MD, MRCP Independent analytical consultancy
DRAFT-ORAL-VS-INJE/004 received 08 Aug 2024

Intention-to-treat and efficacy-estimand results are combined without distinction

Several contributing trials report both a treatment-policy result and an efficacy result that censors at discontinuation. The draft draws from whichever is reported first in each paper.

The respondent, a trial statistician, states that the two answer different questions, that the difference is substantial where discontinuation is common, and that a synthesis should choose one and say which.

Declared interest. Employed by a university department that has received unrestricted research funding from a manufacturer of a compound in the class under assessment. The respondent had no role in that funding.
Secretariat responseAccepted27 Sep 2024

The secretariat accepts this submission. Mixing estimands within a single pooled estimate is a defect of the synthesis rather than of the trials.

The treatment-policy estimand is used throughout as the primary analysis, the efficacy estimand is reported as a secondary analysis where available, and the estimand used is stated in every row of the summary of findings.

Dr Georgiana Mountstephen, MSc (Epidemiology) Academic clinical pharmacology unit
DRAFT-ORAL-VS-INJE/010 received 10 Aug 2024

Subgroup findings are reported that were not registered in the protocol

The draft reports differences between subgroups that do not appear in the registered protocol. The respondent states that unregistered subgroup analysis is hypothesis-generating and that the draft presents it in the same form as the pre-specified results.

The respondent proposes that unregistered analyses be removed.

Declared interest. Is an employee of a marketing-authorisation holder for a compound named in the draft. This submission is made on behalf of that company and is identified as an industry submission throughout.
Secretariat responseAccepted in part25 Sep 2024

The secretariat accepts this submission in part. The analyses are retained and relabelled rather than removed, because removing an analysis that was conducted leaves no record that it was.

Every subgroup analysis is now labelled as pre-specified or post hoc against the registered protocol, post hoc analyses are reported in a separate subsection without a certainty rating, and the protocol version against which the labelling was made is stated.

Dr Vittoria Ylönen, MD, FRCS Academic peptide-chemistry group
DRAFT-ORAL-VS-INJE/015 received 14 Aug 2024

Patient-reported outcomes are collected by the trials and not reported by the review

The respondent, a trustee of a patient organisation, states that several contributing trials measured quality of life and function and that the review reports neither, having selected outcomes on the basis of what could be pooled.

The respondent proposes that these outcomes be reported narratively where they cannot be pooled.

Declared interest. Is a member of the Institute's external reviewer register but did not review the document under consultation.
Secretariat responseAccepted in part14 Sep 2024

The secretariat accepts this submission in part. The outcomes are reported narratively. The proposal to pool them is declined because the instruments used are not comparable and pooling would produce a figure with no interpretation.

Patient-reported outcomes measured by any contributing trial are now reported narratively by instrument, with the instrument named and its minimum important difference stated where one is published, and the absence of a pooled estimate explained.

Dr Liesbeth Quenneville, MPharm, MRPharmS Academic nephrology unit
DRAFT-ORAL-VS-INJE/006 received 21 Aug 2024

The conclusion is stated more strongly than the certainty rating supports

The draft rates the anchor outcome at low certainty and then states in the conclusion that the intervention is effective. The respondent states that the two sentences cannot both be true as written.

The respondent proposes that conclusion language be tied mechanically to the certainty rating, so that a low rating cannot produce an unqualified claim.

Declared interest. Is a member of the Institute's external reviewer register but did not review the document under consultation.
Secretariat responseAccepted21 Sep 2024

The secretariat accepts this submission. The mismatch is the failure mode the certainty framework exists to prevent.

Conclusion wording is now drawn from a fixed set of formulations tied to the certainty rating, so that a low certainty rating produces a statement that the evidence may suggest an effect and that the estimate is likely to change with further research.

Dr Jolanta Uttridge, MD, PhD Academic mass-spectrometry core facility
DRAFT-ORAL-VS-INJE/009 received 21 Aug 2024

Statistical heterogeneity is treated as though it measured clinical heterogeneity

The draft reports a heterogeneity statistic and proceeds to pool where it is low. The respondent states that a low statistic in a small set of trials is uninformative, and that clinical and methodological similarity should be assessed before any statistic is consulted.

The respondent proposes that the decision to pool be justified on clinical grounds first and that the statistic be reported as a description rather than used as a threshold.

Declared interest. Has used a compound in the class under assessment under prescription. Declared at the Institute's request; the Institute regards a lived-experience declaration as an interest and not as a disqualification.
Secretariat responseAccepted in part13 Sep 2024

The secretariat accepts this submission in part. The decision to pool is now made on clinical and methodological grounds and stated as such. The statistic continues to be reported, because readers expect it and its absence would be read as concealment.

The decision to pool is now justified in prose against the population, intervention, comparator and outcome before any statistic is presented, and the heterogeneity statistic is reported with its confidence interval and a note of the number of contributing studies.

Quentin Gwynne-Sarpong, MD, DPhil Metabolic medicine service, tertiary centre
DRAFT-ORAL-VS-INJE/001 received 31 Aug 2024

Efficacy outcomes are rated for certainty and harms are not

The draft assigns certainty ratings to the efficacy outcomes and reports harms narratively without ratings. The respondent states that the asymmetry implies harms are less amenable to assessment when they are simply less well measured.

The respondent proposes that harms carry certainty ratings on the same scale, with the reasons for downgrading stated.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted21 Sep 2024

The secretariat accepts this submission. Rating one side of the balance and not the other produces a document that cannot be used to weigh them.

Every reported harm now carries a certainty rating on the same scale as the efficacy outcomes, with the downgrade reasons stated, and discontinuation for adverse events appears in the summary of findings rather than in an annex.

References cited on this page

References are numbered in order of first citation in this document. Each superscript in the text links to its entry below.

  1. International Organization for Standardization. ISO/IEC 17025:2017 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC Standard 2017;3rd edition. identifier not held by the Institute

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