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 monograph: Thymosin alpha-1 — submissions

The 13 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-082/2
Series
Public comment period
Version
1.0
Published
13 Nov 2024
Last reviewed
13 Nov 2024
Next review
13 Nov 2025
Identifier
10.71829/cei.cp.82
Certainty
Not rated
Cycle
2024 Q3
Window
09 Aug 2024 – 08 Oct 2024
Status
Closed
Submissions
13

§2Submissions and responses

13 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 Melisande Thorsby-Nakamura, PhD (Medicinal Chemistry) University department of public health
DRAFT-THYMOSIN-ALP/007 received 12 Aug 2024

A sortable table implies a comparison the underlying data do not support

The draft presents a sortable table whose columns are drawn from sources of differing quality. The respondent states that sorting on such a column produces an ordering that looks like a ranking and is not one.

The respondent proposes that sorting be disabled on any column whose values are not commensurable.

Declared interest. Employed by an analytical laboratory that performs contract testing for suppliers, including at least one supplier named in the Institute's assessment set.
Secretariat responseNoted, no amendment31 Oct 2024

The secretariat notes this submission and records that the point is correct in principle.

No amendment arises here because every sortable table in the document set already carries a standing statement above it that the ordering is not a ranking and that the values in each column are commensurable only where the column header says so. The proposal to disable sorting was considered and not adopted, because a reader who cannot sort a table generally sorts it elsewhere and without the statement.

Dr Abimbola Sotomayor-Ekwueme, PharmD, PhD Reader in Pharmaceutics
DRAFT-THYMOSIN-ALP/013 received 15 Aug 2024

The certainty rating for the principal assessed outcome cannot be traced to the contributing trials

The draft states a certainty rating for the principal assessed outcome and lists the contributing trials, but does not state which domain drove the downgrade. A reader who disagrees with the rating cannot tell whether the disagreement concerns risk of bias, imprecision, indirectness or inconsistency.

The respondent proposes that each rating carry its downgrade reasons explicitly, in the same row as the rating, so that a reader can accept the evidence assessment while disputing a single domain judgement.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted23 Oct 2024

The secretariat accepts this submission. A rating without its reasoning is an assertion, and the draft asserted rather than showed.

Each assessed outcome now carries its downgrade domains in the summary-of-findings row, with a short statement of the judgement made in each, so that the rating can be checked domain by domain against the contributing trials.

Dr Sigrún Lavrentiev, PhD (Toxicology) Health-technology assessment agency
DRAFT-THYMOSIN-ALP/006 received 19 Aug 2024

Trials are described as terminated where they completed as planned

The respondent states that the draft uses the word terminated for trials stopped at pre-specified interim analyses, for trials stopped for futility and for trials closed for commercial reasons, and that these are three different facts.

The respondent proposes that the status vocabulary be fixed and defined in the glossary.

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 responseAccepted in part04 Nov 2024

The secretariat accepts this submission in part. The vocabulary is fixed and defined. The proposal to distinguish commercial closure from futility in every case is accepted only where the Institute holds a document stating the reason.

Trial status now uses a fixed vocabulary defined in the glossary, and where the reason for stopping is not evidenced by a document the Institute holds, the status is recorded as stopped with the reason not established rather than assigned.

Dr Jacinta Steenkamp-Ferreira, PharmD, PhD University teaching hospital, department of endocrinology
DRAFT-THYMOSIN-ALP/004 received 25 Aug 2024

References should carry a persistent identifier for every cited source

Several references in the draft carry a journal, a year and a volume but no persistent identifier. The respondent, who works in a library setting, states that retrieval of such a reference is materially slower and that identifiers should be supplied throughout.

The respondent asks in the alternative that where an identifier exists but is not carried, the omission be explained rather than left as a gap the reader must interpret.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted in part01 Nov 2024

The secretariat accepts the second limb of this submission and declines the first. Identifiers are supplied wherever the Institute holds one. Where the Institute does not hold an identifier it will not supply one, because a reconstructed identifier that resolves to the wrong record is a worse defect than an absent one.

Every reference without a persistent identifier now carries an explicit statement that the identifier is not held by the Institute, so that its absence is a recorded fact rather than an apparent oversight.

Ivo Mountstephen, PhD (Medicinal Chemistry) University department of public health
DRAFT-THYMOSIN-ALP/011 received 30 Aug 2024

The document set should be published in translation

The respondent notes that the assessments concern compounds supplied internationally and that publishing only in English restricts access to the assessment to readers who work in it.

The respondent proposes machine translation of the document set as an interim measure, with human review of the certainty language.

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 responseNot accepted27 Oct 2024

The secretariat does not accept this submission, and records that the underlying point is sound and that the proposed remedy is the difficulty.

A translation whose certainty language has drifted is a different assessment carrying the Institute's name, and the Institute cannot review translations it does not have the capacity to review. The documents remain in English. The submission is published in full because the access problem it identifies is real and unresolved.

Radoslava Palmgren-Kofi, PhD (Medicinal Chemistry) University department of public health
DRAFT-THYMOSIN-ALP/005 received 31 Aug 2024

Evidence for one member of the class is presented as evidence for this compound

The draft supports a statement about this compound with a citation to a trial of a different compound in the same class. The respondent states that a class-level inference is a judgement that should be labelled as one rather than presented as direct evidence.

The respondent proposes that any class-level extrapolation be flagged at the point of use and excluded from the certainty rating for the compound itself.

Declared interest. Has received honoraria for educational lectures from a marketing-authorisation holder of a compound named in the draft, within the preceding three years.
Secretariat responseAccepted31 Oct 2024

The secretariat accepts this submission. Moderate certainty evidence supports several class-level statements in this area, but a class-level statement is not evidence about a particular member of the class.

Class-level inferences are now labelled at the point of use, are excluded from the certainty rating for the compound, and are reported in a separate subsection stating which compound the underlying evidence concerns.

Dr Dmitri Nordhagen, PhD (Chemistry), MRSC University department of pharmacy practice
DRAFT-THYMOSIN-ALP/009 received 10 Sep 2024

Adverse event frequencies are given without the denominator or the exposure period

The draft reports adverse event frequencies as percentages. The respondent states that a percentage without a denominator and without an exposure period cannot be compared with any other figure, including the corresponding figure in the comparator arm.

The respondent proposes that every frequency carry the number of participants and the exposure period over which it was observed.

Declared interest. Has previously served as an investigator on a trial included in the evidence base under consultation. Received no personal payment; institutional payment was made to the trial site.
Secretariat responseAccepted01 Nov 2024

The secretariat accepts this submission. A frequency detached from its denominator is a number without a quantity.

Every reported frequency now carries the number of participants, the number of events and the exposure period, and comparator-arm figures are reported alongside rather than in a separate table.

Dr Lorcan Zaleski-Mbeki, MPharm, MRPharmS Academic nephrology unit
DRAFT-THYMOSIN-ALP/002 received 15 Sep 2024

The search date is not on the face of the document

The draft carries a publication date and a review date but not the date on which the evidence was last searched. Those are three different dates and only the third tells a reader how current the assessment is. A document published in one quarter may rest on a search run two quarters earlier, and nothing on the page allows that gap to be measured.

The respondent proposes that the search date be printed adjacent to every certainty rating rather than in the methods section, on the ground that a reader who acts on a rating is unlikely to have read the methods section first.

Declared interest. Holds a patent relating to a delivery technology referenced in the draft.
Secretariat responseAccepted31 Oct 2024

The secretariat accepts this submission. The distinction between publication, review and search dates is real and the draft did not make it visible where it mattered.

The search date is now printed adjacent to every certainty rating and is carried in the document metadata, so that the interval between the search and the reading is visible without reference to the methods section.

Dr Mordecai Bellingham-Ojo, RN, MSc (Advanced Practice) Sleep and respiratory medicine service
DRAFT-THYMOSIN-ALP/003 received 16 Sep 2024

The analytical section assumes a reference standard that is not generally available

The draft describes identity and content determinations that require a reference standard of assigned content. For this compound no such standard is in general circulation, and a laboratory following the section as written cannot perform the determination described.

The respondent, employed by a contract analytical laboratory, proposes that the monograph state explicitly where a reference standard is unavailable and what a determination performed without one can still establish.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted20 Oct 2024

The secretariat accepts this submission. The section described an ideal case and did not say so.

The analytical section now states whether a reference standard is in general circulation for this compound and, where it is not, states which determinations remain possible and which become qualitative. A content figure obtained without a reference standard is recorded as an estimate against a stated assumption rather than as a determination.

Dr Wilhelmina Quaresma, PharmD, BCPS Regulatory affairs, generic medicines sector
DRAFT-THYMOSIN-ALP/012 received 20 Sep 2024

The document should state what a reader ought to do

The draft assesses evidence and stops. The respondent, a practising clinician, states that a reader arriving at the document with a decision to make is left to convert an assessment into an action without help, and proposes that each document close with a recommendation.

The respondent argues that other evidence bodies issue recommendations and that declining to do so transfers the difficult part of the work to the reader.

Declared interest. Has received honoraria for educational lectures from a marketing-authorisation holder of a compound named in the draft, within the preceding three years.
Secretariat responseNot accepted23 Oct 2024

The secretariat does not accept this submission, and records that the point is a reasonable one rather than a misunderstanding.

The Institute assesses evidence and does not issue recommendations, because a recommendation embeds values and a resource context that the Institute does not hold and cannot state. That constitutional limit is published on the methodology page and is not varied by consultation. The submission remains published in full.

Dr Yehudit Yorkstone, MD, MPH Primary-care research network
DRAFT-THYMOSIN-ALP/008 received 28 Sep 2024

Doses are expressed in units that differ between sections

The draft expresses dose in milligrams in one section and in micrograms per kilogram in another, drawn from different sources without conversion. The respondent, a hospital pharmacist, states that this is the shape of error that reaches a patient.

The respondent proposes a single unit throughout, with the source unit retained in parentheses where a conversion was performed.

Declared interest. Holds a personal shareholding, below the Institute's materiality threshold, in a diversified fund with pharmaceutical sector exposure. No direct holding in any named company.
Secretariat responseAccepted09 Nov 2024

The secretariat accepts this submission. The inconsistency was inherited from the sources and should have been resolved in drafting.

A single dose unit is now used throughout each monograph, with the source unit retained in parentheses wherever a conversion was applied, and every conversion is stated rather than performed silently.

Dr Liesbeth Quenneville, MPharm, MRPharmS Academic nephrology unit
DRAFT-THYMOSIN-ALP/010 received 01 Oct 2024

A near-isobaric analogue is not distinguished by the identity determination described

The identity determination described in the draft resolves the compound from unrelated substances but would not distinguish it from a closely related analogue whose mass differs by approximately one dalton.

The respondent proposes that the monograph state the resolution required for that discrimination, and state that a nominal-mass instrument reporting an integer mass has not made it.

Declared interest. Is a practising clinician who prescribes compounds in the class under assessment. No financial relationship with any manufacturer.
Secretariat responseAccepted09 Nov 2024

The secretariat accepts this submission. The point is decisive where one member of a near-isobaric pair is an approved medicine and the other is not.

The analytical section now states the resolving power required to discriminate the pair, names the pair explicitly, and records that an identity claim made below that resolution is not conformant with the identity standard.

Dr Katarzyna Yorkstone, MD, MRCP Independent analytical consultancy
DRAFT-THYMOSIN-ALP/001 received 08 Oct 2024

Registered trials that never reported are absent from the monograph

The respondent states that the trial list appears to be drawn from published reports, and that registered trials which completed without a report are therefore invisible. The proportion of a programme that never reported is itself a finding about the evidence base.

The respondent proposes that every registered trial of the compound be listed, with its reporting status, whether or not a report exists.

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 responseAccepted09 Nov 2024

The secretariat accepts this submission. A trial list built from publications reproduces publication bias in the shape of the document.

The trial list now includes every registered trial the Institute identified, with its reporting status stated, and the monograph reports the proportion of registered trials for which no result has been posted or published.

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

Identifiers are reproduced only where the Institute holds them. Where a digital object identifier or PubMed identifier is not shown, the Institute has recorded the journal and year and has not constructed an identifier.

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